$1.$ Accountability for EBT$/$FIs

The American Samoa WIC Program is accountable for the receipt and issuance of all EBT cards and ensures secure storage of unissued EBT cards.

a$.$ Separation of duties: The State Agency will separate staff duties pertaining to the following areas of responsibility:

$$ Participant certification and EBT card$/$food instrument issuance

$$ EBT card$/$FI stock control

b$.$ The Clinic staff will certify participants and issue EBT Card once it has been checked out from the EBT Card Issuance staff.

c$.$ The EBT Issuance staff will receive EBT card stock shipments and perform the physical inventory of the EBT card stock. A different staff member $($EBT Branch Manager$)$ will keep the perpetual inventory log$.$

d$.$ Exception: In the satellite clinics where only one person is staffing a clinic, separation of duties may not be possible. In this instance, all EBT cards issued for a certain day will be verified and initialed the next day by a supervisor.