The Canada Revenue Agency does something similar, where instead of TOTP they ask you to print a grid of alphanums and they ask you for combinations.
The only problem is I think they're only good for a couple months at which point you need to do verification by mailed token which is a royal pain in the ass
The only problem is I think they're only good for a couple months at which point you need to do verification by mailed token which is a royal pain in the ass