oversight

TANF Electronic Benefit Cards: Some States Are Restricting Certain TANF Transactions, but Challenges Remain

Published by the Government Accountability Office on 2012-07-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to the Ranking Member,
             Committee on Homeland Security and
             Governmental Affairs, U.S. Senate


July 2012
             TANF ELECTRONIC
             BENEFIT CARDS
             Some States Are
             Restricting Certain
             TANF Transactions,
             but Challenges
             Remain




GAO-12-535
                                               July 2012

                                               TANF ELECTRONIC BENEFIT CARDS
                                               Some States Are Restricting Certain TANF
                                               Transactions, but Challenges Remain
Highlights of GAO-12-535, a report to the
Ranking Member, Committee on Homeland
Security and Governmental Affairs, U.S.
Senate



Why GAO Did This Study                         What GAO Found
The TANF block grant program                   Six of the 10 states reviewed by GAO took steps aimed at preventing certain
provides federal grants to states for          Temporary Assistance for Needy Families (TANF) transactions determined to be
various benefits and activities,               inconsistent with the purpose of TANF, despite no federal requirement to do so at
including cash welfare for needy               the time. Restrictions are based on selected states’ laws, executive orders, and
families with children. TANF is                other regulations, and generally cover certain locations or certain types of
overseen at the federal level by HHS,          purchases such as alcohol. In some cases, states’ restrictions are broader than
and administered by states. Most               the new federal requirements. These restrictions vary in their degree and means
states disburse TANF cash assistance           of implementation, including widespread disabling of Electronic Benefit Transfer
through electronic benefit cards, which
                                               (EBT) access at automated teller machines located at certain locations across a
can be used to withdraw money or
                                               state, such as at casinos. The other 4 states had no restrictions because no
make purchases. Media coverage
highlighted cases of cardholders
                                               laws, executive orders, or other regulations prohibited certain transactions based
accessing benefits at casinos and              on the location of the transactions or the nature of the goods or services
other locations that were considered           purchased. These states did not implement restrictions due to concerns about
inconsistent with the purpose of TANF.         cost-effectiveness or technical limitations, according to state officials.
In February 2012, Congress passed a            Challenges experienced by states in implementing their current restrictions could
law requiring states to prevent certain        inhibit future restriction efforts, including those intended to address new federal
transactions at casinos, liquor stores,        requirements. These challenges included difficulties with identifying certain
and adult-entertainment
                                               locations that could be prohibited and limitations in available data. For example,
establishments. Within 2 years of
                                               the transaction data states receive do not contain information that is accurate or
enactment, the law also requires HHS
to oversee states’ compliance with             detailed enough for them to identify locations that can potentially be prohibited or
these requirements.                            restricted. State officials suggested that improvements in the completeness and
                                               accuracy of transaction data might better enable them to prevent such
GAO was asked to review the ability of         transactions. In its assessment of the EBT transaction data from 4 states, GAO
TANF recipients to withdraw TANF               found that the data are insufficient for systematic monitoring. To effectively
funds at certain locations inconsistent        conduct systematic monitoring, including the identification of locations that could
with the purpose of TANF, such as              be blocked from TANF access, data should be complete and accurate. However,
gambling or other establishments. To           addressing the limitations that GAO found in the transaction data—such as
do so, GAO reviewed documentation
                                               requiring accurate merchant category codes for retailers—could involve
and interviewed officials from HHS, key
                                               significant resources. States that prohibit certain types of purchases generally do
industry stakeholders, and the top 10
states in TANF basic block grant               not have ways to track what items recipients buy with their cards, partially due to
dollars. GAO also assessed the                 the lack of information in transaction data on specific goods or services
completeness and accuracy of EBT               purchased. States were also challenged in attempting to track the spending of
transaction data from federal fiscal           cash withdrawn with cards. With no controls on how or where individuals spend
year 2010 from 4 of the 10 states              withdrawn cash, a recipient could withdraw money at an authorized location and
selected. GAO selected these 4 states          use it at certain locations or for certain purchases restricted by some states.
on the basis of geographical diversity,        As of July 2012, the Department of Health and Human Services (HHS) was at
and the results of this data analysis
                                               the beginning of its rulemaking process and did not yet know what form its
cannot be generalized to other states.
                                               regulations would take. Until HHS issues regulations or provides further guidance
What GAO Recommends                            as to what policies and practices are sufficient to comply with new federal
                                               requirements, it is unclear to what extent the various restrictions implemented by
GAO is not making any                          states would be in compliance. States’ restrictions could help inform HHS’s
recommendations.                               oversight efforts, especially any information on the cost-effectiveness and
                                               success rates for various state restrictions. Restriction methods that do not rely
                                               on flawed transaction data may be the most practical.
View GAO-12-535. For more information,
contact Gregory D. Kutz at (202) 512-6722 or   We provided HHS with a draft of our report for comment. HHS stated that our
kutzg@gao.gov.                                 report’s findings and analysis will be helpful as it drafts implementing regulations,
                                               and it provided technical comments that we incorporated, as appropriate.
                                                                                        United States Government Accountability Office
Contents


Letter                                                                                     1
               Background                                                                  4
               Some States Are Restricting Certain TANF Transactions, but Face
                 Challenges Because of Data Limitations and Other Factors                 9
               Concluding Observations                                                   28
               Agency and State Comments                                                 29

Appendix I     Objectives, Scope, and Methodology                                        30



Appendix II    Print-Friendly Version of Figure 1                                        32



Appendix III   Comments from the Department of Health and Human Services                 34



Appendix IV    GAO Contact and Staff Acknowledgments                                     36



Table
               Table 1: Some States Have Taken Steps Aimed at Preventing
                        Unauthorized TANF Transactions                                   32


Figure
               Figure 1: Some States Have Taken Steps Aimed at Preventing
                        Unauthorized TANF Transactions                                   10




               Page i                                GAO-12-535 TANF Electronic Benefit Cards
Abbreviations

AFDC              Aid to Families with Dependent Children
ATM               automated teller machine
BIN               bank identification number
CDSS              California Department of Social Services
DSHS              Washington State Department of Social and Health
                   Services
EBT               Electronic Benefit Transfer
EPC               electronic payment card
FNS               Food and Nutrition Service
HHS               Department of Health and Human Services
HHSC              Texas Health and Human Services Commission
MOE               maintenance of effort
OSI               California Office of Systems Integration
POS               point-of-sale
PRWORA            Personal Responsibility and Work Opportunity
                   Reconciliation Act of 1996
SNAP              Supplemental Nutrition Assistance Program
TANF              Temporary Assistance for Needy Families
TIGER             Topologically Integrated Geographic Encoding and
                   Referencing
USDA              Department of Agriculture

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Page ii                                          GAO-12-535 TANF Electronic Benefit Cards
United States Government Accountability Office
Washington, DC 20548




                                   July 20, 2012

                                   The Honorable Susan M. Collins
                                   Ranking Member
                                   Committee on Homeland Security and Governmental Affairs
                                   United States Senate

                                   Dear Senator Collins:

                                   The Department of Health and Human Services (HHS) oversees states’
                                   administration of the Temporary Assistance to Needy Families (TANF)
                                   program to provide cash assistance, childcare, and other services to low-
                                   income families. Among the program’s goals are the promotion of job
                                   preparation, employment, and marriage among parents of dependent
                                   children. HHS oversees the program at the federal level and distributes
                                   $16.5 billion in annual federal block grants to states to provide benefits
                                   and services to recipients. As a federal block-grant program, TANF allows
                                   states broad flexibility in designing and implementing their programs. To
                                   purchase goods and services, TANF recipients receive cash assistance,
                                   which in most states they can access at automated teller machines
                                   (ATM), banks, or retailers, using Electronic Benefit Transfer (EBT) cards.
                                   Cash assistance may be used for goods and services, and the amount of
                                   cash assistance received can vary by state. 1 The EBT cards are similar to
                                   debit or stored-value cards, but do not carry a line of credit, and the
                                   purchases or withdrawals made with these cards cannot exceed the
                                   amount of recipients’ TANF benefits as determined by each state’s TANF
                                   program.

                                   Until February 2012, there were no nationwide federal requirements for
                                   states to take steps aimed at preventing access to TANF cash assistance
                                   at certain locations. However, media coverage in some states highlighted
                                   cases of individuals accessing cash or conducting transactions at
                                   gambling establishments, adult-entertainment establishments, and liquor
                                   stores that could be considered inconsistent with the TANF program. In
                                   response, some states took steps aimed at implementing certain


                                   1
                                    TANF cash benefits are set by states. In July 2010, the maximum monthly benefit for a
                                   family of three ranged from $923 in Alaska to $170 in Mississippi. Benefits in all states
                                   represent a fraction of poverty-level income. In the median jurisdiction (Kansas), the
                                   maximum monthly benefit was $429 for a family of three.




                                   Page 1                                           GAO-12-535 TANF Electronic Benefit Cards
restrictions that would prevent such transactions. In February 2012,
Congress passed, as part of the Middle Class Tax Relief and Job
Creation Act of 2012, the Welfare Integrity and Data Improvement Act,
which requires all states to maintain policies and practices as necessary
to prevent TANF assistance from being used in any electronic benefit
transfer transaction in (1) liquor stores; (2) casinos, gambling casinos, or
gaming establishments; and (3) adult-oriented entertainment
establishments in which performers disrobe or perform in an unclothed
state for entertainment. 2 States must report to HHS the steps they have
taken to implement such policies and practices by February 22, 2014.

