Security and Accountability Handbook

1000, Introduction

Revision 17-1; Effective May 5, 2017

Federal regulations require the Texas Health and Human Services (HHS) to have a security and accountability system for sensitive documents, negotiable instruments, and automation equipment used to obtain benefits from the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), and Medical programs.

1100 Purpose

Revision 17-1; Effective May 5, 2017

HHS has established computer security policy and procedures to protect its automated information resources. The Security and Accountability Handbook reinforces HHS' policies and procedures to account for and safeguard program benefits from fraud, abuse, and misuse. This handbook is to be used in conjunction with the Texas Works Handbook.

The policy and procedures outlined in this handbook are the minimum requirements for all HHS local/benefit offices to protect the sensitive documents, negotiable instruments, and automation equipment used to obtain program benefits. HHS regional management staff responsible for program benefits should evaluate the policy and procedures to decide whether more stringent requirements are necessary and appropriate to meet HHS local/benefit offices needs for security and accountability operations.

1200 Users

Revision 17-1; Effective May 5, 2017

The primary users of this handbook are HHS staff that are responsible for Electronic Benefit Transfer (EBT) operations in HHS local/benefit offices.

HHS expects all employees to:

  • accept the responsibility that comes with being a public servant charged with maintaining the public trust; and
  • make certain that program benefits are accounted for and safeguarded from fraud, abuse, and misuse.

1300 Sensitive Documents, Negotiable Instruments and Automation Equipment

Revision 17-1; Effective May 5, 2017

Sensitive documents, negotiable instruments and automation equipment used to obtain program benefits include:

  • Lone Star card;
  • PIN packet;
  • Administrative Terminal;
  • Form H1172, EBT Card, PIN and Data Entry Request; and
  • Form H1175, Authorization for Administrative Terminal Application Action.

Other items that are used to obtain program benefits but require security and accountability include

  • Form H4100, Money Receipt; and
  • Request for Lone Star Materials order form.

2000, Responsibilities

Revision 17-1; Effective May 5, 2017

The responsibilities outlined in this section ensure the security and accountability for sensitive documents, negotiable instruments and automation equipment used to obtain program benefits via the Electronic Benefit Transfer (EBT) system.

2100 Vendor

Revision 17-1; Effective May 5, 2017

The vendor is responsible for accounting and shipping inactive Lone Star cards in a secure and timely manner via carrier service to the Texas Health and Human Services (HHS) offices.

Generally, the vendor packages contain Lone Star cards with 250 cards per tray.

The vendor mails Lone Star cards in separate shipping boxes, which are numbered. For instance, five boxes will be numbered 1 of 5, 2 of 5, and so on. The vendor includes a shipping receipt in one of the boxes.

2200 State Office

Revision 17-1; Effective May 5, 2017

The EBT Program Operations Section, Lone Star Business Services, is responsible for:

  • overseeing the compliance of security and accountability operations;
  • ensuring security and accountability of the receipt, storage and disbursement of Lone Star cards, including the destruction of defective Lone Star cards;
  • ensuring the vendor is in compliance with the delivery of inactive Lone Star cards to local offices; and
  • providing technical assistance to Field Operations (FO) and the regions.

The Inspector General (IG) is responsible for investigating any suspected fraudulent activities.

FO is responsible for:

  • approving the regional security procedures and regional corrective actions to address audit findings and recommendations; and
  • monitoring the compliance of security and accountability operations.

