Overview
The Department of Transitional Assistance (DTA) should strive to make its Electronic Benefits Transfer (EBT) card issuance process as transparent and accessible as possible. This is critical to not only ensure that eligible recipients have the ability to obtain benefits but also to ensure that tax dollars are spent properly. We sought, in part, to answer stakeholder concerns about potential fraud, waste, or abuse of tax dollars in the form of EBT cards. We analyzed how EBT cards were issued, how eligibility for benefits was determined, and how EBT cards were impacted by emergencies, such as the COVID-19 pandemic. What became clear during our audit was how difficult it was for recipients to navigate the maze of different benefit programs and the perceived lack of clarity (from the perspective of the taxpayers) on how much was being spent on these programs. This information is public and should be easily accessible through DTA’s website so that stakeholders can view how tax dollars are being spent. We strongly recommend that DTA increase accessibility and transparency into the EBT card issuance process and create a comprehensive plan for future emergencies.
EBT cards are the mechanism that transfer cash benefits (Supplemental Nutrition Assistance Program [SNAP], Transitional Aid to Families with Dependent Children [TAFDC], Emergency Aid to the Elderly, Disabled and Children [EAEDC]) to either pay for purchases or to be used directly as cash (including withdrawals at ATMs).29 EBT cards are issued to benefit recipients; however, funds are not added to the cards until eligibility is determined. Funding for these programs comes from a variety of sources. While the state largely funds EAEDC,30 the federal government funds TAFDC31 and SNAP. The US Census Bureau tracks the total number of SNAP recipients in Massachusetts.32 Over the past 25 years, there has been substantial growth in the number of EBT card recipients in Massachusetts from roughly 220,000 in 2000 to over 1,000,000 in 2025. For an overview of the total amount of benefits, see the “Net Benefits Issued by Program (Unaudited)” table, which breaks down the different benefit types for fiscal years 2022 through 2025 (until March 21, 2025).
Our office last audited the EBT program in 2013. The audit,33 reviewed DTA’s eligibility determination processes and its controls over EBT card usage during the period of July 1, 2010 through December 31, 2012. The 2013 audit uncovered significant deficiencies in the EBT card issuance process and benefit distribution and potentially fraudulent transactions. For example, we found that DTA used a system that administered EBT cards with benefits already pre-loaded onto them. Based on this and other findings, we recommended that DTA make substantial reforms regarding staff member procedures and the management of systems such as the Benefit Eligibility and Control Online Network (BEACON) system.
The EBT system that was the subject of our 2013 audit was replaced in 2016.34 Under the current system, EBT cards are first issued, then eligibility for each specific benefit is determined before an EBT card holder can access or use benefits. This process is meant to ensure that cards are distributed to recipients without delay, but that benefits are awarded only to recipients who meet the eligibility requirements of each program.
Anomalies in the EBT Card Issuance Process
Stakeholders have inquired about how the current EBT system works and anomalies in the issuance process and the distribution of benefits; particularly in light of the significant increases in the number of EBT cards issued. Under the current system, DTA issues far more EBT cards than the number of clients. The discrepancy between the number of EBT cards and the number of clients is due to several factors. The primary reason is that DTA issues EBT cards to multiple members of each household (client). For example, although a household of four counts as one client, DTA can issue up to four EBT cards, one for each household member. The result is that there are a larger number of active EBT cards than the number of clients.
A second contributing factor to the large discrepancy between number of active EBT cards and the number of clients is that there are active EBT cards that are unfunded because the recipients have become ineligible to receive benefits. These unfunded cards are not deactivated due to recent ineligibility. DTA’s rationale is that the recipient of the EBT card could become eligible in the future, so deactivating the EBT card could be counterproductive. Additionally, the Pandemic EBT program issued EBT cards to households that no longer had access to school lunches due to the closure of schools during the COVID-19 public health emergency. Many of these households, which were temporarily eligible for the Pandemic EBT benefits, became ineligible for benefits after the pandemic, and EBT cards issued to these households remain active but are unfunded.
Eligibility
During the COVID-19 pandemic, SNAP eligibility requirements were paused by the federal government35 to facilitate access to resources during the emergency.36 This led to a rapid increase of Summer EBT and Pandemic EBT cards so that recipients could access SNAP benefits. The number of Summer EBT and Pandemic EBT cards (tracked together) was 174,199 in July 2021 and peaked at 365,710 in July 2024.37 As of December 2024, there were only three EBT cards issued under the Summer EBT and Pandemic EBT programs.
Duplicate Cards
Another area of concern regarding EBT cards is duplicate cards. As explained in the “EBT Cards” section, the EBT system does not allow for duplicate cards. Specifically, when a new EBT card is issued to a recipient, the previous cards is deactivated by the Electronic Payment Processing Information Control (EPPIC) system. The EPPIC system is used by DTA to distribute benefits to the EBT card accounts of program participants every month.
Eligible Purchases
DTA tracks the use, including the location of uses, of EBT cards.38 Additionally, only eligible purchases are approved.39 If someone attempts to use an EBT card for an ineligible purchase, e.g. alcohol or cigarettes, payment for those specific purchases is declined at checkout. Any retailer that accepts EBT payments must have a Point of Sale system40 that approves eligible purchases and declines ineligible purchases. See the “Benefit Eligibility and Control Online Network System” and “EBT Cards” sections of this report.
