COMMITTEE ON LEGISLATIVE RESEARCH
OVERSIGHT DIVISION
FISCAL NOTE
L.R. No.:0993H.01I Bill No.:HB 315 Subject:Public Assistance; Department of Health and Senior ServicesType:Original Date:January 2, 2025Bill Summary:This proposal prohibits Temporary Assistance for Needy Families (TANF)
benefit cards from being used at ATMs or to access cash and limits the items
that may be purchased with TANF benefits.
FISCAL SUMMARY
ESTIMATED NET EFFECT ON GENERAL REVENUE FUNDFUND AFFECTEDFY 2026FY 2027FY 2028General Revenue($1,106,426)($1,860)($1,907)Total Estimated Net
Effect on General
Revenue($1,106,426)($1,860)($1,907)
ESTIMATED NET EFFECT ON OTHER STATE FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Total Estimated Net
Effect on Other State
Funds $0$0$0
Numbers within parentheses: () indicate costs or losses. L.R. No. 0993H.01I
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ESTIMATED NET EFFECT ON FEDERAL FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Federal Funds*$0$0$0Total Estimated Net
Effect on All Federal
Funds $0$0$0
* Income and expenses exceed $1 million for FY 2026; exceed $1,000 annually beginning in FY
2027 and net to $0.
ESTIMATED NET EFFECT ON FULL TIME EQUIVALENT (FTE)FUND AFFECTEDFY 2026FY 2027FY 2028Total Estimated Net
Effect on FTE 000
☒ Estimated Net Effect (expenditures or reduced revenues) expected to exceed $250,000 in any
of the three fiscal years after implementation of the act or at full implementation of the act.
☐ Estimated Net Effect (savings or increased revenues) expected to exceed $250,000 in any of
the three fiscal years after implementation of the act or at full implementation of the act.
ESTIMATED NET EFFECT ON LOCAL FUNDSFUND AFFECTEDFY 2026FY 2027FY 2028Local Government$0$0$0 L.R. No. 0993H.01I
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FISCAL ANALYSIS
ASSUMPTION
§ 208.024 - SNAP/TANF EBT prohibited transactions; participants may not obtain cash
Officials from the Department of Social Services (DSS) state federal law passed in 2012, (42
U.S.C. 608(a)(12)), requires states to implement policies and practices to prevent Temporary
Assistance for Needy Families (TANF) benefits from being used in any liquor store, casino,
gambling casino, gaming establishment, or adult-oriented entertainment establishment. The
Family Support Division (FSD) has a claims process and procedure in place if eligible TANF
participants make an EBT purchase in violation of § 208.024, where the recipient is required to
reimburse the state at each offense. This policy is in place and being practiced.
However, additional systems updates will be needed to disqualify the recipient at the third
offense for five years. FSD feels it can accomplish this with existing resources.
Oversight has no information to the contrary and will assume the Family Support Division can
make changes to disqualification periods of TANF recipients with existing resources.
DSS
SNAP benefits shall use an EBT card to obtain cash from any automated teller machine (ATM)
or point-of-sale (POS) terminal or otherwise access the benefits as cash.
This section will only impact the TANF population, as SNAP cannot be used at an ATM, to get
cash back or to otherwise access the benefit as cash. The Department of Health and Human
Services (DHHS) does not require a waiver to implement restrictions of EBT card usage and
allows states to use their own discretion when implementing policies and procedures regarding
use of EBT cards. A small portion of TANF participants who receive their benefit via direct
deposit into a personal checking or savings account would not be affected.
To implement this legislation, EBT TANF could only be accessed via a cash purchase
transaction performed on a Point of Sale (POS) terminal. All other cash transactions would be
turned off or denied.
Currently, Missouri’s online EBT systems are interoperable through the QUEST® network,
which is sponsored by the Electronic Benefits and Services Council. QUEST® sets the rules for
the distribution of government benefits. However, if Missouri limits TANF transactions to
purchases only, it will be in violation of QUEST® operating rules. Missouri must remove any
QUEST® logos from all Missouri EBT cards.
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To limit EBT TANF transactions to purchases only, replacement EBT cards will have to be
issued for every active TANF and SNAP eligibility unit in the state.
Fidelity National Information Services (FIS), the Missouri EBT contractor, has provided a cost
estimate to implement the changes of this legislation. All EBT cards would have to be
destroyed/deactivated and reissued for all programs that utilize the EBT card for benefit
distribution. In addition, all EBT programing would need to be altered for all EBT QUEST®
states as participants would not be able to use their card in other states.