2300 HHS Regional Director

Revision 17-1; Effective May 5, 2017

The HHS regional director (RD) ensures:

  • the region is on target for reaching the goal of zero audit findings;
  • audit findings are addressed and cleared (refer to 8000, Performance and Conduct Management);
  • regional staff are aware of the policy and procedures in this handbook, as well regional security procedures;
  • the region is in compliance with this handbook;
  • the EBT regional security officer or designee approves the order forms for supplies of Lone Star cards, including unsecured materials (card sleeves, Second Cardholder form, etc.), for local offices;
  • The local office receives and stores the inactive Lone Star cards in a secure room with a locked safe, vault, file cabinet or other secure storage, and only staff designated on the regional security plan have access to the supply.
  • The copy of the Request for Lone Star Materials order form received from local offices is reconciled with the shipping receipt in the shipment from the vendor;
  • Form H1174, Inventory of EBT Cards/PIN Packets, is completed monthly for each local office and kept on file;
  • any missing or stolen Lone Star cards are reported in a timely manner (see 4500, Missing or Stolen Lone Star Cards);
  • an investigation is initiated for any suspected fraudulent activity; and
  • activities required by audit corrective action plans are completed.

The RD may delegate all or part of these duties to the EBT regional coordinator or designee.

2400 EBT Regional Coordinator

Revision 17-1; Effective May 5, 2017

The RD appoints an EBT regional coordinator to ensure that local/benefit offices are in compliance with state office guidelines on security and accountability operations.

The EBT regional coordinator ensures:

  • regional security procedures are current based on state office guidance;
  • EBT technical assistance and consultation is provided to the local/benefit office EBT site coordinator;
  • local/benefit offices are in compliance with the regional security procedures;
  • guidelines about local/benefit office security procedures, including regional approval of those procedures, are provided to EBT site coordinators;
  • users are restricted to one EBT account, and each account is limited to one user group;
  • local/benefit office security procedures are approved, and any or all exceptions are documented;
  • regional security and accountability operations are monitored;
  • on-site security reviews are conducted in each local/benefit office at least once every three years, with the due date being no longer than the last workday of the month in the 36th month (this may be done by a designee);
  • regional responses to audit findings are submitted in a timely manner;
  • all local/benefit office requests for EBT system permissions, additions and deletions are reviewed monthly;
  • a monthly EBT system user review is conducted to ensure users are assigned an appropriate level of access, which includes monitoring the resets of EBT permissions and modifying EBT users' level of access as deemed necessary;
  • each EBT site coordinator does an assessment of the local/benefit office mail operations to ensure appropriate security measures are taken to safeguard Lone Star cards from fraud and abuse;
  • local/benefit office Request for Lone Star Materials order forms for secured and unsecured EBT materials are approved unless the responsibility is delegated to someone else as designated by the RD;
  • responsible staff designations are approved and processed for the ordering, receiving, accounting, storing and distributing of bulk and daily supplies of secured EBT materials;
  • any missing or stolen Lone Star cards, and/or EBT automation equipment are reported;
  • the RD is notified of any suspected fraudulent activity;
  • the RD is notified of any inconsistencies in separation of duties; and
  • the vendor is notified of discrepancies in supplies of secured EBT materials received by the local/benefit office.

2500 Assistant Regional Director

Revision 17-1; Effective May 5, 2017

The assistant regional director ensures:

  • regional staff are aware of the policy and procedures in this handbook, as well as regional security procedures;
  • the region is in compliance with this handbook;
  • program security and accountability operations are monitored; and
  • there is maximum feasible separation of duties.

The RD may delegate certain responsibilities to the assistant regional director.

2600 Local/Benefit Office Staff

Revision 17-1; Effective May 5, 2017

2610 HHS Supervisor

Revision 17-1; Effective May 5, 2017

The HHS supervisor ensures:

  • unit staff at all locations are aware of the policy and procedures in this handbook, as well as regional security procedures;
  • the unit is in compliance with this handbook;
  • program security and accountability operations are monitored;
  • unit staff at all locations are in compliance with B-200, Issuing BenefitsB-300, Account Maintenance; and B-400, Special Households, of the Texas Works Handbook;
  • the site coordinator is immediately notified when an employee with EBT security access needs to be delete, and the deletion is accomplished as soon as possible but no later than five workdays;
  • the site coordinator is immediately notified when an employee with EBT automation permissions changes any Texas Integrated Eligibility Redesign System (TIERS) permission; and
  • EBT documents are monitored during office visits to ensure compliance with security and accountability.

