The State shall insure that there is a reporting system which is continually operative and accessible. Once a household reports that their EBT card has been lost or stolen, the State or its contractor shall assume liability for benefits subsequently drawn from the account and replace any lost or stolen benefits to the household. The State or its contractor shall maintain a record showing the date and time of all reports by households that their card has been lost or stolen. We particularly like the revised rules on re-presentation . We also support the proposal to allow adjustments only under specific limited conditions, and to require the immediate re-crediting of accounts pending a dispute.
All errors impede the timely posting of accurate account balances.
The proposed regulations appropriately recognize that only actual system malfunctions should qualify for an exception from advance notice procedures. The proposal also appropriately recognizes the importance of the recipient s right to make a timely appeal and have the disputed adjustments recredited to the account pending the outcome of the appeal. Karen Walker of your staff kindly permitted us to file these comments a few days after the deadline. If you have any questions, please do not hesitate to contact us. Thank you for your consideration of these views.