Immigrant Access to EBT Cards
Certain immigrant populations were eligible for cash and SNAP benefits. According to DTA’s Online Guide “Cash and SNAP Benefits for Immigrants,” individuals who are eligible for benefits include US citizens, certain noncitizens (such as lawful permanent residents, refugees, asylees, Cuban/Haitian entrants, Amerasian immigrants, Iraqi and Afghan Special Immigrant Visa holders, certain Afghans, and Ukrainians granted humanitarian parole), and victims of trafficking.41 See the “TAFDC Pathways to Work Program” section and the “TAFDC PTW Program Participants” section.
Recommendations
We recommend that DTA develop a more transparent and accessible system for EBT card issuance and spending along with a clear plan for responding to future emergencies. The COVID-19 pandemic can be used as a starting point, but a plan should be prepared for all types of emergencies, including natural disasters, public health, or any other event that disrupts food supplies or access.
Planning ahead is critical to ensure that DTA can move quickly in an emergency to distribute benefits while ensuring that fraud, waste, or abuse is minimized. Information about the total cost and allocations of EBT cards and the benefits that DTA distributes should be more transparent so that stakeholders, taxpayers, and EBT card recipients can understand the broader impact and scale of these programs. This information can be added to the website in one page or section that covers all the different benefits that DTA distributes with historical data to show how spending has changed over the years. These reforms would not only help recipients understand the benefits for which they are eligible, but also provide stakeholders a clear picture of how DTA manages EBT cards and benefits.
Auditee’s Response
Turning to matters outside of the scope of the audit, yet explored by the [Office of the State Auditor (OSA)] audit team, DTA agrees that transparency into benefit programs, their scale, and Department operations is important information for stakeholders. DTA offers a comprehensive public-facing website (mass.gov/DTA) for Massachusetts residents to explore programs and assistance. On this website, DTA shares monthly performance scorecards that offer demographic insight into benefit recipients and operational performance, and provides monthly reports detailing caseload by zip code and Healthy Incentives Program (HIP) spending, among other topics of public interest. DTA also publicly shares its annual reports submitted to the Massachusetts Legislature on its website. In addition, DTA’s comprehensive policy guide, the DTA Online Guide (OLG), is also available online and can be easily searched by word topic.
In the draft audit report OSA discussed stakeholder inquiries about EBT card volume and issuance anomalies. DTA believes the audit team thoroughly explored the operational and programmatic impacts that dictate EBT card distribution. As discussed throughout DTA’s response, the COVID-19 pandemic public health emergency significantly changed certain components of DTA operations, including introducing new benefit programs (like Pandemic EBT, and later Summer EBT/SUNBucks) that served new clients resulting in higher EBT card volume, and necessitating a rapid shift to remote work then a return to a hybrid office environment. While it is expected that there would be more physical EBT cards, only the EBT cards that are held by an eligible household with an active case that is currently receiving benefits have funds added onto the card. Outside of this, an EBT card is an empty card with no value if benefit funds are not sent to it, much like an MBTA Charlie Card that has no current funds on it.
The OSA audit team’s exploration of other matters in the sections titled: Anomalies in the EBT Card Issuance Process, Eligibility, Duplicate Cards, Eligible Purchases, and Immigrant Access To EBT Cards, are accurately represented and will help inform interested stakeholders of factual information impacting benefit eligibility and DTA operations.
In regard to planning for emergencies, DTA actively maintains several disaster response plans that are updated annually. The Department’s operational disaster response plan is called a Continuity of Operations Plan (COOP) which is an internal document designed to ensure that essential functions and services continue across a wide range of potential emergencies or disruptions. State agencies and municipalities in Massachusetts use these plans to prepare for disasters and recover quickly.
DTA Operations also engages quarterly with the Massachusetts Emergency Management Agency (MEMA) which supports emergency management activities across state agencies and coordinates local and regional activities related to emergency shelter, mass feeding and emergency housing and human services during times of emergency. DTA maintains annually a Disaster SNAP plan, which is required by SNAP State Administering agencies. Disaster SNAP, or D-SNAP, is a federal program that [US Department of Agriculture Food and Nutrition Service] can activate in response to catastrophic regional events and coordinates among state, territory, tribal, and voluntary organizations to provide nutrition assistance to families and individuals affected by a disaster or emergency. D-SNAP has not been activated in Massachusetts in many years, but is kept updated.
DTA also actively coordinates and participates in several cross agency and public-private working groups to support the local food system, which are ongoing and further energized in response to emergencies like the COVID-19 public health pandemic, and the recent Federal Government Shutdown impact on regular SNAP distribution. This includes the ongoing Interagency Food Security Working Group, the Food Policy Council, and most recently the Healey-Driscoll Administration’s Anti-Hunger Task Force.
Auditor’s Reply
We acknowledge DTA’s response regarding our Other Matters and acknowledge its stated commitment to transparency and stakeholder engagement. DTA stated in its response: “Turning to matters outside of the scope of the audit, yet explored by the [Office of the State Auditor (OSA)] audit team.” We note that the addition of this Other Matters is authorized by Generally Accepted Government Auditing Standards (GAGAS), which allows auditors to add audit topics and “Other Matters” when, in the course of their work, they find issues that require further investigation. This is authorized even if these items were outside the original scope of the audit. Other Matters and additions to the scope of our audits are designed to assist the Commonwealth and the audited agency—and ultimately the people of Massachusetts and those served by a particular agency of government. We encourage DTA to take thoughtful and proactive steps to address the concerns we have raised.
| Date published: | January 30, 2026 |
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