The regional director or program manager may delegate certain responsibilities to the unit supervisor at the local/benefit office where the supervisor is housed.

2620 Local/Benefit Office EBT Site Coordinator

Revision 17-1; Effective May 5, 2017

The EBT site coordinator:

  • ensures local/benefit office staff are aware and in compliance with the policy and procedures outlined in this handbook, the regional security plan and the Texas Works Handbook;
  • ensures that separation of duties for performing critical functions in EBT operations are enforced;
  • ensures that the local/benefit office security procedures are current and correct, including all security procedures that are unique to that office;
  • submits a Request for Lone Star Materials order form to the RD's designee or EBT regional coordinator to request supplies of inactive Lone Star cards, and other EBT materials;
  • ensures that inactive Lone Star cards received from the vendor are accounted for by conducting a physical count within five workdays of receipt;
  • completes and submits by fax, Form H1111, Card Order Discrepancy Verification, to the EBT regional coordinator or RD's designee if an inactive Lone Star card listed on the order form is not in the shipment received.
  • stores the office supply of inactive Lone Star cards in a secure room in a locked safe, vault, file cabinet or storage room, unless prohibited by limited office space as approved by the EBT regional coordinator;
  • maintains an inventory of inactive Lone Star cards;
  • ensures inactive Lone Star cards are issued in numerical order;
  • completes Form H1177, Transmittal and Receipt for Controlled EBT Documents, or an approved regional document when applicable;
  • ensures separate logs are maintained as stated in 4410, Logs (a regionally approved log may be used to document voided/returned Lone Star cards/PIN packets);
  • ensures Form H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log, is kept and completed correctly;
  • ensures all voided/returned Lone Star cards are entered on Form H1173 or a regionally approved log;
  • completes Form H1174, Inventory of EBT Cards, by the 10th calendar day of every month, including a physical count, to account for receipt and usage of Lone Star cards, and sends a copy to the RD or designee;
  • ensures all voided/returned Lone Star cards have their status changed immediately on the EBT system to a status other than registered;
  • reconciles daily the EBT report (EBTDS303-1) with Form H1172, EBT Card, PIN and Data Entry Request; Form H1173; Form H1175, Authorization for Administrative Terminal Application Action; and other documents as needed, including the (TIERS) inquiry, and reconciles EBT reports for weekends and holidays on the next workday;
  • ensures benefits issued through the EBT system are entered into TIERS within required time frames;
  • ensures security measures for mail operations of mailed Lone Star cards;
  • ensures keys to safes, vaults, file cabinets or storage rooms are kept in a secure location; and
  • submits the electronic EBT System Access Request form found at https://oss.txhhsc.txnet.state.tx.us/sites/eo/support/lsbs/_layouts/15/start.aspx#/SitePages/LSBS%20Forms.aspx within 10 workdays to the EBT regional coordinator or designee to add or delete EBT permission for EBT staff in the local/benefit office, including any change to the level of access. Terminated employees are reported immediately to the EBT regional coordinator.

The EBT site coordinator may delegate certain duties to other EBT staff in the local/benefit office if approved by the EBT regional coordinator. However, the EBT site coordinator is still responsible for the security and accountability of program benefits in the local/benefit office.

2630 HHS Advisor/Disposition Worker

Revision 17-1; Effective May 5, 2017

The HHS advisor/disposition worker must comply with:

2640 EBT Clerk

Revision 17-1; Effective May 5, 2017

The EBT clerk:

  • maintains awareness of the policy and procedures in this handbook, as well as regional security procedures;
  • complies with this handbook;
  • complies with regional and local/benefit office security procedures;
  • signs Form H1177, Transmittal and Receipt for Controlled EBT Documents, or a regionally approved log to acknowledge receipt of Lone Star cards;
  • issues Lone Star cards in numerical order;
  • accurately enters information on Form H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log, to record issuance of Lone Star cards;
  • ensures confidentiality for a cardholder who self-selects a PIN in the local/benefit office;
  • reviews Form H1172, EBT Card, PIN and Data Entry Request, and Form H1175, Authorization for Administrative Terminal Application Action, for accuracy and completeness before issuing a Lone Star card;
  • ensures Form H1172 is signed and dated within three workdays of the request date (the request date is day zero);
  • signs off the EBT system and secures the daily supply of Lone Star cards when leaving the work area and at the end of each workday;
  • immediately notifies the EBT site coordinator of missing Lone Star cards or other discrepancies;
  • logs and changes the status of returned Lone Star cards on the EBT system to a status other than registered in a timely manner; and
  • transfers daily supply of cards to other approved EBT issuance staff when on break, lunch, leave, or any time other EBT staff will be issuing from the daily supply.

Note: EBT clerks cannot issue a Lone Star card to themselves or a direct relative (spouse, child, parent or sibling) without prior approval from the EBT regional coordinator.

2650 Program Managers

Revision 17-1; Effective May 5, 2017

The HHS program manager (PM) ensures:

  • timely compliance with EBT audit findings and corrective action plans;
  • timely submission of Form H1174, Inventory of EBT Cards for their offices;
  • staff are aware of the policy and procedures in this handbook, and the Texas Works Handbook, as well as regional security procedures; and
  • program security and accountability operations are monitored.

3000, Separation of Duties

Revision 17-1; Effective May 5, 2017

It is necessary to separate duties for performing critical functions in Electronic Benefit Transfer (EBT) operations to ensure that program benefits are not vulnerable to employee fraud or tampering.

3100 Lone Star Cards

Revision 17-1; Effective May 5, 2017

If possible separate duties of local/benefit office staff for the following activities:

  • ordering;
  • receiving;
  • storing; and
  • issuing and accounting.

To achieve separation of duties in these areas use the following procedures.

Ordering

The site coordinator or designee is responsible for ordering secure and non-secure items for the local/benefit office.

The site coordinator or backup may not delegate the ordering of supplies to other EBT staff in the office.

EBT clerks must not order Lone Star cards.

EBT staff must send all EBT orders to the EBT regional coordinator or designee for approval.

Receiving

The person(s) in the local/benefit office responsible for ordering the Lone Star cards may receive the items, but must not be solely responsible for accounting for the materials. A second party must be involved in counting the received cards. The second party must sign the invoice packing slip. Once the local/benefit office receives the supplies, they are stored securely in the local/benefit office bulk supply area.

Note: The second party does not have to be named in the local/benefit office security procedures.

Storing

Cards must be stored according to 4300, Storing.

An EBT clerk must not maintain the bulk supply.

Issuing and Accounting

There must be separation of duties in issuing and accounting for Lone Star cards. The person who issues the cards to the client must not be the person responsible for daily and monthly reconciliation. The EBT clerk must not:

  • reconcile the daily administrative terminal (EBTDS303-1) report;
  • perform monthly reconciliation; or
  • complete Form H1174, Inventory of EBT Cards/PIN Packets.

There may be instances when the site coordinator or backup site coordinator must issue a Lone Star Card to a client. When this occurs, the site coordinator must not perform the daily reconciliation for that particular day. However, the site coordinator is still responsible for monthly reconciliation.

Follow 4400, Issuing and Accounting, when issuing and accounting for Lone Star cards.

Regional management may require additional procedures to ensure that separation of duties is accomplished.

When separation of duties is not possible, staff must document the exception in the local/benefit office security procedures. The EBT regional coordinator must approve exceptions. See 4200, Receiving.

3200 Compatible Permissions

Revision 17-1; Effective May 5, 2017

The guiding principle of EBT security is separation of duties to the maximum extent possible in the local/benefit office.

  • EBT clerks and EBT site coordinators cannot have benefit issuance permissions in TIERS.
  • Texas Works advisors cannot have clerk permissions in EBT. Advisors can have inquiry only or split/merge access.