In this context, you asked us to review the ability of TANF recipients to
withdraw TANF funds at certain locations inconsistent with the purpose of
TANF, such as gambling or other establishments. To understand this
ability better, we reviewed actions selected states have taken to prevent
unauthorized TANF transactions, and the challenges they can face in
taking such steps in compliance with new federal legislation. 3 To perform
our work, we reviewed TANF laws, regulations, and other documentation
and interviewed officials from HHS. We also reviewed documentation and
interviewed officials from the top 10 states in terms of TANF basic block-
grant dollars—California, New York, Michigan, Ohio, Pennsylvania,
Illinois, Florida, Texas, Massachusetts, and Washington. These 10 states
received the greatest TANF basic block-grant dollars, and collectively
represent 66 percent of the TANF basic block grants funded in federal
fiscal year 2012. In addition, we interviewed and reviewed documentation
from key industry stakeholders, including EBT vendors, related to the
selected states’ efforts to prevent unauthorized TANF transactions.

We also obtained EBT card-transaction data from 4 of the 10 selected
states—California, Florida, New York, and Texas—covering transactions
from federal fiscal year 2010. 4 We selected these 4 states on the basis of
geographical diversity. The results of our analysis of these 4 states’ data
cannot be generalized to other states. Using these data, we assessed the
extent to which the data would allow the 4 selected states to conduct
systematic monitoring to identify unauthorized transactions. To do so, we


2
 Pub. L. No. 112–96, § 4004, 126 Stat. 156, 197 - 198.
3
 For the purposes of this report, we consider “unauthorized” to mean all TANF
transactions that are prohibited under state laws, regulations, policies, or other actions.
4
 October 1, 2009, to September 30, 2010.




Page 2                                            GAO-12-535 TANF Electronic Benefit Cards
used a generalizable, random sample of each of the 4 selected states’
EBT transaction data 5 and compared it to electronic geo-coding
information that pinpoints places and identifies locations. 6 We also
assessed whether the data would allow the 4 selected states to identify
individual TANF transactions at certain types of locations by conducting
keyword searches of merchant names for terms associated with casinos,
liquor stores, and adult-entertainment establishments. We conducted
electronic data testing to determine the reliability of the California, Florida,
New York, and Texas EBT data. For all four states, we determined that
the EBT data are not sufficiently reliable for the purpose of performing
systematic monitoring of transactions in locations that are inconsistent
with the purposes of TANF. However, EBT transaction data are
sufficiently reliable for the purpose of identifying examples of transactions
with merchant names that contain words associated with casinos, liquor
stores, and adult-entertainment establishments. A more-detailed
description of our scope and methodology is provided in appendix I.

We conducted this performance audit from October 2011 to July 2012 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




5
 The random samples can only generalize about each state using each state’s sample,
not about other states and not nationally. For example, the Texas sample tells us
something general about the Texas EBT data as a whole, but cannot tell us anything
about the California data or all EBT transaction data nationally.
6
 We compared EBT transaction addresses to U.S. Census Bureau’s Topologically
Integrated Geographic Encoding and Referencing (TIGER) standard addresses.




Page 3                                        GAO-12-535 TANF Electronic Benefit Cards
Background
TANF Funding and   The Personal Responsibility and Work Opportunity Reconciliation Act of
Program Goals      1996 (PRWORA) 7 significantly changed federal welfare policy for low-
                   income families with children, from a program that entitled eligible families
                   to monthly cash payments to a capped block grant that emphasizes
                   employment and work supports for most adult recipients. As part of
                   PRWORA, Congress created the TANF program, 8 through which HHS
                   provides states about $16.5 billion each year in block grant funds to
                   implement the program. To receive the TANF block grant, each state
                   must also spend at least a specified level of its own funds, which is
                   referred to as state maintenance of effort (MOE). 9 In creating the TANF
                   block grant, PRWORA defines four goals for the program:

                   1. provide assistance so that children could be cared for in their own
                      homes or in the homes of relatives;
                   2. end families’ dependence on government benefits by promoting job
                      preparation, work, and marriage;
                   3. prevent and reduce the incidence of out-of-wedlock pregnancies; and
                   4. encourage the formation and maintenance of two-parent families.

                   TANF is a flexible funding stream that states can use to provide cash
                   assistance and a wide range of services that are “reasonably calculated”
                   to further the program’s four goals. 10 In federal fiscal year 2011, states
                   used about 29 percent of their TANF funds on basic assistance that
                   included cash assistance for needy families, 11 and the remaining funds
                   were spent on other purposes, such as child care, employment programs,


                   7
                   Pub. L. No. 104-193, 110 Stat. 2105.
                   8
                    TANF replaced the Aid to Families with Dependent Children (AFDC) program. Id. §
                   103(a)(1), 110 Stat. 2105, 2112.
                   9
                    42 U.S.C. § 609(a)(7); 45 C.F.R. §§ 263.1 – 263.9. To meet the MOE requirement, each
                   state must generally spend 75 or 80 percent of what it spent in fiscal year 1994 on
                   welfare-related programs, including AFDC, Job Opportunities and Basic Skills Training,
                   Emergency Assistance, and AFDC-related child-care programs.
                   10
                       42 U.S.C. § 604(a).
                   11
                     Throughout this report, we refer to families receiving TANF cash assistance, for ease of
                   reporting. However, this is a simplification of PRWORA, which actually refers to families
                   receiving “assistance.” 42 U.S.C. § 603.




                   Page 4                                          GAO-12-535 TANF Electronic Benefit Cards
                       and child welfare services. 12 Due to the flexibility given to states, TANF
                       programs differ substantially by state. States are required to develop
                       plans that outline their intended use of funds and report data on families
                       receiving assistance. While the federal TANF statute does not define
                       “assistance,” HHS defines assistance in regulation as cash payments,
                       vouchers, and other forms of benefits designed to meet a family’s
                       “ongoing basic needs,” such as food, clothing, shelter, utilities, household
                       goods, personal-care items, and general incidental expenses. 13


TANF Cash Assistance   Traditionally, states disbursed cash assistance benefit payments by
Disbursement Methods   means of paper check. The EBT program was devised in the 1980s
                       originally to meet the needs of the Department of Agriculture’s (USDA)
                       Food Stamp Program, in which federal benefits were electronically
                       disbursed to eligible recipients. These cards are not tied to a consumer
                       asset account, and generally the account structures and processing
                       requirements differ from other payment cards. EBT cards can be used to
                       deliver benefits to banked and unbanked recipients and can be used to
                       deliver multiple benefits using a single card. The cost savings in the Food
                       Stamp Program (now known as the Supplemental Nutrition Assistance
                       Program or SNAP) from using electronic payments to distribute benefits
                       prompted states to use EBT cards to also distribute TANF benefits
                       electronically, leveraging the existent EBT system designed for SNAP.
                       Electronic benefit distribution methods also include Electronic Payment
                       Cards (EPC). Some EPC cards are prepaid or debit cards that are
                       branded with a MasterCard, American Express, Discover, or Visa logo,
                       which allows cardholders to conduct signature-based transactions
                       anywhere that those brands are accepted as well as at ATM and point-of-
                       sale (POS) machines.

                       Electronic benefit cards—both EBT and EPC—generally can be used like
                       traditional debit or credit cards, in that recipients can use them at ATMs to
                       withdraw cash, or at retailers’ POS terminals for purchases or to receive
                       cash by selecting a cash-back option. However, there are some key
                       differences between the electronic benefit card and commercial credit



                       12
                         States may use TANF funds to support a variety of child welfare services, such as
                       screening for child abuse and neglect, case-management activities, and cash assistance
                       and services for relative caregivers.
                       13
                        45 C.F.R. § 260.31.




                       Page 5                                         GAO-12-535 TANF Electronic Benefit Cards
                          cards. The main difference is that electronic benefit cards do not carry a
                          credit line, and the purchases or withdrawals made with these cards
                          cannot exceed the amount of recipients’ TANF benefits. With commercial
                          credit cards, cardholders borrow to make a purchase and then pay the
                          money back later. Electronic benefit cards are more like debit or stored-
                          value cards and provide an alternative to cash—each time that a
                          cardholder uses his or her electronic benefit card, the money spent or
                          withdrawn is deducted from the cardholder’s TANF benefits account.

                          States consider various factors when implementing EBT or EPC
                          programs, including potential financial burden to recipients, such as
                          transaction fees at ATMs that charge a surcharge for each transaction;
                          recipient characteristics, such as disabilities; implementation costs; and
                          fraud and security risks. States also take into account how readily
                          recipients can access cash assistance. For example, in some rural areas
                          or low-income neighborhoods the only access point for cash assistance
                          benefits may be a location such as a grocery store, single depository
                          institution, or even a liquor store. Some of the benefits to recipients from
                          states choosing EBT or EPC programs include quicker disbursement of
                          benefits, the elimination of lost or undelivered paper checks, access to
                          benefits without an established bank account, and no need to locate
                          check-cashing venues in order to access benefits.


