Comment on FR Doc # 2012-12907

• Originally, we know that USDA-FNS was considering requiring states to respond in a prescribed manner to persons and households who have received multiple EBT card replacements or requested multiple EBT card replacements. Under the proposed rule, while response is strongly encouraged, it is not mandated but instead is left to the option of the states. At meetings held this past Spring on the topic of SNAP program integrity, many states strongly advised USDA not to mandate response but to leave it up to the states how best to respond. USDA listened to the states, and we thank and congratulate them for doing so. • Although the implementation of the engagement of multiple card replacement requestors is optional under the proposed rule, as noted above and in Administrative Notice 20-2012, issued May 1, 2012, engagement of multiple card replacement requestors is strongly being encouraged by USDA-FNS. OTDA is concerned about the potential impact of this rule on the homeless population. While 274.6 (b)(5)(iii) requires State agencies to act to protect households containing homeless persons, we want to note that implementation of the options available under the proposed rule would be difficult and impractical to apply equitably to the homeless population. Ensuring proper notification of homeless clients is always a challenge. Further, EBT cards can be multi-benefit cards and these proposed rules may not be effective for multiple benefit program clients. In New York State, for example, in addition to SNAP our “Combined Benefit Issuance Card” (or CBIC) also is the EBT card for our cash assistance programs and is our state’s Medicaid card. Because it also is our state’s Medicaid card and almost all of our SNAP cardholders also receive Medicaid, it is highly unlikely that we ever would or could withhold a CBIC. • We also note that the tracking system that would be required under the option permitted under the proposed rules (and strongly encouraged by USDA-