10 Colo. Code Regs. § 2506-1-4.707
The electronic benefit issuance area shall be physically separated, such as, but not limited to, the cage, counter, and railing, from both clients and other employees of the office who are not responsible for benefit issuance and accountability. Persons not specifically responsible for benefit issuance accountability shall also be barred from the electronic benefit card storage area.
Local offices, including contract issuers, shall take all precautions necessary to avoid acceptance, transfer, negotiation, or use of counterfeit SNAP benefits and to avoid any unauthorized use, transfer, acquisition, alteration, or possession of SNAP benefits. EBT cards shall be safeguarded from theft, embezzlement, loss, damage, or destruction.
Issuance supervisors shall give each cashier a daily supply of blank EBT cards from the bulk card inventory. On high volume issuance days, the cashier's supply may need to be replenished during issuance hours from an office vault. The vault containing bulk card inventory shall remain locked unless opened to withdraw cards. Keys and lock combinations shall be controlled and restricted to as few individuals as possible. Combinations and locks should be changed whenever an individual who has received them leaves the employ of the office.
EBT cards must be removed from public view and reach. It is required that each cashier operate from a card drawer rather than from sources on top of the counter. The EBT cards must be locked in the drawer whenever the cashier leaves the issuance area for any reason. In small offices where it is not possible for each cashier to have a separate supply of EBT cards, the number of EBT cards shall be counted whenever one cashier assumes duties of another cashier at the issuance counter, and transferred to that cashier's responsibility.
The office shall never be left unattended during hours of issuance, such as during breaks or lunch, unless the building is secured as it would be after business hours.
The goal of a security program is to safeguard issuance personnel, EBT cards, and other valuables. In the event of a robbery, a planned security program will prevent panic that could endanger the lives of the people in the office.
A major element in an effective security program is the designation of a security officer who would continually review office facilities and procedures to improve office security and deter loss. She/he shall acquaint fellow employees with the security measures including precautions during issuance, night security, and safety of persons and EBT cards while they are in transit between the issuance office and bulk storage area.
In addition to a security officer, each office shall distribute written instructions to all employees concerning appropriate behavior in the event of a robbery attempt and procedures for reporting the theft to law enforcement authorities and the state department.
Bulk EBT supplies shall be stored in a secure facility, preferably a bank or courthouse vault. If possible, all EBT cards should be returned daily to the secure storage facility. If EBT cards must be kept in the issuance office overnight, the amount shall be strictly limited to a one- or two-day supply.
If EBT cards are being stored in the office overnight, doors and windows that could afford access to the building shall be secured. Doors shall be equipped with double-cylinder dead bolt locks or locks of equivalent security. Any glass in doors and windows shall be barred or otherwise protected against breakage. Doors connecting with other offices or buildings shall be locked as securely as exterior doors. All doors and windows shall be checked to make certain they are locked before closing the office.
Issuance office EBT supplies shall be kept in a safe rather than a desk or file cabinet. The safe shall be immovable and in a part of the office not visible to the outside.
To minimize the temptation for robbery, the amount of EBT cards in the issuance office shall be limited to a one- or two-day supply. The cashier's supply shall be out of public view and issued from a cashier's drawer out of reach of clients.
The county social services director or office supervisor will inform local law enforcement officials of the issuing office operation and advise them of the maximum amounts of EBT cards handled.
If EBT cards are returned to the bank at the end of the day and/or EBT card mailings are delivered to the post office by issuance personnel, an escort shall be provided. EBT card deliveries shall not be made by only one person, especially at night.
Offices that use itinerant issuance points shall take additional precautions to protect EBT cards in transit and during issuance. An escort shall be provided to and from the itinerant point and shall be present during issuance hours.
To prevent embezzlement, there shall be a division of issuance responsibilities. The supervisor must verify issuance records and resolve or document any discrepancies in daily reconciliation.
At a minimum, supervisory personnel must take a monthly physical count of all EBT cards in the bulk EBT card storage points and EBT cards in each cashier's working stock. The end-of-the-month physical inventory must be accomplished after the close of business on the last issuance day of the reporting month or prior to the opening of business on the first issuance day of the following month. The actual inventory count is reported on Form FNS-250 (EBT Card Accountability Report). The supervisor must verify the accuracy of the FNS-250 report.