Recent TANF Legislative   Prior to 2012, states were not required under federal law to take steps
Changes                   aimed at preventing specific TANF transactions at certain locations.
                          However, the Welfare Integrity and Data Improvement Act, part of the
                          Middle Class Tax Relief and Job Creation Act of 2012, signed into law on
                          February 22, 2012, introduced several changes to TANF that can affect
                          recipients’ ability to access cash assistance at certain locations. 14
                          Specifically, the Act requires that each state receiving a TANF block grant




                          14
                           Pub. L. No. 112–96, § 4004, 126 Stat. 156, 197 - 198.




                          Page 6                                        GAO-12-535 TANF Electronic Benefit Cards
maintain policies and practices as necessary to prevent TANF assistance
from being used in any “electronic benefit transfer transaction” 15 in

•     any liquor store; 16
•     any casino, gambling casino, or gaming establishment; 17 or
•     any retail establishment that provides adult-oriented entertainment in
      which performers disrobe or perform in an unclothed state for
      entertainment.

The Act calls for HHS to determine whether states have implemented and
maintained policies and practices to prevent such transactions, within 2
years of the Act’s enactment. If HHS determines that a state has not
implemented and maintained these policies and practices, or if a state
has not reported to HHS on its policies and practices, HHS may reduce
the state’s family assistance grant by an amount equal to 5 percent of the
state’s grant amount for the federal fiscal year following the 2-year period
after enactment and each succeeding federal fiscal year in which the
state does not demonstrate that it has implemented and maintained such
policies and practices. However, HHS may reduce the amount of this
penalty on the basis of the degree of noncompliance of the state in
question. In addition, the Act specifies that states are not responsible for
individuals who engage in fraudulent activity to circumvent the state’s
policies and practices, and will not face a reduction in their family
assistance grant amounts in such cases. 18




15
  The Act defines electronic benefit transfer transaction as “the use of a credit or debit
card service, automated teller machine, point-of-sale terminal, or access to an online
system for the withdrawal of funds or the processing of a payment for merchandise or a
service.” Id. § 4004(a), 126 Stat. 197.
16
  The Act defines liquor store as “any retail establishment which sells exclusively or
primarily intoxicating liquor. Such term does not include a grocery store which sells both
intoxicating liquor and groceries including staple foods (within the meaning of section 3(r)
of the Food and Nutrition Act of 2008 (7 U.S.C. 2012(r))).” Id.
17
  The Act states that the terms casino, gambling casino, and gaming establishment do not
include “(I) a grocery store which sells groceries including such staple foods and which
also offers, or is located within the same building or complex as, casino, gambling, or
gaming activities; or (II) any other establishment that offers casino, gambling, or gaming
activities incidental to the principal purpose of the business.” Id.
18
    Id., § 4004(b), 126 Stat. 197 - 198.




Page 7                                            GAO-12-535 TANF Electronic Benefit Cards
The Act also contains requirements for states related to maintaining
recipients’ access to TANF cash assistance. As part of the plan that each
state is required to submit to HHS, 19 states must include policies and
procedures to ensure that recipients have adequate access to their cash
assistance. In addition, states must ensure that recipients have access to
using or withdrawing assistance with minimal fees or charges, including
an opportunity to access assistance with no fees or charges, and that
they are provided information on applicable fees and surcharges that
apply to electronic fund transactions involving the assistance, and that
such information is made publicly available. 20

HHS issued a request for public comment in April 2012, seeking
information by June 2012 on: how states deliver TANF assistance to
beneficiaries, whether states have implemented policies and practices to
prevent electronic benefit transfer transactions at the locations mentioned
above, states’ experiences with these policies and practices, and other
similar restrictions states place on TANF assistance usage. 21 In its notice,
HHS identified multiple questions for states to answer, including
questions on the methods states use to track the locations where
transactions occur, challenges states experienced when implementing
any restrictions on transactions at certain locations, the initial and ongoing
costs of restrictions, the effectiveness of restrictions and the factors
influencing the effectiveness, and any concerns that have been raised
about the restrictions, among other things. In addition, HHS requested
input from states’ EBT vendors on potential issues that states may face in
implementing restrictions, including technical issues, cost implications,
access implications, and mechanisms for addressing problems identified.




19
 42 U.S.C. § 602(a).
20
 Pub. L. No. 112–96, § 4004(c), 126 Stat. 156, 198.
21
 77 Fed. Reg. 24667 (Apr. 25, 2012).




Page 8                                        GAO-12-535 TANF Electronic Benefit Cards
                        Six of the 10 states we reviewed have taken steps to prevent certain
Some States Are         types of inappropriate TANF transactions—restrictions that in some cases
Restricting Certain     are broader than recent federal requirements that require states to take
                        steps aimed at preventing transactions in casinos, liquor stores, and
TANF Transactions,      adult-entertainment establishments. These 6 states faced a variety of
but Face Challenges     challenges in identifying inappropriate locations and preventing
Because of Data         transactions at these locations. At the time these efforts were undertaken,
                        there were no federal requirements that required states to take steps
Limitations and Other   aimed at restricting such transactions. In addition, EBT transaction data
Factors                 from federal fiscal year 2010 from 4 of the 10 selected states were
                        generally incomplete or unreliable, and were of limited use to the states
                        for systematically identifying or monitoring inappropriate locations. While
                        the federal requirements to restrict inappropriate transactions now exist,
                        data issues and other challenges, if unaddressed, may continue to affect
                        efforts to comply with these new requirements.


Some States Have        Six of the 10 states we selected and reviewed have taken steps to
Attempted to Restrict   prevent certain types of TANF transactions; these actions vary in their
TANF Transactions       degree and means of implementation, from widespread disabling of EBT
                        access at ATMs in certain locations across a state to, according to
                        officials from one state, passing a law without implementing steps for
                        enforcing it. The restrictions generally involve prohibiting the use of EBT
                        cards at certain locations or prohibiting purchases of certain goods or
                        services, or both, as shown in figure 1 below. In 4 of the 10 selected
                        states, there were no restrictions on TANF transactions, as no
                        transactions were unauthorized based on the location of the transactions
                        or the nature of the goods or services purchased. As mentioned above,
                        before the 2012 enactment of federal legislation, states were not required
                        by the federal government to maintain or implement policies and practices
                        aimed at preventing TANF transactions based on the location of the
                        transactions. Figure 1 below, an interactive map, provides rollover
                        information (see interactive instructions below) that describes the steps
                        that selected states have taken aimed at preventing the use of TANF
                        cash assistance for certain purchases or in certain locations. (See app. II
                        for the steps taken within each selected state.)




                        Page 9                                  GAO-12-535 TANF Electronic Benefit Cards
Figure 1: Some States Have Taken Steps Aimed at Preventing Unauthorized TANF Transactions

 Interactive Graphic


    Some States Have Taken Steps Aimed at Preventing
    Unauthorized TANF Transactions
    Six of the 10 states we reviewed have taken steps aimed at preventing the use of TANF cash assistance for
    certain purchases or in certain locations. Figure 1 below, an interactive map, provides rollover information that
    describes the steps that selected states have taken.

          Instructions: Rollover the selected states for more information.



                           Washington




                                                                                           Michigan

              California
                                                                                                                      Massachusetts
                                                                                                            Pennsylvania




                                                                 Texas




                                                                                             Print Version: Click here or go to appendix II.


                                                Source: GAO
                                                  Source:   (data); Map Resources (map).
                                                          GAO.


                                                Page 10                                     GAO-12-535 TANF Electronic Benefit Cards
                           Some of the selected states experienced various challenges while
                           attempting to prevent certain TANF transactions. Some states’ restriction
                           activities were impeded by transaction data that did not allow them to
                           identify sufficiently or monitor locations that were prohibited in their state.
                           In some cases, states have attempted to address these challenges
                           through ongoing monitoring and other efforts. In addition, some of the
                           selected states’ restrictions currently lack means of enforcement. For
                           example, some states that prohibit certain types of purchases generally
                           do not have ways to track what items recipients buy with their cash
                           assistance, partially due to the lack of information in transaction data on
                           what items are bought with EBT cards. There are also challenges for
                           states in attempting to track cash spending. With no controls on how or
                           where individuals spend their cash benefits, a recipient could withdraw
                           money at an authorized location and then use it at certain locations or for
                           certain purchases restricted by some states.

States with Restrictions   California

                           In response to media attention, and a California executive order,
                           California’s Department of Social Services (CDSS) and its EBT vendor
                           took steps to disable TANF access at thousands of ATMs; however, they
                           have faced certain technical and legal limitations. In June 2010, the
                           Governor of California issued an executive order requiring that CDSS
                           prevent TANF recipients from accessing their benefits at ATMs in
                           gambling establishments. 22 The executive order resulted from news
                           reports that revealed that state TANF recipients had accessed their
                           benefits at ATMs located in gambling establishments. The order stated
                           that benefits are provided to pay for the families’ basic subsistence needs
                           and not for gambling. From June 2010 to December 2010, and pursuant
                           to this executive order, CDSS issued notices explaining its intent to
                           expand the number of locations where EBT access to TANF cash
                           assistance would be eliminated. This effort required disabling EBT access
                           at ATMs in locations that fall under at least 14 different prohibited
                           categories (see fig. 1 above).

