MR #14.25: TANF EBT Use Restrictions

Illinois Department of Human Services


Obsoletes Policy Memorandum dated 02/04/14.


  • It is illegal to use the Link card to access TANF cash benefits at casinos, liquor stores, or adult entertainment establishments.  
  • Language is added to the Illinois Link brochure (WCS 9203), Form 360C and Form 360P to inform TANF customers of the prohibition.
  • Posters informing customers of the prohibition are displayed in FCRCs, and in establishments where it is illegal to access TANF.
  • Adults are issued a warning for the first infraction, then are removed from the cash assistance unit for a month for each subsequent infraction.

  1. Introduction:
  2. Customer Notification:
  3. Penalty for Accessing TANF at a Prohibited Location:
    1. First infraction:
    2. Subsequent infraction(s):
  4. Manual Changes:


Pursuant to Public Law 112-96, it is illegal to access TANF cash using an Illinois Link card at the following prohibited locations:

  • any liquor store; or
  • any casino, gambling casino, or gaming establishment; or
  • any retail establishment which provides adult-oriented entertainment in which performers disrobe or perform in an unclothed state for entertainment.

A liquor store is defined as a retail establishment which sells exclusively or primarily, intoxicating liquor. It does not include approved SNAP retailers which sell both liquor and groceries.

A business which offers gaming activities which are incidental to the primary purpose of the business, such as a restaurant which has video gaming machines, is not considered a prohibited location.

It is illegal to withdraw TANF benefits from an ATM located in one of the prohibited locations, or to use TANF benefits at a point of sale (POS) terminal located in a prohibited location.

Customer Notification:

TANF customers are informed that it is illegal to access cash benefits at prohibited locations and that they may lose their benefit if they do, through the following means:

  • CN 14.06 Important Notice About Your TANF Cash Benefit mailed to active cases in February 2014; and 
  • Language added to:
    • Illinois Link brochure (WCS 9203); and 
    • Notice of Decision on Application for Cash, Medical and/or SNAP Benefits(Form 360C); and
    • You Have Certain Responsibilities (Form 360P); and 
  • Posters located in FCRCs, and in businesses where it is illegal to access TANF benefits.

Penalty for Accessing TANF at a Prohibited Location:

First infraction:

When it is first learned that a Link card was used to get or use TANF cash at a prohibited location, remind the client of the policy, and warn them that if it happens again, the adults in the case will lose cash for a month. Document the warning in the case record.

Subsequent infraction(s):

If it is learned that TANF cash has been accessed at a prohibited location after being warned about the practice, send Notice of Change (Form 157), with response due in 10 calendar days. Compute the cash benefit amount without the adult(s). Enter the reason for the action as "Your Illinois Link card has been used to get, or use TANF at a liquor store, casino or gaming place, or a place where performers undress for adult entertainment." Use manual reference PM 03-14-00.

If the customer responds to Form 157, and is able to show good cause for accessing benefits at a prohibited location, or can disprove the finding, do not take negative action. A customer may have good cause for withdrawing cash from a prohibited location if there is no other working ATM within a reasonable distance from their home.

The customer is responsible for use of their Illinois Link card and will not avoid a penalty by claiming another person used their card at a prohibited location.  

Use regular appeal policy if the customer appeals the reduction in benefit.  

If the customer does not respond to Form 157 within 10 days, cannot disprove the finding, or does not have good cause for accessing cash at a prohibited location, take action to remove the adult(s) from the cash assistance unit for one month by coding Item 78 with "3". If the ineligible adult(s) is/are the only person(s) in the cash unit, the case will be placed in zero grant reason 3. No additional notice is required.

If otherwise eligible, add the adult back to the cash assistance unit after one month by coding Item 78 as "-".

Manual Changes:

[signed copy on file]

Michelle R.B. Saddler

Secretary, Illinois Department of Human Services