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MS 1020

(4)

for payment of the credit account is pursued as trafficking. During a claims interview, a recipient admits to paying on a store credit account with an EBT card. A review of the EBT website account confirms numerous whole dollar ($15.00; $12.00; $18.00) transactions which indicate suspicious purchases. Trafficking is pursued and the retailer information needs to be reported to IAS to submit to Food and Nutrition Services (FNS).

Example 4: A hotline referral was received stating that a retailer purchased 20 cases of soda from a recipient who purchased the soda with SNAP benefits. Trafficking is pursued against the recipient and OIG is notified by the person who received the referral using procedures outlined in Item E of this section, of the retailer’s participation in the transaction.

2. If after reviewing the EBT transaction history and, using professional judgement, no suspicious activity is found or the identified activity does not indicate a strong pattern of trafficking, the RCW has the discretion not to pursue a trafficking referral. Annotate IEES with detailed comments as to the reason for the determination that no trafficking exists.]

3. If trafficking activity has been identified, take the following action:

a. Make copies of the EBT account showing the identified trafficking activities and/or excessive card history.

b. Include all supporting documentation, such as hotline reports or third- party reports, in the claim file.

c. Schedule a telephonic appointment with the recipient to discuss the trafficking activity identified. Schedule an appointment using the IEES scheduling system. If requested, an in-person appointment can be held in the local office of the county where the recipient resides. Discuss all documentation supporting the allegations with the recipient.

d. Thoroughly document the discussion with the recipient as the information obtained is the basis for action taken by the Department of Community Based Services (DCBS).

e. If the household later contacts the agency to cooperate, an interview should be conducted. When a claims specialist is not available onsite for a walk-in recipient, each local office will have a designated worker to interview recipients who come in to resolve a fraud or trafficking complaint.

4. If after a review of the documentation and/or discussion with the recipient (if