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Memorandum of Support

Empire Justice Memo of Support: Eliminate finger imaging from the Food Stamp Program

A.5303 (Wright)/S.740 (Squadron)

The Empire Justice Center strongly supports A.5303/S.740, which would amend section 139(a) of the Social Services Law by adding a new provision (paragraph “n”) to end finger imaging requirements for food stamp-only applicants and recipients in New York State. 

To ensure that the bill is clearly in line with federal law, we recommend the bill be amended to clarify that finger imaging requirements do not affect food stamp eligibility in any way.

Finger imaging technologies are used in just four states (Arizona, California, New York, and Texas), but affect almost one-quarter of the nation’s food stamp caseload, because of the large populations in three of those states. 

Over the years there has been no evidence on a national or statewide level that finger-imaging is a cost effective method of avoiding duplicate participation.  Indeed, finger imaging systems have proved costly to states, and it is unclear that the amount of fraud deterred warrants their costs to the state itself, even without consideration of the costs to eligible households that do not apply. Other states, such as Maryland, Illinois, and Michigan, considered implementing finger imaging systems, but found that such systems were not cost effective and that other methods could fulfill the federal requirement to detect duplicate-aid fraud.  Furthermore, current finger imaging technologies are not failsafe and sometimes produce errors.  Such errors can mean that applicants guilty of fraud are not detected and that legitimate applicants are deemed fraudulent. [1]

Several published studies have shown that finger imaging requirements in the Food Stamp Program deter eligible households from participating. [2] This is especially true with respect to certain groups in the food stamp-eligible population, specifically: elderly and disabled individuals; families living in rural areas of the state, many without reliable access to transportation; families with working adults who cannot take time off from work and households with children between the ages of 18 and 21, whose cooperation with the finger imaging requirement is sometimes impossible for the parents to obtain.

The imposition of finger imaging requirements in the food stamp program has never been mandated by either state or federal law. USDA has allowed states to conduct finger imaging solely for the purpose of preventing duplicate participation.  However, USDA is now openly acknowledging that finger imaging presents unnecessary application barriers for eligible households. [3]

Food stamp benefits are 100% federally funded – there is no state or local share to the cost of the benefits.   It is unconscionable that New York is wasting precious state dollars to fund its finger imaging system, at a time that we are facing an economic downturn and ongoing budget crisis. 

We strongly support A.5303/S.740 which would remove finger imaging as a barrier for households who are applying for food stamps.  As previously indicated, we also recommend that the bill be amended to clarify that finger imaging requirements never apply to food stamp applicants and recipients, regardless of whether or not they are also applying for cash assistance.

End Notes:
[1] See Access and Access Barriers to Getting Food Stamps: A Review of the Literature, Food Research and Action Center, February 2008, pp. 68-69, available at
[2] Id.
[3] “USDA criticizing food stamp application methods,”  Agweek, March 8, 2010, available at

This memo was prepared by:

Barbara Weiner

Empire Justice Center
119 Washington Avenue
Albany, NY 12210

(518) 462-6831
(518) 935-2852