                           Officials from CDSS and the state’s Office of Systems Integration (OSI)
                           worked with the state’s EBT vendor and other parties to identify and block
                           these locations from EBT access. For example, CDSS officials stated that



                           22
                            Cal. Exec. Ord. S-09-10 (June 24, 2010).




                           Page 11                                     GAO-12-535 TANF Electronic Benefit Cards
CDSS approached California’s casino commission, requesting that it
notify CDSS if it found EBT cards being used within licensed California
casinos. In addition, CDSS officials stated that they reached out to the
California Office of Alcoholic Beverage Control in order to determine,
identify, and deactivate liquor stores that were not already authorized by
the Food and Nutrition Service (FNS), which oversees the Supplemental
Nutrition Assistance Program (SNAP). To identify and block additional
locations, CDSS and OSI officials manually searched EBT transaction
records for business names that appeared to belong to one of the
prohibited categories. For example, OSI searched for terms such as
“beer,” “wine,” “spirit,” “tattoo,” “piercing,” and other words that related to
the prohibited categories. In addition, OSI used lists of tribal casinos and
card rooms located in the state and corresponding addresses to verify
against the EBT transaction data. After identifying potential locations to
be blocked, officials performed Internet searches to attempt to verify the
type of location. However, California officials noted that the accuracy of
Internet searches cannot be validated because it is not clear whether the
information on the Internet is current. For example, when looking at
satellite photos of streets on the Internet to verify a restricted location, the
Internet photo may show a vacant building or building under construction
because the photo could be 1 to 2 years old, according to California
officials.

Once officials confirmed that the businesses appeared to belong in one of
the 14 prohibited categories, then they provided the state’s EBT vendor
with locations that needed to be blocked. The vendor contacted the
responsible third-party processor to request that the ATMs at these
locations be disabled from accepting the state’s EBT card. To do so, the
processors deactivated the state’s bank identification number (BIN) at
each terminal. CDSS and OSI provided the state’s Department of Justice
with nonloaded EBT cards so that it could test ATMs at gambling
establishments to determine whether they are in compliance.

According to CDSS officials, as of February 2012, EBT access was
disabled at approximately 6,328 ATMs in California, out of a total of
approximately 35,400 ATMs in California that have performed EBT
transactions. However, state officials noted that they experienced
challenges with identifying locations to block. For example, according to
state officials, the EBT transaction data contain incomplete or inaccurate
fields, including key information on the location of transactions. California
officials said that the EBT transaction data sometimes contain misspelled
addresses, and do not provide information on what type of retailers were
involved for each transaction. In addition, California officials told us that


Page 12                                    GAO-12-535 TANF Electronic Benefit Cards
the address information included in the EBT transaction data is
sometimes that of retailers’ corporate offices rather than the location
where the transactions actually took place. State officials said that there is
no code available in the EBT transaction data that would allow them to
identify easily the nature of each retailer. 23 While their EBT vendor
receives merchant category codes for some ATM transactions, this
information has limitations because a known issue is that some ATMs
have the same merchant category code that identifies the location of the
transaction as a financial institution rather than any categories associated
with the particular nature of the business where the transaction occurred.
To work around the limitations in the EBT transaction data, California
officials told us that their staff conducted online research to verify whether
businesses actually fell under one of the state’s prohibited categories.
However, they said that this was a manual, time-intensive process that
involved making judgments about the nature of retailers, which can be
subjective and prone to error. According to California officials, some
ATMs at liquor stores were reactivated because they were initially
identified as liquor stores not authorized by the U.S. Department of
Agriculture’s Food and Nutrition Service (FNS), 24 but others were
reactivated because the storeowner applied for FNS authorization after
having the ATM deactivated. In those stores, the ATM was reactivated as
the new FNS authorization was verified.

California officials told us that their EBT vendor also conducts ongoing
monitoring of transaction data to identify terminals blocked formerly that
then change location or are reactivated, as well as transactions at new
locations with names that appear to fall under one of the state’s prohibited
categories. State officials also told us that the transaction data only allow
them to identify locations where transactions have already occurred, so
they are unable to assess the universe of locations that might fall under
prohibited categories. For example, although they disabled EBT access at
thousands of ATMs that have performed EBT transactions, as mentioned



23
  As discussed below, we identified limitations in the accuracy and completeness of the
transaction data from four states. In addition, officials from multiple states expressed
concerns about the data similar to our findings and the views of California officials.
24
  Any retailer that would like to allow its customers to use their federal food benefits from
the Supplemental Nutrition Assistance Program (SNAP) must be authorized by FNS to
participate in SNAP. According to FNS, the only form of SNAP benefit issuance is the EBT
card. EBT allows the retailer, such as a liquor store, to accept SNAP payment for food
using the EBT card.




Page 13                                           GAO-12-535 TANF Electronic Benefit Cards
above, officials said that there are likely many more ATMs that exist in the
state, but they cannot be identified until a transaction takes place there.
As a result, CDSS is unable to use the EBT transaction data and its
methodology noted above to identify all ATMs in California locations that
may fall under the 14 prohibited categories.

In addition, although CDSS has expressed its intent to disable TANF
access at POS devices that fall under the 14 categories, officials from
CDSS and the state’s EBT vendor told us that they have been unable to
disable EBT access at any POS terminals as of March 2012. CDSS
officials stated that POS terminals will be blocked sometime in the future,
but they did not know when this would occur because third-party
processors are finding it difficult to block POS terminals as opposed to
ATMs. For example, according to CDSS’s vendor, identification numbers
for POS terminals are generally not as unique as those assigned to
ATMs. Specifically, POS terminals located in many retailers in California
and across the country use the same terminal identification numbers as
opposed to unique terminal identification numbers, which may result in
third-party processors accidentally blocking POS terminals at locations
that were not intended to be blocked, including some that are located
outside of California.

Further, it is not illegal under California state law for a California resident
to use his or her EBT card at one of the prohibited locations. In fact,
California state law still includes a provision that specifically protects the
rights of individuals to spend their cash assistance as they want in
California. The California statute states, “[n]o person concerned with the
administration of a public assistance program shall dictate how any
recipient shall expend the aid granted to him.” 25 Implementing this statute,
CDSS’s Manual of Policies and Procedures: Eligibility and Assistance
Standards states “[e]ach individual or family has the right to manage
his/her own affairs; to decide what use of his/her money, including the aid
payment, will best serve his/her interests.” 26 Such broad treatment, while
consistent with California state law, raises questions about the extent to
which California’s current controls will help to ensure that cash assistance
is being used in a manner consistent with the purposes of the TANF
program and the new federal requirements. Until HHS issues regulations


25
 Cal. Welf. & Inst. Code § 10501.
26
 Cal. Dep’t. Soc. Serv. Manual Pol’y. & Proc. § 44-301.




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or provides further guidance as to what policies and practices are
sufficient to comply with the new federal requirements, it is unclear
whether there is any conflict between the new federal law and California’s
statute.

Massachusetts

Although Massachusetts has made certain TANF transactions illegal, the
state has not yet finalized plans for enforcing its legal restrictions and has
not blocked any transactions. Specifically, state TANF officials have not
yet taken steps aimed at enforcing the legal restrictions or monitoring
compliance. As of July 2011, Massachusetts state law prohibits
individuals from using their cash assistance to purchase alcohol, tobacco,
and lottery tickets. 27 Individuals who make a purchase in violation of the
law are required to reimburse the state for the purchase, and are also
banned from receiving benefits for varying periods, according to state
law. 28 The law also states that individuals or store owners who knowingly
accept direct cash assistance funds held on EBT cards for the purchase
of alcoholic beverages, lottery tickets, or tobacco products will be fined
not more than $500 for the first offense, not less than $500 or more than
$1,000 for the second offense, and not less than $1,000 for the third or
subsequent offense. 29 However, as of July 2012, Massachusetts had not
yet finalized plans for enforcing the law and had not blocked any
transactions. State officials told us that they are unable to track or identify
the types of items or services recipients actually purchase with the TANF
cash assistance withdrawn using their EBT cards at ATMs or POS
terminals. For example, according to state officials, EBT transaction data
do not contain information on what items are purchased using EBT cards.
According to a Massachusetts official, the state has not yet blocked any
purchases because it does not have the manual or technological
processes to do so.

In December 2011, Massachusetts law also mandated the creation of an
EBT Commission to study and report on, among other things, the use of
EBT cards for the purchase of products such as firearms, tobacco, lottery



27
 Mass. Gen. Laws ch. 18, § 5I.
28
 Id.
29
 Mass. Gen. Laws ch. 18, § 5J.




Page 15                                   GAO-12-535 TANF Electronic Benefit Cards
tickets, and alcohol. 30 The commission was tasked with developing
recommendations for the state legislature, including recommendations on
how to prevent the inappropriate use of EBT cards. The commission met
between February and March 2012 and determined that EBT transaction
data do not capture information on what items are purchased with EBT
cards, which makes blocking specific items from being purchased with an
EBT card impossible technologically. In compliance with, and in addition
to implementing the new federal law, the commission recommended and
stated that legislative members of the commission will file legislation in
Massachusetts that will ban EBT transactions at ATMs and POS
terminals in liquor stores, casinos and gaming establishments, adult-
oriented entertainment establishments, nail salons, tattoo parlors,
firearms dealers, bars/drinking establishments, smoke shops, and spas.
The commission discussed, but did not recommend, implementing further
restrictions on recipients’ use of cash. For example, the commission
considered, but chose not to recommend, limiting the amount of cash
assistance that can be withdrawn from ATMs or POS terminals either
entirely or to 50 percent of each recipient’s monthly cash benefit amount.
However, the commission determined that restricting cash access this
way could incentivize fraud and trafficking of EBT cards. In addition, the
commission did not want to cause additional hardship for recipients who
use their cash assistance appropriately to pay for rent, transportation, and
other essential costs. Moreover, the commission learned that its EBT
vendor did not have current functionality to restrict each recipient’s cash
access at ATMs to only 50 percent of his or her total monthly benefit
amount.