The local law enforcement agency shall be notified immediately by one of the persons at the issuance office who have been designated to carry out the reporting of a robbery or burglary. The state department shall also be notified immediately and will be responsible for informing USDA/FNS.
The office shall be protected to ensure that evidence is not destroyed. Any articles touched by the robbers (papers, furniture, counter tops) should not be touched by employees or other persons until law enforcement officers arrive.
The names of persons other than employees in the office at the time of the robbery shall be obtained if they insist on leaving prior to the arrival of law enforcement officers.
Each employee shall write down all pertinent information about the robbery. They should be told it is important to record their own impressions and observations prior to any discussion of them with other employees.
After law enforcement officers have made their examinations and with their approval, an immediate reconciliation of EBT cards shall be made to determine the amount of any loss. Stolen EBT cards will be identified by serial numbers.
Issuance offices shall maintain EBT card inventory at proper levels as determined by volume of issuance, availability of adequate storage facilities and insurance coverage. EBT card inventory levels shall not exceed a six-month supply, including EBT cards on hand and those on order.
The security of issuance offices shall be continually monitored to ensure that adequate safeguards and insurance coverage are provided for the EBT card inventory on hand.
Arrangements have been made for issuance offices with sufficient issuance volume to receive shipments of EBT cards directly from USDA/FNS. Offices with low issuance volume will receive EBT card shipments from the state department storage vault by fully insured registered mail.
It is advised that issuance offices that receive direct shipments should check EBT cards after monthly reconciliation and order EBT cards according to USDA/FNS instructions. USDA/FNS will assess the reasonableness of EBT card requisitions based on prior inventory change. The requisitioning issuance office will be notified prior to any adjustment made to requisitions.
Those issuance offices which receive their EBT card supply from the state department storage vault shall requisition EBT cards in accordance with the instructions from the state department. The instructions will advise of procedures for ordering from the contractual EBT card provider.
Issuance offices and bulk storage points shall promptly verify and acknowledge, in writing, the contents of EBT card shipments received, and shall be responsive for the control and storage of EBT cards. Cartons of blank EBT cards are usually numbered consecutively, and serial numbers should be verified upon receipt of shipment. The receiving agent shall ensure that the indicated number of cartons is received before signing the receipt form.
When a shipment of EBT cards is received from USDA/FNS, an original and three (3) copies of Form FNS 261 (Advice of Shipment) are mailed to the receiving agent. If the shipment is in order, the receiving agent shall complete Form FNS 261. If the shipment is not in order, immediately notify the State Department. The receiving agent will then be instructed to annotate Form FNS-261, describing the EBT card discrepancy or damaged condition of the EBT cards. Form FNS 261 must be signed, dated, and submitted in the normal manner.
When a shipment is received from the State Department, Form FNS-300 (Advice of Transfer) is mailed to the receiving agent in the original and three (3) copies. If the shipment is in order, the original and all copies of Form FNS-300 are signed and dated by the receiving agent. If the shipment is not in order, immediately notify the state department.
Prior to issuance, each carton and box of EBT cards shall be examined. When there is a shortage or overage of EBT cards, Form FNS-471 must be completed and signed by two witnesses. In the case of a shortage, show the amount of shortage on Line 13 of Form FNS-250 as credits. In the case of an overage, show the amount on Line 9 of Form FNS-250 (Shipments Received from USDA/FCS) regardless of where shipment originated.
If EBT cards are improperly manufactured or mutilated, Form FNS-471 shall be completed. The EBT cards are cancelled immediately and destroyed at the end of the month in accordance with Section 4.708.5.
If one or more boxes of EBT cards were improperly manufactured, local offices shall contact the state department, who will contact USDA/FNS on the instructions for disposition of the destructible EBT cards. EBT cards must be destroyed within thirty (30) calendar days from the close of the month in which the EBT cards were received. For disposition of mutilated EBT cards returned by participants, refer to Section 4.708.5.
There will be occasional instances where an EBT card will be substituted for an EBT card damaged in manufacturing. Out-of-sequence serial numbered EBT cards in the box present no problem as long as the correct number of EBT cards are contained in the box, and shall be issued in the normal manner.
