International Biometrics + Identity Association Letter Supports Identity Technology in Texas Benefits Program

Mar 15, 2011: Texas House of Representatives Committee on Human Services The Honorable Chairman, Rep. Richard Peña Raymond The Honorable Vice Chairman, Rep. Geanie Morrison The Honorable Members: Rep. Naomi Gonzalez Rep. Chuck Hopson Rep. Bryan Hughes Rep. Todd Hunter Rep. Jodie Laubenberg Rep. Elliott Naishtat Rep. Van Taylor Dear Chairman Raymond, Vice Chairman Morrison, and Members of the Committee: The International Biometrics & Identification Association (IBIA) appreciates the opportunity to comment on HB 710, which discontinues the use of electronic fingerprint-imaging or photo imaging of applicants and recipients of financial or food stamp assistance. This highly effective longstanding program to deter duplicate participation should be maintained. Ending it will be a step backwards that will reduce the ability of Texas to ensure it provides assistance in the most effective and responsible manner possible for its citizens. The electronic imaging system has:

• Prevented “double dipping” by people claiming multiple identities,
• Stopped false claims by those using identities of legitimate recipients, and
• Protected the identity of recipients by preventing others from claiming benefits by using the identities of recipients.

The electronic imaging system has significantly reduced fraudulent “double dipping.” Opponents say that there is little evidence of “double dipping” fraud to justify continuing it. This statement is patently incorrect because it draws illogical conclusions from the program’s implementation. The system functions as a deterrent to “double dipping.” The big reduction in this type of fraud occurred when the system was first introduced. As an ongoing deterrent, electronic imaging prevents “gaming” of the system. If your fingerprints are already in the system, you are not going to apply again under a different name. Likewise, if someone knows your fingerprints are in the system under your name, that person is not going to apply under your name. Discontinuing the system will result in increased costs to Texas, not a savings. Ending the system will be an invitation to wrong doers. Without the effective deterrent of electronic fingerprint-imaging, “double dipping” will again rise since there will be considerably less risk in trying to “game” the system. Also, still faced with the legal requirement to have measures in place to deter “duplicate participation,” Texas must replace the electronic system with more costly administrative efforts, such as having staff perform checks and visit applicants where they live and work. Texas can ill afford such added costs.

The American Public Human Services Association (APHSA) notes that the program’s administrative costs are already “among the highest of any comparable assistance programs.” As a result, ending the electronic imaging system will likely increase costs. The electronic imaging system protects the identities of the recipients, who represent a vulnerable population. With a recipient’s fingerprints in the system, no other person can steal that recipient’s identity, claim benefits, and create a host of legal problems for that recipient, thereby providing protection for a vulnerable population. The electronic imaging system does not deter participation. APHSA found that “the jurisdictions that use this technology have carefully evaluated whether it deters access, and overall do not find that it does. One state reports a study showing that 87 percent of those questioned do not object to finger imaging. Another state found that benefit deficiencies, including the low minimum benefit, were cited far more frequently as access concerns than finger imaging.” The electronic fingerprint-imaging system enhances the dignity and privacy of applicants and recipients. Alternative methods to deter duplicate participation, involving staff to check up on applicants, are far more intrusive and demeaning than electronic fingerprint-imaging. In addition, people are increasingly aware that biometrics serve to protect identity and do not object to its use.

Biometrics is Used Increasingly to Confirm or Deny a Claim of Identity: The government, the commercial sector, and individual consumers increasingly use biometric-based systems for security, convenience, and privacy. Specific examples include homeland security programs; de-duplication in driver’s licenses; to secure computers and laptops, to protect ubiquitous mobile devices such as cell phones and tablets; to make purchases at the retail level; and in school lunch programs where they protect children who participate in free lunch programs from being stigmatized. The social service arena is simply another case where biometrics is routinely used for identification purposes. Recent public opinion surveys have shown the increasing widespread acceptance of biometrics to protect identity and for convenience.

According to the latest Unisys Security Index report conducted in October 2009, “Nearly two-thirds of U.S. citizens are concerned about identity theft and 58% of Americans would be willing to provide biometric data to protect that identity.” IBIA is a trade association that promotes using technology effectively and appropriately to determine identity and enhance security, privacy, productivity, and convenience for individuals, organizations, and governments. Its membership is open to all stakeholders, both consumers and providers of technologies and solutions for identification and identity verification. IBIA appreciates your consideration of these comments and would be pleased to meet or talk further with you at any time. Sincerely, Tovah LaDier International Biometrics + Identity Association Managing Director
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