Michigan

Michigan has a procedure in place that prohibits certain uses of TANF
cash assistance, but does not have a way to track whether recipients
adhere to state requirements. Beginning in October 2011, Michigan law
required that TANF recipients’ family self-sufficiency plans—which
families must execute in return for receiving assistance—must include a
prohibition on using assistance to purchase lottery tickets, alcohol, or
tobacco, or for gambling, illegal activities or other nonessential items. 31 If
a recipient does not adhere to the requirements of his or her family self-


30
 2011 Mass. Acts ch. 219.
31
 Mich. Comp. Laws § 400.57e.




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sufficiency plan, the state can impose penalties based on the number of
instances of noncompliance. For example, the third instance of
noncompliance can result in the family being permanently ineligible from
receiving program assistance. 32 In addition to the prohibited items or
activities noted above, state policy also bars recipients from using cash
assistance for adult entertainment, massage parlors, spas, tattoo shops,
bail bond agencies, and cruise ships. 33 However, state officials told us
that they do not have any way to track how recipients spend cash
withdrawn with EBT cards, and that EBT card data do not include
information on what purchases recipients make with their cards.

In addition, in a letter sent to Michigan casinos in 2011, the state
governor’s office expressed its decision to correct flaws in Michigan’s
EBT card program, and tighten the rules for Michigan’s EBT card use by
prohibiting clients from using their EBT card to withdraw cash from any
ATM machine located in any casino in Michigan, due to reports of
possible abuse committed by some of Michigan’s TANF recipients. As a
result, state officials said that Michigan casinos contacted third-party
processors and financial institutions to ask that they block the state’s BIN
at ATMs located in the casinos, thereby cutting off EBT access there.
State officials told us that they later had the state’s EBT vendor conduct a
query to determine whether transactions were still occurring at casinos.
The vendor ran six separate queries, but identified no EBT transactions at
casinos after the EBT access was disabled, including one casino where
state officials said that they had previously identified $87,340 in EBT
transactions. State officials said that ATMs have not been blocked yet at
locations other than casinos. In addition, EBT access at POS terminals
has not yet been disabled at restricted locations, and state officials are
unaware of EBT access being disabled at POS terminals in Michigan
casinos. Michigan officials noted that EBT vendors do not have a suitable
electronic method of disabling the use of EBT cards in certain types of
businesses, whether at POS devices or at ATMs. Michigan officials noted
two contributing problems with identifying locations and disabling EBT
access at certain locations. First, identifying the type of location is
dependent on the business accurately reporting data on the nature of its
business, according to Michigan officials. Second, although the banking
and ATM industries are the entities that collect the business type and


32
 Mich. Comp. Laws § 400.57g.
33
 Michigan Bridges Eligibility Manual (BPB 2011-023) §§ 228, 230A, and 515.




Page 17                                      GAO-12-535 TANF Electronic Benefit Cards
location data, and they have the means to disable access at any location,
they have not been mandated to assist the states in this effort.

Pennsylvania

Pennsylvania prevents EBT use at state-run liquor stores and obtained
the cooperation of casinos in disabling EBT access on their premises. In
addition, since December 2009, it has been illegal under Pennsylvania
state law to purchase liquor or alcohol with an electronic benefits card. 34
Under Pennsylvania law, a person found to violate knowingly this law
shall be guilty of a misdemeanor, and, upon conviction, shall be
sentenced to pay a fine, not exceeding $100, or to undergo imprisonment,
not exceeding 6 months, or both. 35 Liquor stores in Pennsylvania are
operated by the state. According to state officials, these liquor stores do
not accept the state’s EBT card at POS devices, and there are no ATMs
in these state-run liquor stores. In response to bills introduced, but not
passed, in the state assembly that would have prohibited EBT access at
casinos, 36 state officials from the gaming control commission contacted a
third-party processor for ATMs at casinos to ask the processor to
deactivate the state’s bank identification number (BIN) from those
machines. State officials told us that they assessed the effectiveness of
the restrictions by sending staff members with working EBT cards to three
casinos to check in person whether the casinos’ ATMs accepted EBT
cards. Although some of the ATMs still accepted EBT cards at first, state
officials told us that those machines were eventually blocked from
accepting further EBT transactions. According to Pennsylvania officials,
when they conducted pilot monitoring of their restrictions, they had to look
up retailer information on the Internet because the transaction data did
not contain information that allowed them to determine what type of
businesses the retailers were.

Texas

As opposed to restricting categories of locations that had previously
accepted TANF EBT cards, the design of Texas’s TANF program places



34
 62 Pa. Cons. Stat. § 484.
35
 62 Pa. Cons. Stat. § 483.
36
 Pa. S.B. 975 (2011) and Pa. H.B. 1254 (2011).




Page 18                                      GAO-12-535 TANF Electronic Benefit Cards
limitations on the participation in the state EBT network of retailers that
derive most of their revenue from alcohol, gambling, adult entertainment,
and other functions. Since the mid-1990s, Texas has required that
retailers seeking to participate in the state’s EBT system must be: (1)
authorized by FNS to provide food services to SNAP recipients; or (2) a
non-FNS authorized retailer that receives no more than 10 percent of its
gross revenue from entertainment, such as from the sale of alcoholic
beverages, legalized games of chance, sexually oriented materials, coin-
operated amusement machines or amusement services. 37 According to
officials with the state’s Health and Human Services Commission
(HHSC), third-party processors are responsible for ensuring that retailers
comply with these requirements. In addition, state officials said that third-
party processors send them a list of TANF-only retailers, 38 which HHSC
uses to monitor locations that appear to be in noncompliance on the basis
of the retailers’ names. State officials added that they implemented a
more-rigorous monitoring process in 2011, but were not aware of any
retailers removed from the EBT program for noncompliance.

Since September 1997, a Texas state statute has required that recipients
use TANF benefits to purchase only goods and services necessary and
essential to the welfare of the family, such as food, clothing, housing,
utilities, child care, transportation, and medicine, medical supplies, or
equipment not covered by Medicaid. 39 State officials told us that they are
unable to track how recipients spend their cash assistance. However,
they said that if they receive information through social workers,
neighbors of recipients, a hotline, or other sources regarding TANF
recipients misusing their TANF benefits, they could assign a protective
payee to TANF recipients who display misuse of their TANF benefits. 40



37
 1 Tex. Admin. Code §§ 372.1701 - 1702.
38
  According to HHSC officials, TANF-only retailers are those retailers that have the ability
to redeem TANF benefits in Texas, but are not authorized by FNS to redeem SNAP
benefits.
39
  Tex. Hum. Res. Code § 31.0355(a). Subsequent state regulations expanded the list of
permissible purchases to include furniture, laundry, household supplies, and recreation.
See 1 Tex. Admin. Code § 372.1509(b).
40
  Texas state regulations define a TANF protective payee as “a person whom HHSC
selects to receive and manage benefits for the certified group instead of the caretaker.
HHSC may designate a protective payee whenever HHSC determines that the caretaker
has failed to comply with one or more program requirements.” See 1 Tex. Admin. Code §§
372.2(17) and 372.905(a).




Page 19                                           GAO-12-535 TANF Electronic Benefit Cards
According to state officials, in May 2012, 84 active TANF cases were
assigned a protective payee. In addition, TANF recipients are not able to
access their benefits at ATMs in Texas, as the state’s EBT cards are not
accepted at ATMs there.

Washington

Washington has implemented a system in which retailers are responsible
for blocking unauthorized TANF transactions, and will soon employ
monitoring efforts to determine the effectiveness of its actions. As of
January 1, 2012, businesses falling under one of Washington’s nine
prohibited categories (see fig. 1 above) are required by Washington law
to disable the ability of ATM and POS machines located on their premises
to accept the state’s EBT card. 41 State-licensed taverns, nightclubs,
beer/wine specialty stores, bail bond agencies, gambling establishments,
and tattoo, body piercing, or body-art shops can have their state business
licenses suspended by various state regulatory agencies if it is
determined that they are not in compliance with this Washington law. 42
For example, the Washington State Liquor Control Board is required to
suspend the licenses of taverns, beer/wine stores, and nightclubs if they
are not in compliance. However, because there are no specific statewide
licensing requirements for Washington adult-entertainment
establishments or establishments where individuals under the age of 18
are not permitted, it is unclear what penalties might apply to those
businesses. According to one official from Washington State Department
of Social and Health Services (DSHS), DSHS will rely on businesses to
ensure that third-party processors have deactivated the state’s BIN from
relevant machines in the restricted locations, and businesses will be held
accountable if DSHS finds that the third-party processors have failed to
perform these deactivations. However, one DSHS official stated that
DSHS was able to work with the state’s tribal casinos, EBT vendor, liquor
control board, and gaming commission to disable EBT access at ATMs in
casinos and liquor stores. 43 To do so, according to DSHS officials, the
state’s EBT vendor contacted tribal casinos and commercial bingo
establishments to identify the relevant third-party processors and ATM


41
 Wash. Rev. Code § 74.08.580(2).
42
 Wash. Rev. Code §§ 66.24.013, 18.185.056, 9.46.410, and 18.300.095.
43
   By June 1, 2012, all state-run liquor stores were closed, and sale and distribution of
liquor in the state was privatized. See Wash. Initiative Measure No. 1183 (Nov. 8, 2011).




