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Research & Policy
Policy Matters Ohio

Testimony on SB 165 before the General Government and Agency Review Committee

October 09, 2019

Testimony on SB 165 before the General Government and Agency Review Committee

October 09, 2019

Good afternoon, Chairman Schuring, Vice Chair Rulli, Ranking Member O’Brien and members of the committee. My name is Will Petrik and I am the Budget Researcher with Policy Matters Ohio, a nonprofit, nonpartisan organization. Our mission is to create a more prosperous, equitable, sustainable and inclusive Ohio. Thank you for the opportunity to testify on Senate Bill 165.

Our work focuses on strengthening Ohio’s workforce and ensuring all Ohioans are healthy, stable and secure. Basic food security is a crucial foundation for health, security, and a strong workforce.

The stated purpose of this bill is to:

  • Protect the integrity of the Supplemental Nutrition Assistance Program (SNAP)
  • Deter trafficking in SNAP cards for drugs and other illegal activity; and
  • Preserve resources for those in need.

Policy Matters Ohio agrees with these goals. Unfortunately, the bill as it is written will not accomplish these intended outcomes.

The proposed legislation doesn’t address program integrity

Missouri was the first state to pass and implement a SNAP photo EBT card requirement in 2000. A 2001 state audit of Missouri’s photo EBT card program found the photo ID tactic to be “useless.” According to the audit, “State officials expected the cards to help deter fraud, but federal regulations allow any family member to use the card, which renders the photographs useless for fraud or identification.”[1] Missouri’s state legislature ended the policy after learning about the ineffectiveness of the program.

The proposed legislation will not deter trafficking of SNAP cards

A number of states have considered or implemented SNAP photo EBT requirements since 2000. The Congressional Research Office looked at several states that have implemented a SNAP photo EBT card to evaluate the impact. The lesson learned from states that have tried the photo EBT card strategy is straightforward. It has “little to no effect on recipient trafficking.”[2]

That’s why it is not surprising that the vast majority of states have decided against a photo ID policy. Since 2000, Missouri, Maine, Georgia, Massachusetts and New York all passed legislation to implement a photo ID for SNAP EBT cards. All of those states with the exception of Massachusetts have ended the program. Over a dozen other states have considered and decided against photo ID policies after studying the costs and actual outcomes.

One of the proponents claimed a photo would deter trafficking, because the current SNAP cards are “easy to use - under federal regulations, possession of the card plus the PIN equals authorized use.” A photo doesn’t change the federal regulations. This will still be the case if recipients are required to have a photo on their SNAP card.

The proposed legislation will limit critical resources for Ohioans in need.

The most concerning aspect of this legislation is the potential impact on Ohioans who participate in the SNAP program. The state of Maine ended its photo ID requirement earlier this year because the policy “threatens eligible Mainers’ access to assistance.” The Maine Department of Health and Human Services called the photo requirement an “ineffective policy.”[3]

Rather than preserving resources for those in need, this policy would:

  • Increase food insecurity of children, adults, and families; and
  • Increase administrative costs and create barriers to accessing food assistance

My colleagues plan to outline the administrative costs, so I will focus on the human cost. Evidence shows that poverty harms children’s development and well-being. For instance, children who grow up in deep poverty develop weaker language, memory and self-regulation skills than their peers in higher income families. When the grow up, they have lower earnings, more health challenges, and are more likely to be involved in the criminal justice system.

On the other hand, programs that alleviate poverty, such as SNAP, improve child well-being. When children have access to stable, affordable housing, nutritious food and quality child care, they have better health, do better at school, and earn more on average. SNAP helps ensure Ohio’s children have a chance to achieve success.[4]

In states where this policy has been enacted, children, adults, and families who need access to nutritious food have faced barriers applying for and retaining access to food and nutrition assistance.

I urge you all to oppose this legislation. SB 165 will not strengthen the integrity of SNAP, it will not deter trafficking of SNAP cards, and it will, if passed, harm residents with low-income in your districts and across the state. I will be happy to take any questions.


[1] Office of State Auditor Claire McCaskill, “Audit of Department of Social Services Electronic Benefit Security Card and Electronic Benefit Transfer Benefit Delivery System.” https://bit.ly/31XLmOp

[2] Aussenberg, Randy Alison, "Errors and Fraud in the Supplemental Nutrition Assistance Program (SNAP)," Congressional Research Service. https://bit.ly/2M0kbxc

[3] Acquisto, Alex, "Mills reverses another signature LePage move by pulling photos from EBT cards," Bangor Daily News. https://bit.ly/31ZMMYR

[4] Carlson, Steven, Rosenbaum, Dottie, Keith-Jennings, Brynne, Nchako, Catlin, "SNAP Works for America’s Children," Center on Budget and Policy Priorities. https://bit.ly/2nYx51Z

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