The USDA Food and Nutrition Service (FNS) prompted California to create an “integrity plan” on how it would address illegal “trafficking” in SNAP benefits, including how the CalFresh program responds to ALERT cases of “unusual transactions” occurring at stores found to have trafficked in SNAP benefits and either shut down or fined as a result. The integrity plan was also expected to address: Frequent requests for replacement EBT cards, suspected to be attempts at trafficking; the use of social media to facilitate trafficking; and employee fraud. California convened a workgroup of fraud investigators, counties and advocates to discuss the issues and make recommendations about the integrity plan. The result was the CalFresh Recipient Integrity Plan (September 14, 2012).
In addition to the ALERT cases, the Integrity Plan is directed at several issues, including the following:
- Data Mining: CDSS will develop data mining protocols and implementation through Xerox (the EBT vendor) within one year. In the interim, the Office of Systems Integration will produce ad hoc reports which identify information about excessive EBT card replacements utilizing both the California standard of four active card replacements in four consecutive months, and the FNS proposed standard of four active card replacements in 12 months.
- Excessive card replacement: Excessive requests for replacement cards protocol will be developed within “at least” six months from submission of the Integrity plan (i.e., the end of 2013 or later). “Excessive” means at least one card replacement for active cards that have had at least one transaction for four consecutive months. Four requests gets a warning letter; six requests gets a “contact us” letter. (Copies of these letters are attached to the Integrity Plan.) Eight requests gets will result in a fraud referral. See ACL 13-54 (implementing the Excessive card replacement process).
- Social media: CDSS will monitor social media sources daily, with extra scrutiny of Craigslist, Facebook and Twitter. CDSS will use data resources and social-network relationship software to help identify anonymous sellers. CDSS will ask Craigslist to remove trafficking related postings. Screen shots of the posts will be sent to the CDSS Special Investigations Unit (SIU).
- Employee fraud: CDSS will develop and maintain statewide protocols for sharing best practices employed by counties to prevent, detect and investigate employee fraud. Examples include: Processes for training workers on employee fraud; protocol guidelines to ensure fraudulent activities do not occur, such as dual sign off or rotating unit assignments; statewide calls to discuss employee fraud “strategies” to alert other CWOs; and development of further monitoring and prevention processes. This includes any type of welfare fraud. CDSS will refer to the USDA Office of the Inspector General any incidents of employee fraud involving CalFresh.
- Media: CDSS will share all publicized efforts to control fraud, waste and abuse with the FNS Western Regional Office as they occur. CDSS will also develop and implement best practices for responding to negative media stories, to include coordination among affected agencies and talking points for media response.
- Trafficking Prevention / Consumer Education: CDSS will develop educational material in the form of a letter or brochure to ensure recipients know the rules and responsibilities regarding their EBT card and how to protect their benefits. Additionally, this material will inform them that their EBT card transactions can be tracked and the consequences of buying and selling an EBT card or purchasing ineligible items.
- Recommendations to FNS: Encourage FNS to develop a “zero tolerance” policy for EBT fraud and require local vendors to post the policy as part of their approval process. The poster should indicate that EBT usage is monitored by federal, state and county agencies.