Page 20                                         GAO-12-535 TANF Electronic Benefit Cards
owners, and then asked them to deactivate the state’s BIN from their
machines.

Although Washington law requires that certain retailers disable TANF
EBT access at ATMs and POS devices on their premises, a state official
said that in order to implement the EBT restrictions, the owners of ATMs
and POS terminals must manually disable the state’s BIN at the ATMs
and POS machines. However, DSHS officials clarified that it is possible
for larger businesses to perform this remotely. According to officials from
DSHS, some retailers may not be aware of the new state law, especially
small “mom and pop” retailers. DSHS has coordinated with state licensing
agencies to educate licensees about the new requirements affecting
them, according to officials from DSHS. However, according to one DSHS
official, there are ways to circumvent the state’s laws, such as businesses
reactivating the state’s BIN or changing the location of an ATM after the
business obtained or renewed its license.

One official from DSHS also said that the department monitors EBT
transaction data to test whether certain retailers are complying with the
requirement to disable EBT access on their premises. However,
according to one official, although the EBT transaction data may have
address information of a business that may match the address of an ATM
transaction, this does not necessarily mean that the ATM is located
physically on the business’s premises. DSHS officials said that they are
still considering, but have not yet decided whether to use undercover
investigators with loaded EBT cards to test on-site whether retailers are in
compliance.

State officials also said that in the past they faced challenges in
identifying and classifying locations pursuant to some definitions of
prohibited locations. For example, DSHS officials said that the state’s
gaming regulations classified a certain game as gambling, in which
children use a claw to try to win toys, candy, or other prizes. According to
state officials, the regulations were changed so that they would not
classify these types of games as gambling. In addition, state officials told
us that adult-entertainment establishments are not regulated by the state,
which may complicate the monitoring of these retailers’ compliance with
state law due to the uncertainty about what agencies are actually
responsible for these specific retailers. For example, one DSHS official
told us that DSHS contacted local law enforcement to ask what adult-
entertainment establishments are located in their jurisdictions, in an
attempt to identify establishments that should disable their EBT access.



Page 21                                  GAO-12-535 TANF Electronic Benefit Cards
Washington state law allows TANF recipients to use their TANF cash
assistance to pay for a reasonable amount of basic living expenses, such
as shelter, food, transportation, clothing, household maintenance,
personal hygiene, employment or school related items, or other
necessary incidentals and items. However, state law prohibits individuals
from using their EBT cards or TANF cash assistance for gambling
activities or to purchase lottery tickets, tobacco, cigarettes, horse racing,
or for the purpose of participating in or purchasing any activities located in
nightclubs, adult-entertainment venues, establishments where persons
under the age of 18 are not permitted, contract liquor stores, bail bond
agencies, beer/wine stores, taverns, gambling establishments, or a
licensed tattoo, body piercing, or body art shop (see fig. 1 above). 44
Individuals who violate this provision can be fined, forfeit future cash
assistance, or after more than one violation be assigned a protective
payee. 45 Under state regulations, violators can also be required to provide
proof that the cash assistance is being used for the benefit of the children
in the household. 46 DSHS officials also said that they are unable to
restrict specific types of purchases. Rather, they would need to either
completely disable the state’s BIN at affected POS devices or allow
everything to be purchased with an EBT card. As a result, DSHS officials
told us that they rely on the honor system and hope that retailers will stop
individuals from using their EBT cards to purchase prohibited items. One
DSHS official told us that it is difficult to track how individuals spend the
cash withdrawn with their EBT cards. However, DSHS officials stated that
if in the course of working with a TANF client the case managers find that
the family is consistently in financial crisis and cannot adequately explain
why, the case managers might assume the client is not expending the
benefits appropriately or wisely. According to DSHS officials, in those
instances, the case managers will delve deeper and talk with the clients
to determine if they are using their benefits correctly by meeting the basic
needs of the clients’ families and assist the clients with understanding
how the TANF benefits should be used. If these issues continue, the case
managers may suggest or require that a protective payee be assigned.



44
 Wash. Rev. Code § 74.08.580(1).
45
  Wash. Rev. Code § 74.08.580(5). Washington state regulation defines a protective
payee as “a person or an employee of an agency who manages client cash benefits to
provide for basic needs—housing, utilities, clothing, child care, and food.” See Wash.
Admin. Code § 388-460-0020(1).
46
 Wash. Admin. Code § 388-412-0046(1)(e)(ii).




Page 22                                         GAO-12-535 TANF Electronic Benefit Cards
States without Restrictions   Four of our 10 selected states—Florida, Illinois, New York, and Ohio—do
                              not have any restrictions aimed at preventing certain TANF transactions.
                              This is because they have no state laws, executive orders, or other
                              regulations that prohibit certain TANF transactions on the basis of the
                              location of the transaction or the nature of the goods or services
                              purchased. In addition, these states did not implement restrictions due to
                              concerns about cost effectiveness or technical limitations, according to
                              state officials. As mentioned above, before the recent passage of the
                              Welfare Integrity and Data Improvement Act, as part of the Middle Class
                              Tax Relief and Job Creation Act of 2012, states were not required to
                              maintain or implement policies or practices aimed at preventing certain
                              TANF transactions in certain locations. TANF was designed to provide
                              states with great flexibility in determining how to run their own programs.
                              Although states are required to implement policies and practices aimed at
                              preventing certain TANF transactions in certain locations by February 22,
                              2014, there is currently no nationwide restriction on how TANF recipients
                              can spend their TANF cash assistance. Because of these factors, these 4
                              states have not attempted to block or prohibit certain TANF transactions
                              at certain locations or to prohibit the purchase of certain goods and
                              services, unlike the other 6 states discussed above.

                              Other additional factors also influenced these states’ decisions not to
                              restrict certain TANF transactions. For example, officials in Florida and
                              New York told us that they reviewed the number of EBT transactions
                              conducted at certain locations—casinos and liquor stores in Florida; bingo
                              halls, casinos, and off-track betting sites in New York—and compared
                              that number to the total number of EBT transactions. They found that only
                              a small percentage of transactions took place at these locations. 47
                              Therefore, officials in these states determined that it would not be cost-
                              effective to implement restrictions aimed at preventing a relatively small
                              number of transactions.

                              New York officials did note later that liquor stores in New York are
                              precluded from having ATMs. In addition, New York officials noted that
                              they received voluntary cooperation, over the last several years, from
                              merchants and ATM providers to prevent TANF transactions initiated with
                              the New York EBT card in select gambling establishments located in New
                              York and other states serviced by these merchants and ATM providers.



                              47
                               We did not independently verify the results of these reviews.




                              Page 23                                         GAO-12-535 TANF Electronic Benefit Cards
                            New York officials stated that merchants have accomplished this by
                            identifying TANF transactions initiated at ATMs in select gambling
                            establishments and declining such transactions that are associated with
                            New York’s BIN for EBT transactions. New York officials noted this
                            methodology as one possible cost-effective way to prevent electronic
                            transactions with TANF funds at certain locations because it would entail
                            that the merchants direct their third-party processor to block the states’
                            EBT cards’ BINs from being able to complete an ATM or POS transaction
                            in certain establishments. According to New York officials, third-party
                            processors can add and block BINs regularly through software updates.
                            According to New York officials, this can be done as part of the service
                            third-party processors provide to business establishments through their
                            service agreements, which could be performed at no extra cost to the
                            business establishments.

                            Illinois officials told us that their current EBT contract did not include the
                            capability to block certain locations from EBT access. Although Illinois
                            officials said that their state had no restrictions in place to block certain
                            TANF transactions, they said that state casinos voluntarily disabled EBT
                            access at ATMs on their premises—this is similar to the voluntary efforts
                            by casinos in Michigan and Pennsylvania. Ohio is unique among our 10
                            selected states in that it uses EPC cards to distribute TANF cash
                            assistance rather than EBT cards. State officials told us that they chose to
                            use EPC cards because of the increased accessibility they provide to
                            recipients. Because federal financial-privacy laws generally prevent the
                            state from receiving data on individual EPC transactions, unless a
                            specified exception exists, 48 state officials said that they are unable to
                            monitor or restrict the use of EPC cards at certain locations.


States May Face             States may face challenges in implementing future restrictions on TANF
Challenges in               transactions. As mentioned above, the Welfare Integrity and Data
Implementing Restrictions   Improvement Act, part of the Middle Class Tax Relief and Job Creation
                            Act of 2012, will require states to prevent TANF electronic benefit
                            transactions at certain locations. 49 In addition, the law requires that HHS



                            48
                             12 U.S.C. § 3402.
                            49
                              As stated above, states will be required to have in place policies and practices as
                            necessary to prevent such transactions within 2 years of the Act’s enactment. Pub. L. No.
                            112–96, § 4004(b), 126 Stat. 156, 197–198.




