FNS and Lost SNAP Cards

A smattering of stories reporting on the Food and Nutrition Service's proposed regulation (out for public comment) permitting states to request justification for issuing a replacement SNAP (food stamp) EBT card when it's the fourth one within a year.  Here's the FNS post.

This bothers me, but probably not enough to do the research I'd need to.  I'm bothered in part by this language:

The proposed minimum threshold is based on an analysis by FNS of electronic transaction data that demonstrates a statistically significant difference when a client reaches his or her fourth replacement card, indicating that transaction activity is three times more likely to be flagged as potential trafficking, which is the exchange of benefits for cash or other consideration, compared to clients with three or fewer replacement cards.

Now I'd assume the EBT cards operate like a debit card; lose one, you notify the issuer and they put a hold on the account and you get a new card.   I can understand that some of the SNAP recipients are prone to lose their cards; while not a recipient I've trouble losing things as my senility comes on faster.  So what I would imagine happens: recipient goes to the store on Monday and uses the card.  Recipient absent-mindedly puts the card in the trash on the way out.  Recipient needs the card on Wednesday and finds it's missing.  Recipient notifies issuer.  If someone found the card and used it, then there'd be a couple days of transactions.  So I could handle issuing a replacement with no more justification than "I lost it and can't find it" and having the government cover the transaction costs..  And it'd probably be hard to differentiate between the misuse of a found card and the use of a card sold by the SNAP recipient, just by looking at the transactions.

But, from the language I quoted I'm not sure that's what's going on.

And my bottom line would be, the default position for the government should be no more forgiving than a commercial bank is.