!"DISTRICT OFFICE !

"CITY HALL OFFICE

1041 CASTLE HILL AVENUE 250 BROADWAY, ROOM 1781
BRONX, NY 10472 NEW YORK, NY 10007
(718) 792-1140 (212) 788-6853
FAX: (718) 931-0235 FAX: (212) 788-1656
apalma@council.nyc.com

THE COUNCIL OF
THE CITY OF NEW YORK

ANNABEL PALMA
COUNCIL MEMBER, 18TH DISTRICT, BRONX
CHAIR OF GENERAL WELFARE

December 14, 2010

Robert Doar
Commissioner
Human Resources Administration
180 Water Street
New York, NY 10038

Dear Commissioner Doar,

We were disturbed to read yesterday that three current and former HRA employees have
been charged with stealing $8 million in food stamp benefits. This is clearly the act of
individuals intent on defrauding the program for personal gain, and they should be
prosecuted to the full extent of the law. However, it also raises serious concerns about
the ways in which HRA monitors for fraud in the food stamp system.

You are quoted in yesterday’s New York Post as saying, “we are reevaluating our
processes to be sure this unacceptable offense is prevented in the future.” We hope that
this reevaluation includes a substantial policy shift away from the use of finger imaging.

The finger imaging of food stamp applicants is currently the primary method used by
HRA to prevent fraud. This method is only useful in detecting one kind of fraud –
namely, a single applicant receiving multiple benefit cases.

That kind of potential fraud pales in comparison to incidents of government employees

falsifying cases or stores illegally giving cash in exchange for benefits. Historically, the
largest cases of fraud have involved food stamp recipients selling their benefits for a
lower cash value, to store and restaurant owners who then turn them in for
reimbursement. Because these kinds of cases – such as a $60 million scheme in 1998 –
involve lawful food stamp recipients, they are undetectable through the use of finger
imaging.

In fact, in the full history of food stamp finger imaging in New York City, there is not a
single instance in which it has been used to prosecute suspected fraud. On the contrary, it
is a harmful, destructive, and discriminatory practice that does nothing to prevent the
kind of fraud we see being prosecuted today.
To make matters worse, finger imaging needlessly stigmatizes a critical safety net for
hungry New Yorkers, deterring nearly 30,000 eligible New Yorkers from signing up.
This in turn costs our city over $54 million a year in foregone benefits that could be spent
at local stores, supporting our economy in a time of great financial insecurity. And it
quite literally takes food out of the mouths of hungry New Yorkers.

We, along with a number of our Council colleagues, have urged you on numerous
occasions to end the practice of finger imaging food stamp applicants in New York City –
one of only four localities in the country that maintain this archaic requirement. It leads
to unnecessary attention and resources focused on benefit recipients who are trying
desperately to feed their families. As was made quite apparent by recent news, our
attention and resources would be much better devoted to combating genuine instances of
large-scale fraud.

The time has come for New York City to decriminalize hunger; we look forward to
meeting with you to discuss this matter further. Please have your office contact my Chief
of Staff, Meghan K. Lynch, at 212-788-6853 or MLynch@council.nyc.gov to set
something up at your earliest convenience.

Sincerely,

Annabel Palma Albert Vann

Council Member Council Member
District18, Bronx District 36, Brooklyn

Jimmy Van Bramer Melissa Mark-Viverito

Council Member Council Member
District 26, Queens District 8, Manhattan

Brad Lander Deborah Rose

Council Member Council Member
District 39, Brooklyn District 49, Staten Island
2
Vincent J. Gentile Daniel Dromm
Council Member Council Member
District 43, Brooklyn District 25, Queens

Fernando Cabrera Helen Diane Foster

Council Member Council Member
District 14, Bronx District 16, Bronx

Letitia James Elizabeth Crowley

Council Member Council Member
District 35, Brooklyn District 30, Queens

Inez Dickens Charles Barron

Council Member Council Member
District 9, Manhattan District 42, Brooklyn

Rosie Mendez Gale Brewer

Council Member Council Member
District 2, Manhattan District 6, Manhattan

3
Jumaane D. Williams Leroy G. Comrie, Jr.
Council Member Council Member
District 45, Brooklyn District 27, Queens

James Sanders, Jr. Sarah Gonzalez

Council Member Council Member
District 31, Queens District 33, Brooklyn

Stephen Levin Maria del Carmen Arroyo

Council Member Council Member
District 33, Brooklyn District 17, Bronx

Margaret Chin Ruben Wills

Council Member Council Member
District 1, Manhattan District 28, Queens

Joel Rivera Mark Weprin

Council Member Council Member
District 15, Bronx District 23, Queens

4
Robert Jackson Karen Koslowitz
Council Member Council Member
District 7, Manhattan District 26, Queens

Ydanis Rodriguez
Council Member
District 10, Manhattan

CC: Governor-Elect Andrew Cuomo

Mayor Michael R. Bloomberg
Speaker Christine Quinn
Deputy Mayor Linda Gibbs
Executive Deputy Commissioner Elizabeth Berlin
Kathryn Dyjak, Deputy Commissioner of Legislative Affairs, HRA
Massiel Garcia, Legislative Representative, Office of Mayor