                            Page 24                                         GAO-12-535 TANF Electronic Benefit Cards
determine whether states have implemented and maintained such
policies and practices for preventing these transactions. At the time of this
report’s issuance, HHS was at the beginning of its rulemaking process
and it did not yet know what form its final regulations would take. As such,
it was too early to determine what states will need to do in order to
comply with the new federal requirements. Officials from multiple states
told us that the federal requirements are expected to help states ensure
that cash assistance is used in a manner reflecting the purpose of TANF.
However, some officials cited challenges that they might face in
attempting to prevent certain TANF transactions in order to meet the
potential requirements of the law. These challenges were primarily
focused on difficulties with identifying locations that could be blocked from
EBT access and limitations in available data. For example, according to
officials from multiple states, the transaction data they receive do not
contain information that is accurate or detailed enough for them to identify
locations that could potentially be prohibited or restricted. If transaction
data are inaccurate or lack enough information about the business nature
of specific retailers, states’ efforts to prevent certain TANF transactions
may be impeded. State officials suggested that improvements in the
quality of EBT transaction data might better enable them to prevent such
transactions. For example, state officials suggested that prevention efforts
would be aided by more-accurate and complete address information for
transactions, or requiring merchant category codes to be included in the
data. In addition, officials from multiple states suggested that businesses
or third-party processors should be responsible for ensuring that EBT
access is disabled at certain locations, rather than states.

We found that EBT transaction data from four states—California, Florida,
New York, and Texas—contained incomplete or inaccurate information
for the address of the location where the transaction occurred, which
limits the data’s usefulness for systematic monitoring. 50 To conduct
systematic monitoring effectively, including the identification of locations
that can be blocked from EBT access, data should be complete and
accurate. In the California and Florida data, the address information was
sufficiently complete; however, it was not sufficiently accurate. We
estimate that the reported addresses of the locations where the
transactions occurred could be linked to standardized addresses for less



50
  As mentioned above, we assessed EBT data from these four states containing
transactions made from October 1, 2009, through September 30, 2010.




Page 25                                      GAO-12-535 TANF Electronic Benefit Cards
than 21 percent and 14 percent of the transactions, respectively. 51 This
means that the states could not rely on the majority of the transaction
records for accurately identifying a true location and would therefore need
to verify manually that the reported addresses for the transactions
matched to a real location, which would increase the time and labor
required as part of this process. The New York EBT data contained
complete address information for approximately 71 percent of the
transactions, of which we estimate that up to 34.2 percent could be linked
to standardized addresses. 52

Texas address information was complete for approximately 30 percent of
the transactions, 53 although we estimate that as many as 70.4 percent of
those addresses could be linked to standardized addresses. Without
sufficiently complete and accurate information for the address where an
EBT transaction occurred, states are unable to systematically monitor or
block EBT access. To the extent that the information is available, states
could use EBT data to identify individual transactions that may have
occurred at certain locations on the basis of the name of the merchant at
the location where the transaction occurred. We found that the merchant
name was available for approximately 19 million transactions—45 percent
of the transactions we examined—as low as 30 percent in Texas and as
high as 90 percent in Florida.

Officials from multiple states and representatives from states’ EBT
vendors expressed concerns about the EBT data. For example, according
to one vendor, address information in the data— which is self-reported by
ATM or POS device owners or operators, and is transmitted by third-party
processors—is not always correct, and the ATM addresses listed in the
data sometimes do not reflect where transactions actually took place. In
addition, state officials and representatives from states’ EBT vendors
stated that the ATM transaction data maintained by vendors all list the
same merchant category code that provides no information about the type



51
  As mentioned above, we compared EBT transaction addresses to U.S. Census Bureau
TIGER standard addresses. Estimates include a margin of error of no more than 3.3
percent for California and 2.8 percent for Florida at the 95 percent confidence level.
52
  Estimate includes a margin of error of no more than 4.1 percent at the 95 percent
confidence level.
53
  Estimate includes a margin of error of no more than 4.2 percent at the 95 percent
confidence level.




Page 26                                         GAO-12-535 TANF Electronic Benefit Cards
of retailer where the ATM machines are located. According to state and
vendor officials, the inaccuracies and insufficiencies in the EBT
transaction data are due to gaps in data reporting and the nature of the
EBT system’s infrastructure. According to representatives from one EBT
vendor, third-party processors do not always verify the information
contained in transaction data, which diminishes the quality of the data that
they submit to the EBT vendors. According to some state and vendor
officials, the EBT transaction data are not used generally for only
identifying where TANF transactions might occur.

The EBT program was devised in the 1980s to originally meet the needs
of the USDA’s Food Stamp Program, in which federal benefits would be
disbursed electronically to eligible recipients, with states later adding their
TANF programs to EBT cards. Some state officials and vendor
representatives noted that the specifications governing the extent of the
EBT data captured as part of an EBT transaction do not require all
transaction information on each EBT transaction. 54 For example,
according to state officials from Texas, some data elements, such as
merchant names, could be useful for monitoring where TANF benefits are
accessed, but they are not required under those specifications. The
accuracy of the data is also affected by self-reporting. For example,
although it is intended that the transactions follow these specifications,
key industry players, such as third-party processors, do not follow these
specifications consistently, according to California officials. Moreover,
because transactions can go through multiple entities, including third-
party processors, the transaction data can change and may not always be
transmitted accurately to the vendor, according to California officials.

As mentioned above, Ohio is unique among our selected 10 states in
disbursing TANF cash assistance through EPC cards rather than EBT
cards. Regarding potential future restrictions, Ohio officials told us that
they are unsure how they will be able to restrict TANF transactions, and
will need to work with their vendor that operates their EPC state card to
determine the feasibility of performing these restrictions. However,
according to one vendor, given that EPC cards are branded by major
financial institutions—such as Visa and MasterCard—and operate on


54
  These state officials and vendor representatives said that EBT transactions follow ISO
8583, which is the International Standard designed as an interface specification enabling
messages relating to financial transactions to be exchanged between systems adopting a
variety of application specifications.




Page 27                                         GAO-12-535 TANF Electronic Benefit Cards
               these institutions’ commercial infrastructure, these institutions could
               disable POS access for EPC cards by using merchant category codes
               that retailers are required to submit as part of the transaction data in order
               to participate in the institutions’ networks. This type of blocking is not
               possible, however, with ATMs that accept EPC cards, according to
               representatives from one vendor. However, vendor representatives told
               us that ATM data for EPC transactions, similar to EBT card data, contain
               only one merchant category code for all terminals, identifying the location
               of the transaction as a financial institution. Also similar to EBT card data,
               EPC card data do not contain detailed information on items purchased
               with the EPC cards.


               The purpose of TANF is to help needy families achieve self-sufficiency.
Concluding     Providing TANF benefits by means of electronic benefit cards helps the
Observations   banked and unbanked TANF recipients, gives TANF recipients an
               alternate to cash, and allows states to use existing infrastructures.
               However, any misuse of TANF funds not only deprives low-income
               families of needed assistance, but also diminishes public trust in both the
               integrity of the program and the federal government. Before Congress
               passed the Welfare Integrity and Data Improvement Act, as part of the
               Middle Class Tax Relief and Job Creation Act of 2012, some states acted
               independently to implement restrictions on certain TANF transactions. As
               a result, their approach to enacting restrictions varies significantly.
               However, until HHS issues regulations or provides further guidance as to
               what policies and practices are sufficient to comply with the new federal
               requirements, it is unclear to what extent the various restrictions
               implemented by states would be in compliance. The experience of these
               states—especially any information related to the cost-effectiveness and
               success rates for various restrictions—could be beneficial for HHS to
               consider as it works toward determining what policies and practices are
               sufficient to comply with the new federal law. As we heard from officials in
               multiple states, preventing unauthorized transactions can be time-
               intensive and is impaired by flaws in available transaction data and other
               challenges. Addressing the limitations we found in transaction data that
               impede the identification and monitoring of certain locations could require
               significant resources. Therefore, restriction methods that do not rely on
               flawed transaction data may be the most practical, such as Washington
               state’s requirement for businesses to independently disable EBT access
               or risk losing or not obtaining their state licenses to operate.




               Page 28                                  GAO-12-535 TANF Electronic Benefit Cards
                   We provided a draft of this report to HHS for comment. In its written
Agency and State   comments, reproduced in appendix III, HHS noted that our report
Comments           highlights many of the challenges and issues states and others face in
                   issuing the TANF requirements that Congress enacted in February 2012.
                   In addition, HHS stated that our report’s findings and analysis will be
                   helpful as HHS drafts implementing regulations relevant to these TANF
                   requirements. HHS also provided technical comments that we
                   incorporated, as appropriate.

                   In May 2012, we also provided the 10 selected states with an opportunity
                   to comment on our draft findings relevant to their specific TANF
                   programs. In May 2012, 7 of the 10 selected states provided us with
                   technical comments by e-mail, and we incorporated their technical
                   comments as appropriate. Three states, Illinois, Massachusetts, and
                   Pennsylvania, had no comments.


                   As agreed with your office, unless you publicly announce the contents of
                   this report earlier, we plan no further distribution until 7 days from the
                   report date. At that time, we will send copies to other interested
                   congressional committees and the Secretary of Health and Human
                   Services. In addition, the report will be available at no charge on the GAO
                   website at http://www.gao.gov.

                   If you or your staff have any questions about this report, please contact
                   me at (202) 512-6722 or kutzg@gao.gov. Contact points for our Offices of
                   Congressional Relations and Public Affairs may be found on the last page
                   of this report. GAO staff who made key contributions to this report are
                   listed in appendix IV.