Estimates are based upon the following assumptions:
Recipient training and notification:
The State will provide their TANF recipients with notice of the change in the way they can
access their cash assistance benefits. Notice will be given prior to implementation of the
change. The State will provide FIS with a copy of any notice or mailing given to the TANF
recipients to prepare the Recipient Help Desk [Crusecom] for any calls they may receive.
The State will no longer be able to be part of the QUEST® network. Issuance of new EBT cards
without the QUEST® logo will be required.
Re-contracting will be needed with every EBT-Only merchant, Third Party Processer (TPP) and
Network if the State is no-longer uses QUEST®. All current contracts are QUEST® contracts.
No special reporting needs are required by the State.
Assisted and non-assisted testing will not be required between FIS and the State.
Start-up costs (Development, notification, OIG update) $12,520
($12,000 + $20 + $500)
Development & Implementation $12,000
Notification to TPPs, Networks & EBT Processors $20
Help Desk Call Support Cost:
Client Help Desk Call Support $1.50 per minute
OIG Update $500
The State will be charged an IVR up front 20 second message per call enhancement and a
Recipient Help Desk call minute surcharge if the total Missouri monthly call minutes increase by
10% or more over the average monthly minutes of the 3 months prior to implementation. The
state will be subject to a surcharge of the per minute rate for each month that the call minutes are
over 110% of that baseline for up to 6 months. The surcharge will be charged only for the call
minutes in excess of 110% of the average monthly minutes of the 3 months prior to L.R. No. 0993H.01I
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implementation. The Family Support Division assumes the calls will not exceed 110% of the
average calls received in the previous three months.
In addition, if the call volume per month exceeds 110% FIS cannot guarantee that the call center
service levels will be made.
Costs Associated with Switch to Non-Quest State
Switching from a QUEST State to a non-QUEST state will require the State to reissue all of their
EBT cards to remove the QUEST logo from the back of the card. The following quotes are based
on the current number of active cards on FIS’ ebtEDGE System. These counts are being used for
example purposes only. Final pricing will be calculated based on the actual count at the time this
project is implemented.
Development/Implementation for Card Reissuance $48,630
Write program to generate new cards for existing cardholders
Card Issuance $1,928,714
The state Missouri has 785,889 active cards as of 12/2023; all cards will need to be deactivated
and reissued to remove the QUEST logo. FIS indicated that their team used last year’s card count
as a high-level estimate as final count and price would be determined at the time of approval is
the proposed section is passed.
Plastic $157,178
Insert $125,742
Envelope $31,436
Printing & Inserting $267,202
Card Carrier $471,533
Postage $873,123
Card Re-design $2,500
Reconstructing services with EBT-only merchants, TPP and Network $108,325
Re-contracting Services w/ EBT-only, TPP and Networks $46,332
Postage for mail re-contracting $61,993
Destruction of Unusable Card Stock & Carriers $62,100
Cards: Current inventory is 302,264 $30,200
Carriers: Current inventory is 319,173 $31,900
Modifications to Card Carrier $5,000
Printing Card Carrier $28,219
Cash Case Notifications of Allowable Transactions $1,200 L.R. No. 0993H.01I
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Cash Cases 1,420
Development/Implementation for Card Reissuance $48,630Card Issuance$1,928,714Reconstructing services with EBT-only merchants, TPP and
Network
$108,325
Destruction of Unusable Card Stock & Carriers$62,100 Modifications to Card Carrier and Cash Case Notifications of
Allowable Transactions
$5,000
Printing Card Carrier$28,219Cash Case Notification of Allowable Transactions$1,200Start-up Costs$12,520TOTAL:$2,194,708
Therefore, the total estimated contracted cost FSD would incur as a result of section 208.024 is
$2,194,708.00. The cost is 50% GR, 50% Federal, matching the way EBT is claimed, for a total
of $1,097,354 GR and $1,097,354 Federal funds.
In prior years, the fiscal impact was expected to be funded 100% by TANF federal funds. The
on-going TANF grant is currently fully utilized; therefore, this could not be covered with 100%
TANF federal funds and the EBT claim of 50% GR and 50% Federal will provide the funding
split for the fiscal impact of this legislation.
FSD defers to the Office of Administration (OA), Information Technology Services Division
(ITSD)/DSS for system costs to implement the provisions of this legislation.
Oversight does not have information to the contrary and therefore, Oversight will reflect the
estimates as provided by DSS, FSD.
Officials from OA, ITSD/DSS state changes to the Family Assistance Management Information
System (FAMIS) will have to be made to implement this proposal.
FAMIS does not control the usage of the EBT cards or track the account balance. The vendor,
FIS Global, tracks the usage. They convey the balance to the State and FAMIS displays this
information on the payment history screen. The interface is between the EBT team and FIS.
FAMIS provides the data to the EBT team.
