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STATE OF ARKANSAS TEMPORARY ASSISTANCE FOR NEEDY FAMILIES REVISED 2023 Page 43 of 46 Step Four – Federal Restrictions - Staff Notification: ¾ Developed and delivered training for DWS TANF staff regarding the Federal Restrictions. Step Five – Development of Program Policies ¾ Developed TANF Program policies that addressed the following: x Penalties for clients who uses or accesses TANF cash benefits in an EBT transaction in a prohibited location. x Penalties for merchants/establishments that allow prohibited EBT transactions. x Process by which agency staff that becomes aware of prohibited EBT transactions to report such transactions. Step Six – Development of EBT Transactions Monitoring ¾ Developed and deployed EBT Transactions monitoring activities will continue within the existing DWS TANF Unit activities. 19.2 Ensuring Reasonable Access to TANF EBT The implications for restricting TANF benefit access at inappropriate locations is a reduction in the number of cash access locations available to EBT cash recipients. This is especially true in rural locations that have very few alternatives for cash access. While use of or access to TANF benefits in an EBT transaction is limited as described above, the Division is also required by federal law to ensure TANF participants have adequate access to their cash benefits. “Adequate access” to TANF benefits is determined on a case-by-case basis and may vary depending on individual participant strengths and barriers, including access to transportation. When a TANF client expresses concern with access to their cash benefits or a worker determines a TANF participant does not have adequate access to benefits, the Division will take reasonable steps to ensure adequate access for the participant. Reasonable steps do not include granting EBT withdrawals at one of the prohibited establishments. 19.3 EBT Card Access Fees and Charges Currently, TANF participants may use an ATM two times per month for free. Some ATMs and retailer POS terminals may surcharge their