4000, Security and Control of Lone Star Cards or PIN Packets

Revision 18-1; Effective December 19, 2018

Procedures to enhance security and control of inactive Lone Star cards in local/benefit office operations are as follows.

4100 Ordering

Revision 17-1; Effective May 5, 2017

The Electronics Benefits Transfer site coordinator or backup orders EBT supplies of Lone Star cards.

The EBT regional coordinator determines the maximum number of Lone Star cards an individual office may have on hand. The EBT site coordinator immediately updates the local/benefit office security procedures to reflect changes in the allowable bulk supply and sends a copy of the updated procedures to the EBT regional coordinator.

4200 Receiving

Revision 17-1; Effective May 5, 2017

Follow established regional/local/benefit office procedures for accepting the orders of Lone Star cards and securing the orders if designated EBT staff are not available to perform the count.

After receipt, handle the packages of vault Lone Star cards as follows:

  • Designated EBT staff must open the packages of Lone Star cards and physically count the cards.

Note: Two people must be involved in this process unless specifically approved by the EBT regional coordinator in writing. The second party does not have to be assigned an EBT position or listed in the local/benefit office security procedures.

  • Repackage the Lone Star cards, seal with heavy tape, and mark the outside with the beginning and ending cards/numbers.
  • Sign and send a copy of the Request for Lone Star Materials order form/packing slip to the EBT regional coordinator or designee within five workdays. The second party assisting with the count must also sign the packing slip.

Option

Staff may:

  • log the personal account numbers (PAN) for the Lone Star cards using Form H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log;
  • repackage in increments of 25 in separate envelopes; and
  • seal the envelopes with heavy tape.

Examine all boxes of inactive Lone Star cards for any signs of tampering.

If an inactive Lone Star card listed on the order form (request for Lone Star Materials) is not in the shipment received or any other discrepancy exists, the EBT site coordinator or backup person:

  • documents the discrepancy;
  • completes Form H1111, Card Order Discrepancy Verification; and
  • provides a copy by fax to the EBT regional coordinator.

The EBT regional coordinator:

4300 Storing

Revision 17-1; Effective May 5, 2017

Store the bulk supply of inactive Lone Star cards in secure rooms in a locked safe, vault, file cabinet or storage room.

Allow only staff designated on the local office security plan to have access to the bulk supply. Keep keys to safes, vaults, file cabinets or storage rooms in a secure place.

4310 Bulk Supply Maximum

Revision 17-1; Effective May 5, 2017

The EBT regional coordinator will determine the maximum number of Lone Star cards that a local/benefit office may have in bulk supply.

4320 Daily Supply

Revision 17-1; Effective May 5, 2017

The daily supply is a limited amount of Lone Star cards from the bulk supply that is given to the EBT clerk to use during the work day. When providing the daily supply to the EBT clerk and/or anytime cards are transferred from one EBT clerk to another, account for the cards on Form H1177, Transmittal and Receipt for Controlled EBT Documents.

EBT clerks must keep the Lone Star cards in a locked file cabinet or desk drawer whenever they leave their workstations. Anytime another EBT staff person will be issuing a card from the daily supply the cards must be transferred.

Note: The EBT regional coordinator must approve any exceptions to the daily supply procedures through the process of approval for regional office procedures and/or approval of local/benefit office security procedures.

4400 Issuing and Accounting

Revision 17-1; Effective May 5, 2017

The policy and procedures for issuing and accounting for Lone Star cards are found in:

4410 Logs

Revision 17-1; Effective May 5, 2017

To enhance accountability of Lone Star cards keep:

  • Form H1173EBT Card Issuance and PIN Self-Selection Issuance Log, for Lone Star cards; and
  • a log or Form H1173 for returned/voided Lone Star cards/PIN packets.

4420 Returned and Voided Lone Star Cards and PIN Packets

Revision 17-1; Effective May 5, 2017

Local/benefit offices log a returned or defective Lone Star card or compromised PIN packet on the void/return log.

