Protective Payee Changes for Suspicion-Based Drug Testing

When an individual tests positive or fails to submit to suspicion-based drug testing, access to cash assistance on the EBT card is to be restricted. Staff were initially instructed to restrict cash access immediately when notified of the positive test or failure to test by coding ebtEdge ‘PF’ for cash assistance.

EBT system issues with the required change in coding have been identified. These system issues require a change in procedure for individuals who have been identified as needing a Protective Payee.

Beginning with the issuance of this memo, the following procedures are to be followed Staff will provide timely and adequate notice of the EBT cash restriction.

Staff will request the household identify a protective payee and the household is to be given 10 days to provide.

1. Positive or Failure to Drug Test
   
   
   • Timely and adequate notice will be sent to the client requesting submission of a Protected Payee for their case. (V018, V019)
     
     
   • Set a WOAL for return of Protective Payee assignment.
     
     
   • The cash access for the primary person (and existing alternates) will not be restricted at this time. This will allow households to use any existing cash benefits approved prior to the positive drug test.
     
     
2. 10 days after notification
   
   
   • The cash access for the primary person and any existing alternate payees will be restricted by field EBT support staff. (Code ebtEdge cash access “None” for the primary cardholder and any other authorized users –including authorized representatives or spouses).
     
     
   • Any subsequent cash benefit authorizations for the case will be rejected and not applied to EBT until a Protected Payee is assigned. This will require extra work by staff.
     
     EXAMPLE: Household was mailed the V018 and V019 requesting a Protective Payee. 13 days have passed and a Protective Payee has not been assigned. The Purple Team notifies the ebtEdge clerk to restrict cash access for all payees by coding cash access “None”. Once this is completed, all cash benefits (and work program payments), cannot be credited to the EBT card. Even if a benefit is authorized through rollover, it will not apply to the card. Once a Protective Payee is added to ebtEdge system, cash benefits will successfully apply to the EBT case. When this occurs, staff will need to reauthorize TANF through the AFAD screen for any payments that have not been applied. In addition, any work program payment authorized during this time period will require reauthorization.
     
     
3. Protected Payee assigned
   
   
   • The Protected Payee is added to ebtEdge field EBT support staff.
     
     
   • All cash benefit authorizations issued between the period of cash restriction of the primary person and addition of the Protected Payee must be reauthorized in order to resubmit the payment to the EBT system. This includes any work program payments.
     
     
4. EBT unit notification of case address changes
   
   Cash restrictions on ebtEdge will cause additional issues with changes made to a case on KAECSES. Any change made to a case (address, person level changes, etc) will not upload to the EBT system. This will also cause additional duties for staff.
   
   
   • Field staff must send an email to the CO EBT unit whenever an address change occurs on a case with active cash restriction. EBTmail@ks.gov
     
     
   • The EBT unit will match batch change refresh errors to address changes reported by the field staff, and manually update the information in ebtEdge to match legacy system information.
     
     
   • The EBT unit will contact field staff if a change batch refresh error occurred, that does not match a reported case address change.
     
     
5. Cash Restriction Resolved
   
   
   • Field EBT support staff will immediately grant cash access to the primary person and non-protected payee alternate payees.
     
     
   • Field EBT support staff will remove the Protected Payee from ebtEdge. (Change from ‘PF’ to ‘P’)
     
     
6. Households who do not identify a Protective Payee:
   
   Care should be taken not to allow a TANF case to be without a Protective Payee for an extended period of time. If a household cannot identify a Protective Payee, the Regional Drug Coordinator may be of assistance in identifying a Protective Payee. However, if no payee is identified, and there has been no access to the cash assistance, then the EES worker should explore how the family is making ends meet.