On January 6, 2016, the United States Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) published a Proposed Rule entitled, “Supplemental Nutrition Assistance Program (SNAP) Photo Electronic Benefit Transfer (EBT) Card Implementation Requirements” (Proposed Rule). The Proposed Rule would, among other things, provide parameters on the requirements for States that elect to implement a photo on an EBT card and establish procedures to ensure that any member of a household or authorized representative of the household regardless of whether their photo is on the card is able to purchase food. 

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