FAMIS will have to do some analysis to implement changes to the Sanction/Disqualification
process to implement the requirement where the system needs to reject a participant for any non-
compliance. L.R. No. 0993H.01I
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ITSD assumes that every new IT project/system will be bid out because all ITSD resources are at
full capacity. The current contract rate for IT consultants is $105 per hour.
It is estimated that IT consultants will require 172.8 hours to make the necessary changes to
FAMIS at a cost of $18,144 (50% GR; 50% Federal) in FY 2026 ($9,072 GR; $9,072 Federal).
Ongoing system support is estimated to be $3,720 ($1,860 GR; $1,860 Federal) in FY 2027 and
$3,813 ($1,907 GR; $1,907 Federal) in FY 2028.
Oversight does not have any information to the contrary. Therefore, Oversight will reflect the
costs provided by OA, ITSD/DSS for fiscal note purposes.
Rule Promulgation
Officials from the Joint Committee on Administrative Rules assume this proposal is not
anticipated to cause a fiscal impact beyond its current appropriation.
Officials from the Office of the Secretary of State (SOS) note many bills considered by the
General Assembly include provisions allowing or requiring agencies to submit rules and
regulations to implement the act. The SOS is provided with core funding to handle a certain
amount of normal activity resulting from each year's legislative session. The fiscal impact for
this fiscal note to the SOS for Administrative Rules is less than $5,000. The SOS recognizes that
this is a small amount and does not expect that additional funding would be required to meet
these costs. However, the SOS also recognizes that many such bills may be passed by the
General Assembly in a given year and that collectively the costs may be in excess of what the
office can sustain with its core budget. Therefore, the SOS reserves the right to request funding
for the cost of supporting administrative rules requirements should the need arise based on a
review of the finally approved bills signed by the governor. L.R. No. 0993H.01I
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FISCAL IMPACT – State
Government
FY 2026
(10 Mo.)
FY 2027FY 2028GENERAL REVENUECosts - DSS (§ 208.024) Replacing
Quest ® EBT cards with non-Quest®
EBT cards p. 5-6($1,097,354)$0$0
Costs - OA-ITSD (§ 208.024) FAMIS
system changes p. 7($9,072)($1,860)($1,907)
ESTIMATED NET EFFECT ON
GENERAL REVENUE($1,106,426)($1,860)($1,907)
FEDERAL FUNDSIncome - DSS (§ 208.024) Increase in
program reimbursements p. 5-6$1,097,354$0$0
Income - OA, ITSD (§208.024)
FAMIS update reimbursement p. 7$9,072$1,860$1,907
Costs - DSS (§ 208.024) Replacing
Quest ® EBT cards with non-Quest®
EBT cards p. 5-6($1,097,354)$0$0
Costs - OA, ITSD (§ 208.024) FAMIS
system changes p. 7($9,072)($1,860)($1,907)
ESTIMATED NET EFFECT ON
FEDERAL FUNDS$0$0$0
FISCAL IMPACT – Local GovernmentFY 2026
(10 Mo.)
FY 2027FY 2028$0$0$0 L.R. No. 0993H.01I
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FISCAL IMPACT – Small Business
This proposal may impact small business retailers if they do not re-sign up with the State and
recipients cannot use their benefit cards in those establishments (§ 208.024).
FISCAL DESCRIPTION
This bill changes the law regarding the use of Temporary Assistance for Needy Families (TANF)
and Supplemental Nutrition Assistance Program (SNAP) benefits via electronic benefit transfer
(EBT) transaction. The bill adds pornography to the list of items that are prohibited from being
purchased with TANF or SNAP benefits using an EBT card.
The bill requires that upon a first violation of the prohibition against using TANF benefits via an
EBT card in a prohibited establishment or to purchase prohibited items, a TANF recipient will be
disqualified from receiving benefits for three months; upon a second violation, the recipient will
be disqualified for six months; and upon any third or subsequent violation, the recipient will be
disqualified for five years. An individual may resume participation in the program at the end of
the disqualification period by applying again.
The bill prohibits a recipient of TANF or SNAP from using his or her EBT card at any
automated teller machine (ATM), to receive cash back on a purchase, or to otherwise access the
benefits as cash. If the Department of Social Services determines that a waiver is necessary for
implementation of the prohibition, the Department will apply for a waiver from the Federal
Department of Health and Human Services. (§ 208.024).
This legislation is not federally mandated, would not duplicate any other program and would not
require additional capital improvements or rental space.
SOURCES OF INFORMATION
Department of Social Services
Joint Committee on Administrative Rules
Office of Secretary of State
Julie MorffJessica HarrisDirectorAssistant DirectorJanuary 2, 2025January 2, 2025