Assessing the Merits of Photo EBT Cards in the Supplemental Nutrition Assistance

In seeking to reduce the trafficking of electronic benefit transfer (EBT) cards in the Supplemental Nutrition Assistance Program (SNAP, formerly the Food Stamp Program), states are considering—and some have implemented—the use of photo EBT cards. These personal identification number (PIN)protected EBT cards include an imprinted photograph of the SNAP case’s head of household. Massachusetts adopted a statewide photo EBT policy in fall 2013, and Maine has more recently sought to expand a one-county pilot project statewide. Though states are given the authority to implement such policies under the Food and Nutrition Act of 2008, the statute also requires that “the State agency . . . establish procedures to ensure that any other appropriate member of the household or any authorized representative of the household may utilize the card.” States’ use of photo EBT cards in SNAP has sparked controversy. These policies place in direct conflict two principles: the desires of state government agencies and taxpayers to uphold program integrity, and the statutory rights of SNAP household members and their designated representatives to use program benefits without being subjected to additional scrutiny in the retail marketplace. The US Department of Agriculture’s Food and Nutrition Service (FNS), the federal agency that administers SNAP, has sought through its regional offices to ensure that the photo EBT procedures and practices of state agencies and food retailers adequately protect clients’ rights to full benefit access and equal customer treatment. Client advocacy organizations contend that photo EBT policies undermine program participation by imposing undue procedural burdens upon households legitimately entitled to SNAP benefits and by re-stigmatizing program use by clients in food retail establishments. Representatives of food retailers indicate that checkout clerks typically refrain from checking the photo on the EBT card, relying on the PIN to protect against unauthorized card use.