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United Council on Welfare Fraud

Strengthening Integrity in our Public Assistance Programs



July 5, 2011

Ronald Ward
Acting Chief
Retailer Management and Issuance Branch
Benefit Redemption Division, Room 418
3101 Park Center Drive
Alexandria VA 22302

Dear Mr. Ward:


The United Council on Welfare Fraud (UCOWF), an international organization of fraud investigators, administrators, prosecutors and collection agents, and the National Association of State Welfare Fraud Directors (NASWFD) are in support of the Proposed Rules issued 6/20/11 regarding changes to 7 CFR Parts 271, 273 and 281.

UCOWF and NASWFD have had numerous communications with the USDA urging these changes.  Our investigators see firsthand the damage done to public perception and program integrity as they receive complaints such as SNAP recipients dumping cases of soda in store parking lots for the deposits and SNAP recipients purchasing/re-selling turkeys during the holidays.  We look forward to the revised regulations so that these SNAP abuses can be curtailed, and recipients who abuse SNAP can be disqualified.


Attached is a copy of the latest letter our organizations sent to Deputy Administrator Shahin.  We certainly hope that the changes we have proposed in this letter will be seen soon in the next set of proposed rules.  Please do not hesitate to contact us if you have further questions.


Bruce Carmichael, Chairperson NASWFD

PO Box 66277

Newton, Massachusetts 02466


cc: John Bumford, President

Paula Hisle, Co-chairperson, UCOWF Intergovernmental Committee

Sandy Smith, Co-chairperson, UCOWF Intergovernmental Committee


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