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transactions. The methodology was tested by FIS and is also being utilized in several other states. D.C. is using the Fraud Navigator to block transactions at liquor stores, casinos and places for adult entertainment. It also allows D.C. to track activity and patterns, which should further reduce public assistance fraud. FIS provides a report of all blocked transactions to D.C. on a monthly basis.

D.C. has implemented the following policies to ensure access to benefits for all TANF customers:

• D.C. uses the Electronic Benefits Transfer (EBT) system in place of the paper-based welfare benefits issuance system. EBT allows TANF customers to access their benefits through automatic teller machines (ATM) and point-of-sale devices to electronically deliver cash assistance and Supplemental Nutrition Assistance Program (SNAP) benefits throughout each Ward of D.C. There are eight (8) Wards in D.C. The entire city is linked by public transportation and each Ward has commercial banking establishments where funds can be accessed. DHS is able to review both the blocked transactions as well as the executed transactions. Should the blocked transactions become proportionally high (over 5% of the total transactions) D.C. will review access.

• D.C. covers the cost of any access charges and fees, thus making benefits easily accessible with no transactional costs. TANF customers are notified of the accessibility with no transactional costs through DHS written policies, and DHS posts the information publicly online. DHS modified the Integrated Combined Application for Public Assistance to include notification about the restrictions on EBT usage.

• FIS has a sub-contracted provider, United Planning Organization (UPO), with the responsibility of distributing EBT cards at brick-and-mortar locations. D.C. mails EBT cards to the customers’ homes, and UPO also has two storefront locations.