Local assistance offices may legally contract with other parties such as banks, savings and loan associations, the U.S. Postal Service, community action and migrant service agencies, and other commercial businesses, the responsibility of issuance and storage of EBT cards. Contractors may be permitted to subcontract assigned issuance responsibilities with the approval of the local office.
Any delegation of issuance and EBT card security must clearly delineate the responsibilities of both parties. Local offices remain responsible regardless of any agreements to the contrary for ensuring that assigned duties are carried out in accordance with the regulations. Local offices are still liable to USDA/FNS for all losses of EBT cards regardless of the actual responsibility for duties.
If an issuance office/agent or bulk storage point is being closed for noncompliance with contractual agreements, the local assistance office shall perform weekly reconciliation until alternative issuance or storage points are obtained.
The state department shall conduct an onsite review of each EBT issuance office and bulk storage point at least once every three (3) years. All offices or units of an EBT issuance office are subject to this review requirement. The state department shall base each review on the specific activities performed by each EBT card issuer or bulk storage point. A physical inventory of EBT cards shall be taken at each location, and count compared with perpetual inventory records and the monthly reports of the EBT card issuer or bulk storage point. This review may be conducted at branch sites as well as the main offices of each issuer and bulk storage point that operates in more than one office.
Over the counter and mail issuance responsibilities shall be divided between a cashier and another issuance employee.
The cashier shall use Form FS-10 (Daily Report of Books Issued) each issuance day to record his/her beginning EBT card inventory to show the amount of EBT cards received to replenish the cashier's card stock supply, to show returns to inventory, and to enter total amount of EBT cards on hand by physical count at the end of the issuance-day. The cashier's actual issuance totals must be reconciled with Form FS-52, Form FS-11 or other authorizing documents each issuance day.
EBT cards shall be maintained in a secure location with access limited to authorized personnel. The issuance supervisor shall establish proper tracking and accounting methods to replenish each cashier's EBT card stock supply as needed.
In all issuance systems, EBT card issuers shall reconcile their issuance daily using daily tally sheets, cashiers' daily reports, tapes or printouts.
The daily total of issuances is recorded for printouts by the automated system, and shall also be reconciled with the cashiers' daily total of actual issuance of EBT cards determined by physical count. Any unresolved discrepancy must be verified daily and on the cashiers' Form FS-10.
The local office shall maintain issuance and reconciliation records for a period of three (3) years from the month of origination. This period may be extended with the written approval of USDA/FNS. Issuance and reconciliation records shall include, at a minimum, reports regarding Notices of Action, Notices of Change, and inventory record. Forms FNS-250, FNS-259, FNS-46 and substantiating documents, cashiers' daily reports, cashiers' daily tally sheets, master issuance files, the records for issuance for each month and any rosters or lists produced by the automated system. In lieu of the records themselves, easily retrievable microfilm, microfiche, or computer tapes that contain the required information may be maintained.
Local offices shall control all issuance documents that establish household eligibility while the documents are transferred and processed within the local office. The local office shall use numbers, batching, inventory control logs, or similar controls from the point of initial receipt through the issuance and reconciliation process. Access to all Notices of Action that initiate or terminate the master issuance file and blank EBT cards shall be limited to authorized personnel.
The issuance office shall mail EBT cards to all eligible households if the household does not utilize any available in person pick up option. Certified households must be issued EBT cards by the end of the month except when benefits are suspended, cancelled, or reduced.
If benefits have been suspended, and the local office receives a directive to resume issuance of benefits, the issuance of mailed or over the counter EBT cards will be staggered through the end of the month or over a five-day period following the resumption of issuance. This could result in benefits being issued after the end of the month in which the suspension occurred.
All EBT cards shall be mailed as first-class mail, in sturdy non-forwarding envelopes.
USDA/FCS will assume financial liability for all properly issued EBT cards lost in the mail except losses in excess of three tenths of a percent (0.3%) of the state total quarterly mail issuance loss. Each local office that has a mail loss during a quarter will be assessed a percentage of the state total penalty when a penalty is assessed against the state by the USDA/FNS.
Form FNS-259 reports shall be submitted by local offices for each unit using a mail issuance system. Local offices shall submit Form FNS-259 reports so that they are received by the fifteenth (15th) day of the next month.
10 CCR 2506-1-4.707