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Iowa’s TANF State Plan

32 and Licensing (DIAL) for further investigation. If the referral is founded, the action will be considered fraudulent. Penalties for the participant household include:  Requirement to repay any amounts accessed at a prohibited location, along with any associated fees that may apply;  Three-months of FIP ineligibility for the first finding of misuse; or  Six-months of FIP ineligibility for each subsequent finding of misuse.

When parents from a two-parent family separate during an ineligibility period:  If the participant who misused the EAC is identified, the ineligibility period will follow only that participant.  If the participant who misused the EAC at a prohibited location is not identified, the ineligibility period will follow the participant identified as the head of the household when the violation occurred.

As of January 1, 2014, information regarding the Middle-Class Tax Relief and Job Creation Act of 2012 requirement that limits where FIP participants can use their EAC and the penalties for using the card at a prohibited location was added to essential FIP forms. These forms include:  FIP Notices of Decision (NOD) for benefit approval, change and reinstatement;  FIP Application;  Review/Recertification Eligibility Document (RRED), form 470-2881, 470-2881(S);  Comm. 108-Family Investment Program Brochure;  Comm. 377 FIP Electronic Access Card; and  Comm. 233 Right and Responsibilities.

State statute gives the Iowa HHS the authority to take additional measures if required by federal law. Such measures could require changes in administrative rules, employee manuals, systems, forms and other informational materials issued to FIP applicants and recipients, and the contract the Iowa HHS has with the vendor managing EAC accounts.

To ensure that these policies and procedures do not prevent recipients from having adequate access to their cash assistance, the state has, to the extent not expressly precluded by federal law or regulation, or by the federal Office of Family Assistance (OFA), further defined the places described in section 408(a)(12) so as to minimize the number of locations where electronic benefit transactions are prohibited, and to maximize the number of locations where the prohibition does not apply.

Given the total number of financial institutions, automated teller machines (ATMs) and point- of-sale (POS) devices in the state that accept the state’s EAC, and that the state’s EAC allows for receiving cash back at point-of-sale devices in conjunction with making a purchase when such service is available, ATMs and POS devices at prohibited locations (as defined by the state), represent a very small percent of the total. The sheer volume of alternative locations where electronic benefit transactions are not prohibited ensures that FIP families continue to have adequate access to their benefits.

See Attachment J for additional details describing policies and practices to prevent electronic benefit access at prohibited locations while ensuring recipients have adequate access to their benefits.