The EBT site coordinator ensures:

  • the card is immediately deactivated on the EBT system and cut in half,
  • compromised PIN packets are immediately torn in half, and
  • both are disposed of before a witness.

4430 Mailing Lone Star Cards

Revision 17-1; Effective May 5, 2017

In most cases, Lone Star cards should be mailed by the vendor using "Issue Replacement card only" and selecting the "Send by mail" check box in the EBT AT.

Note: Vendor-mailed cards do not apply to the procedures listed below.

Because mailing a Lone Star card is a risk, local/benefit offices must justify mailing in accordance with B-230, Electronic Benefit Transfer (EBT), of the Texas Works Handbook.

Local/benefit offices must secure the cards until the mail is picked up or delivered to the post office.

Log the mailed Lone Star cards on Form H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log, or a regionally approved mail log, if required by regional management.

Local/benefit office mailing procedures must ensure security and accountability of mailed Lone Star cards. All PIN packets are mailed by vendor by selecting send by mail check box in the EBT AT.

4500 Missing or Stolen Lone Star Cards

Revision 17-1; Effective May 5, 2017

If local/benefit office EBT staff find that a vault Lone Star card is missing during the accounting process, the EBT site coordinator must immediately notify the EBT regional coordinator.

The EBT regional coordinator reports any discrepancy, including any problem with the quality of the Lone Star cards, to EBT Program Operations via email.

If it is determined that Lone Star cards were stolen, follow these procedures:

  • the EBT site coordinator must immediately notify the EBT regional coordinator of any missing or stolen inactive Lone Star card that was accounted for upon receipt and stored; and
  • the EBT regional coordinator reports the loss immediately to EBT Program Operations by telephone or email.

Within 24 hours after the initial report, the EBT regional coordinator sends a follow-up memorandum to EBT Program Operations describing the incident and steps taken to prevent future occurrences. Send copies of the memo to appropriate regional management staff and, if deemed necessary, to the field investigations unit supervisor.

If the region later finds the missing or stolen Lone Star card, the EBT regional coordinator notifies appropriate regional and state office staff by memorandum.

If EBT Program Operations finds that a card has been used, EBT Program Operations deactivates the card and notifies the EBT regional coordinator, the Inspector General (IG) and Eligibility Services – Field staff.

The EBT regional coordinator explores the validity of a case record associated with the used Lone Star card. If the use is valid, the EBT regional coordinator notifies EBT Program Operations and appropriate regional management staff by memorandum.

If the EBT regional coordinator suspects criminal misconduct, the EBT regional coordinator notifies the RD regarding the fraudulent activity.

4600 Disaster Electronic Benefit Transfer (EBT) Card Reserve

Revision 18-1; Effective December 19, 2018

The EBT card reserve must be maintained in a secure storage location with limited access as further described below. Inventory control and records through point of issuance must be maintained along with periodic third-party review and validation of inventory.

Secure Storage and Limited Access

Reserve EBT cards will be secured in a limited-access space. The EBT cards will be sealed in sleeves containing 250 cards each and will be stored in locked file cabinets. The locked file cabinets will be secured with a serialized, tamper-evident seal signed by the regional EBT coordinator. Policy and procedures for secure storage are found in 4300, Storing.

Inventory and Point of Issuance Controls

The inventory record for each file cabinet will include the EBT card numbers and the associated seal serial number. The regional EBT coordinator and a second individual included on the EBT Security Plan will verify the signature, integrity and serial number of the tamper-evident seals on a monthly basis.

In the event of a disaster where Disaster Supplemental Nutrition Assistance Program (D-SNAP) has been authorized, Eligibility Operations will utilize the reserve EBT cards before leveraging the vendor’s reserve supply. Cards distributed for D-SNAP use will be accounted for using Form H1177, Transmittal and Receipt for Controlled EBT Documents.

Third-Party Periodic Review

Annually, a group of individuals on the EBT Security Plan will remove the seals, conduct functional testing on a sample of the EBT cards, complete a detailed inventory, and reseal the card sleeves and file cabinets.