                   Sincerely yours,




                   Gregory D. Kutz
                   Director, Forensic Audits and Investigative Service




                   Page 29                                 GAO-12-535 TANF Electronic Benefit Cards
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objective was to determine the extent to which selected states have
              taken action to prevent unauthorized Temporary Assistance for Needy
              Families (TANF) transactions. To conduct our work, we reviewed TANF
              laws, regulations, and other documentation—including the Welfare
              Integrity and Data Improvement Act, part of the Middle Class Tax Relief
              and Job Creation Act of 2012, which introduced new state requirements
              for preventing certain TANF transactions—and interviewed officials from
              Health and Human Services (HHS). From each selected state, we
              reviewed information related to its laws, policies, practices, and other
              factors affecting its TANF program. In addition, we interviewed and
              reviewed documentation from several key industry stakeholders related to
              states’ efforts to prevent unauthorized TANF transactions. We also
              interviewed officials from the top 10 states in terms of TANF basic block-
              grant dollars—California, New York, Michigan, Ohio, Pennsylvania,
              Illinois, Florida, Texas, Massachusetts, and Washington. Together, these
              10 states represent a total of 66 percent of TANF basic block-grant
              funds. 1 The industry stakeholders included: JP Morgan Chase and
              Affiliated Computer Services, the two largest vendors providing TANF
              electronic benefit card services to the states; the Electronic Funds
              Transfer Association, an industry trade association that conducts work
              related to electronic benefit card services for government agencies at the
              federal and state level; the National Conference of State Legislatures, a
              bipartisan organization that provides research and other services to state
              legislators and their staff; and the American Public Human Services
              Association, a bipartisan, nonprofit organization representing appointed
              state and local health and human-services agency commissioners. We
              obtained electronic benefit card transaction data from 4 of the 10 selected
              states—California, Florida, New York, and Texas—covering transactions
              from federal fiscal year 2010. 2 We selected these 4 states based on
              geographical diversity. The results of our analysis of these 4 states’ data
              cannot be generalized to other states. 3 Using these data, we assessed


              1
                California represents 22.6 percent of total national TANF basic block grant dollars; New
              York, 14.8 percent; Michigan, 4.7 percent; Ohio, 4.4 percent; Pennsylvania, 4.4 percent;
              Illinois, 3.5 percent; Florida, 3.4 percent; Texas, 2.9 percent; Massachusetts, 2.8 percent;
              and Washington, 2.5 percent in fiscal year 2012.
              2
               October 1, 2009, to September 30, 2010.
              3
               The random samples can only generalize about each state using each state’s sample,
              not about other states and not nationally. For example, the Texas sample tells us
              something general about the Texas EBT data as a whole, but cannot tell us anything
              about the California data or all U.S. data.




              Page 30                                           GAO-12-535 TANF Electronic Benefit Cards
Appendix I: Objectives, Scope, and
Methodology




the extent to which the data would allow the 4 selected states to conduct
systematic monitoring of TANF transactions. Such monitoring might
include an assessment of the prevalence of transactions at certain
locations.

To do so, we used a generalizable, random sample of each of the 4
selected states’ Electronic Benefit Transfer (EBT) transaction data and
compared it to electronic geo-coding information that pinpoints places and
identifies locations. 4 Subsequent visual inspection and manual cleaning of
obvious address errors in the EBT data only resulted in a small portion of
corrected location addresses. We also assessed whether the data would
allow states to identify individual TANF transactions at certain types of
locations. To do so, we conducted keyword searches of merchant names
for terms that are potentially associated with casinos, liquor stores, and
adult-entertainment establishments. We performed data checks to
determine the reliability of the California, Florida, New York, and Texas
EBT data for the purposes of our engagement. For all four states, we
determined that the EBT data are not sufficiently reliable for the purpose
of performing systematic monitoring, as the selected states’ data
contained incomplete or inaccurate information for the addresses of the
locations where the transactions occurred. Given the combination of both
completeness and accuracy issues in the 4 selected states, we also
determined most of the data in the 4 selected states could not match to
address location information that would allow for suitable comparisons to
other potential data sources. However, we determined that the
transaction data would support keyword searches of merchant names for
terms that are associated potentially with casinos, liquor stores, and
adult-entertainment establishments, for records that contain merchant
names. We conducted this performance audit from October 2012 to July
2012, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




4
 We compared EBT transaction addresses to U.S. Census Bureau’s Topologically
Integrated Geographic Encoding and Referencing (TIGER) standard addresses.




Page 31                                     GAO-12-535 TANF Electronic Benefit Cards
Appendix II: Print-Friendly Version of
                                        Appendix II: Print-Friendly Version of
                                        Figure 1



Figure 1

                                        The table below includes figure 1’s (see above) rollover information and
                                        describes the steps that 6 of the 10 states we reviewed have taken that
                                        are aimed at preventing the use Temporary Assistance for Needy
                                        Families (TANF) cash assistance for certain purchases or in certain
                                        locations.

Table 1: Some States Have Taken Steps Aimed at Preventing Unauthorized TANF Transactions

State                 Steps taken
California            - EBT access disabled at ATMs in California businesses, including
                            - Casinos
                            - Adult-entertainment businesses
                            - Bail-bond locations
                            - Night clubs/saloons/taverns
                            - Bingo halls
                            - Race tracks
                            - Gun/ammunition stores
                            - Cruise ships
                            - Psychic readers
                            - Smoking shops
                            - Cannabis shops
                            - Tattoo/piercing shops
                            - Spa/massage salons
                            - Liquor stores not authorized by the Food and Nutrition Service (FNS)
Massachusetts         - TANF recipients in Massachusetts are prohibited by state law from using cash assistance to purchase
                             - Alcohol
                             - Tobacco
                             - Lottery tickets
                      - Merchants in Massachusetts are prohibited by state law from knowingly accepting EBT cards for the
                        purchase of
                             - Alcoholic beverages
                             - Tobacco products
                             - Lottery tickets
Michigan              - TANF recipients in Michigan are prohibited by state law and policies from using their TANF cash
                           assistance for
                           - Lottery tickets
                           - Alcohol
                           - Tobacco
                           - Gambling
                           - Illegal activities, including purchasing illegal drugs
                           - Adult entertainment
                           - Massage parlors
                           - Spas
                           - Tattoo shops
                           - Bail-bond agencies
                           - Cruise ships
                           - Nonessential items, including items not necessary to sustain the household
                      - EBT access disabled at ATMs in Michigan casinos




                                        Page 32                                         GAO-12-535 TANF Electronic Benefit Cards
                                 Appendix II: Print-Friendly Version of
                                 Figure 1




State          Steps taken
                                                                   a
Pennsylvania   - No ATMs exist in Pennsylvania-run liquor stores
               - Pennsylvania liquor stores do not accept Pennsylvania’s EBT card at POS terminals
               - EBT access disabled at ATMs in licensed casinos in Pennsylvania
               - By Pennsylvania law, TANF cash assistance shall be diminished by amounts that a Pennsylvania TANF
                recipient obtains by cashing a TANF cash assistance check at a Pennsylvania gambling casino, racetrack,
                bingo hall or other establishment which derives more than 50 percent of its gross revenue from gambling
               - TANF recipients are prohibited from using their EBT card to purchase liquor or alcohol
Washington     - Washington merchants are required by state law to disable ATMs and POS terminals located in their
                       - Casinos
                       - Liquor stores
                       - Taverns
                       - Nightclubs
                       - Bail-bond agencies
                       - Body-art shops
                       - Race tracks
                       - Adult-entertainment venues
                       - Establishments where persons under the age of 18 are not permitted
               - Washington TANF recipients are prohibited by state law from using TANF cash assistance for
                      - Gambling
                       - Amusement games
                       - Raffling
                       - Horse racing
                       - Lottery tickets
                       - Cigarettes
                       - Tobacco products
                       - Body piercings
                       - Beer
                       - Wine
                       - Adult-entertainment materials
                       - Bail bonds
                                                                                                           a
Texas          - TANF recipients in Texas are not able to access their TANF cash assistance at ATMs
               - Retailers participating in the Texas EBT program must be either FNS-authorized or nonfood retailers that
                 receive no more than 10 percent of their gross revenue from entertainment, such as from the sale of
                      - Alcoholic beverages
                      - Legalized games of chance
                      - Sexually oriented materials
                      - Coin-operated amusement machines or amusement services
               - TANF recipients in Texas can only use their TANF cash assistance for goods and services necessary and
               essential to the welfare of the family
                                 Source: GAO.
                                 a
                                 Liquor stores in Pennsylvania are operated by the state.
                                 b
                                  TANF recipients in Texas can use their EBT cards to make purchases of approved items or take out
                                 cash at participating retailers’ POS devices




                                 Page 33                                              GAO-12-535 TANF Electronic Benefit Cards
Appendix III: Comments from the
             Appendix III: Comments from the Department
             of Health and Human Services



Department of Health and Human Services




             Page 34                                      GAO-12-535 TANF Electronic Benefit Cards
Appendix III: Comments from the Department
of Health and Human Services




Page 35                                      GAO-12-535 TANF Electronic Benefit Cards
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Gregory D. Kutz, (202) 512-6722 or kutzg@gao.gov
GAO Contact

                  In addition to the contact named above, Cindy Brown Barnes, Assistant
Staff             Director; Erika Axelson, Assistant Director; Christopher W. Backley;
Acknowledgments   Melinda Cordero; Justin Fisher; Katherine Forsyth; Gale Harris; Olivia
                  Lopez; Grant Mallie; Flavio J. Martinez; Maria McMullen; James Murphy;
                  Anna Maria Ortiz; Robert C. Rodgers; Rebecca Shea; and Timothy
                  Walker made key contributions to this report.




(192390)
                  Page 36                               GAO-12-535 TANF Electronic Benefit Cards
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