BILL ANALYSIS                                                                                                                                                                                                    Ó






                                  SENATE HUMAN
                               SERVICES COMMITTEE
                            Senator Carol Liu, Chair


          BILL NO:       AB 2035                                     
          A
          AUTHOR:        Bradford                                    
          B
          VERSION:       April 16, 2012
          HEARING DATE:  June 12, 2012                               
          2
          FISCAL:        Yes                                         
          0
                                                                     
          3
          CONSULTANT:    Mareva Brown                                
          5
                                        

                                     SUBJECT
                                         
                  Electronic benefits transfer cards: skimming

                                     SUMMARY  

          Protects recipients of CalFresh benefits from losses due to 
          the practice of electronic skimming of their electronic 
          benefit transfer (EBT) cards. 

                                     ABSTRACT  

           Current law
          
              1.   Establishes under federal law the Supplemental 
               Nutrition Assistance Program (SNAP) pursuant to the 
               Food Stamp Act of 1964.

             2.   Establishes under state law the CalFresh program, 
               which provides assistance using federal SNAP funds to 
               low-income families in order to mitigate hunger, 
               undernutrition and malnutrition in the state. In 
               California this is accomplished through distribution 
               of EBT cards to CalFresh recipients (WIC 18900 et 
               seq).

                                                         Continued---



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             3.   Creates through the Electronic Benefits Transfer 
               Act (WIC 10065, et seq.) an EBT system to store 
               information and distribute benefits to recipients of 
               CalFresh. Regulations issued by the Department of 
               Social Services give counties the option of also 
               delivering CalWORKs and General Assistance benefits 
               through EBT cards. (Manual of Policies and Procedures 
               § 16-001.3)

             4.   Provides that a recipient does not incur any loss 
               of electronic benefits after reporting that his or her 
               EBT card of the personal identification number has 
               been lost or stolen. (WIC 10072(g))

           


          This bill

              1.   Makes a series of findings and declarations about 
               the need to address a recipient's loss of benefits due 
               to electronic skimming.  

              2.   Provides that a recipient shall not incur any loss 
               of electronic benefits that are removed from his or 
               her EBT account through skimming and requires that 
               electronic benefits withdrawn by skimming be promptly 
               replaced after the recipient reports the loss, in 
               accordance with existing law governing stolen public 
               assistance issuances. (Gov. 29853.3)  
                 
              3.   Requires that the state Department of Social 
               Services establish a protocol for recipients to report 
               skimming that minimizes the burden to recipients and 
               ensures a prompt payment of benefits.  
                 
              4.   Defines skimming as a form of theft by which a 
               recipient's EBT account information, or "PIN" number, 
               or both, are accessed by an unauthorized person, who 
               uses that information to unlawfully remove funds from 
               the recipient's account.  
                 
                                   FISCAL IMPACT  

          The Assembly appropriations committee analysis indicates 




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          this bill would result in unknown workload costs, likely 
          less than $100,000 for one limited-term staff person to 
          develop the appropriate protocol. 

                            BACKGROUND AND DISCUSSION  

           Purpose of the bill
           
          The author states that the emerging practice of illegally 
          "skimming" account numbers and personal identification 
          numbers (PIN) of electronic cards leaves low-income 
          recipients who rely on of CalFresh benefits without 
          protections afforded other victims of theft. A recent 
          lawsuit highlights the lack of process that would allow a 
          victim this type of theft to recover their EBT benefits. 
          While California law provides recourse for recipients whose 
          EBT cards have been stolen, it does not extend the same 
          protection for individuals whose EBT benefits have been 
          stolen through the act of skimming because the victims 
          never lose possession of their cards. One of the primary 
          purposes of the EBT system, as stated in the EBT Act, is 
          "to afford public social services recipients the 
          opportunity to better and more securely manage their 
          financial affairs."  

           EBT usage
           Food benefits for CalFresh recipients are distributed 
          through an EBT system, which allows recipients to access 
          funds at point-of-sale terminals, automated teller machines 
          (ATMs) and other electronic fund transfer devices. EBT 
          cards look similar to ATM debit cards, and are swiped 
          through the same machines using magnetic strips to transfer 
          information. 

          In addition to delivering CalFresh benefits through the EBT 
          system, all of California's 58 counties also deliver either 
          CalWORKs or General Assistance benefits, or both, through 
          the EBT cards. According to DSS, in May 2012 there were 
          nearly 22.5 million EBT transactions to purchase food 
          through the CalFresh program and nearly 3 million cash 
          purchase or withdrawals at point-of-sale or ATM machines 
          through the cash benefit programs, CalWORKs and General 
          Assistance.

           Carpio v Lightbourne




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           In December 2011, Evelyn Carpio filed suit against the 
          Department of Social Services and its director, Will 
          Lightbourne, claiming that the department illegally refused 
          to replace benefits that were stolen electronically. On 
          Oct. 5, 2009, thieves stole $720 of CalWORKs cash 
          assistance from her EBT account, even though the EBT card 
          never left her possession. Ms. Carpio, a single mother who 
          works part-time as a sales associate at a department store, 
          discovered the loss when she attempted to access her funds 
          at a Food4Less that afternoon. 

          She argued in her filing that the state provides for 
          replacement of stolen EBT benefits through the state's EBT 
          statute, however acknowledges that DSS does not have 
          procedures in place to replace lost benefits when the card 
          itself is not stolen. Although her benefits eventually were 
          restored after two years of appeals, Ms. Carpio argues in 
          her lawsuit that counties continue to deny restoration of 
          benefits that are lost through electronic theft. The 
          lawsuit seeks to establish that the department must replace 
          stolen benefits in a timely manner, however it does not 
          seek to remedy the need for state protocols regarding 
          skimming theft.   The next conference in the case is set 
          before the judge on September 6.
           
          Comments: 
          
           For clarity, staff suggests the following amendment:

          12       (3)  The State Department of Social Services shall 
          establish a
          13    protocol for recipients to report skimming that 
          minimizes
          14    the burden on  recipients,   and  ensures prompt  payment     
            replacement  of benefits  to  ,
          15     recipients   and ensures program integrity  . For 
          purposes of this section,"skimming" 16    means a form of 
          theft by which a recipient's EBT account information,
          17    or  "PIN"  number, or both, are accessed by an 
          unauthorized person, who uses that 18     information to 
          unlawfully remove funds from the recipient's account.

                                         
                                  PRIOR VOTES
           




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          Assembly Floor:     73 - 0
          Assembly Appropriations:16 - 0
          Assembly Human Services:  5 - 0 

                                    POSITIONS  

          Support:       Western Center on Law and Poverty (sponsor)
                         California Bankers Association
                         California Catholic Conference, Inc.
                         California Coalition of Welfare Rights 
          Organizations, Inc.
                         California Reinvestment Coalition
                         Coalition of California Welfare Rights 
          Organizations
                         Consumer Federation of California
                         Insight Center for Community Economic 
                    Development
                         Legal Services of Northern California
                         National association of Social Workers

          Oppose:   None received




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