5000, EBT System

Revision 18-1; Effective December 19, 2018

Texas Health and Human Services (HHS) staff with security access use a Web-based application to log in to the administrative terminal (AT) at http://www.ebtedge.com/gov/portal/PortalHome.do to issue and replace Lone Star cards and personal identification number (PIN) packets. Staff also use the Electronic Benefit Transfer (EBT) system to perform such functions as inquiry, account transaction update to the vendor database and, in certain very restricted situations, priority Supplemental Nutrition Assistance Program (SNAP) benefit authorization.

5100 Security Access

Revision 17-1; Effective May 5, 2017

Field staff designated to have access to the EBT system are:

  • Regional Office:
    • EBT regional coordinator
    • Backup staff

Note: The regional director (RD) appoints the EBT regional coordinator and notifies EBT Program Operations of the appointment within 10 workdays.

  • Local Office:
    • EBT site coordinator
    • EBT clerk
    • Backup persons

Responsible staff must complete and submit the electronic local/benefit office EBT System User Access Request form found on the EBT Program Operations website at https://oss.txhhsc.txnet.state.tx.us/sites/eo/support/lsbs/_layouts/15/start.aspx#/SitePages/LSBS%20Forms.aspx within 10 workdays to the EBT regional coordinator or designee to request the:

  • addition of newly assigned staff to an EBT position,
  • deletion of EBT staff vacating an EBT position, or
  • modification of the level of access for EBT staff changing EBT positions.

Note: EBT user access is limited to only one user group. Terminated employees are reported immediately to the EBT regional coordinator.

The EBT regional coordinator or designee keeps the EBT system access permission request for three years after the EBT staff person vacates the EBT position.

The EBT site coordinator updates the local/benefit office security procedures to reflect changes in EBT staff.

5200 Benefit Entry Restriction

Revision 18-1; Effective December 19, 2018

EBT staff may be required to issue benefits via the EBT Administrative Terminal (AT) system under certain very restricted situations. If TIERS is unavailable for an extended period, Field Operations (FO) requests Lone Star Business Services temporarily activate benefit issuance permissions for EBT staff and notifies EBT regional coordinators to begin issuing priority SNAP benefits via the EBT AT. Form H1000-A, Notice of Application (NOA) numbers are provided to EBT regional coordinators by FO and are required in the EBT AT to issue benefits.

5300 EBT Administrative Terminal Report

Revision 17-2; Effective May 19, 2017

Each day, the EBT site coordinator or backup staff must reconcile the administrative terminal report (EBTDS303-1) with Form H1172, EBT Card, PIN and Data Entry Request; Form H1173, EBT Card Issuance and PIN Self-Selection/Vendor Mail; Form H1175, Authorization for Administrative Terminal Application Action; and other appropriate documents, and perform inquiry on TIERS to confirm data entries. This includes the reconciliation of EBT system reports for weekends and holidays that are reconciled on the next workday.

Note: Form H1173 is not required for reconciliation of vendor-mailed cards.

The Client Status column on the EBTDS303-1 will contain one of the following values to indicate that activity listed is part of a series of events resulting from a single action taken by the user.

Definitions for this activity:

Split: This activity cannot be performed by local office staff, please contact your EBT Regional Coordinator and provide them with the Form H1175 when two EDG’s connected to the same Lone Star card need to be split from each other due to an error by the agency. This action is performed from the Partial Match cases and will display on the EBTDS303-1 Report as a split.

Merge: This activity is performed by the EBT Site Coordinator using the Form H1175 when two existing EDG’s need to be attached to the same Lone Star card.  This action is performed from the Partial Match cases and will display on the EBTDS303-1 Report as a merge.

Split/Merge: This activity is performed by the EBT clerk using the Form H1172 when a new EDG is added to an existing EDG. This action is performed on the Case/Client List by selecting “Add Case” to attach two EDG’s to the same card. This action will display on the EBTDS303-1 Report as a split/merge.

The EBT site coordinator or backup staff must sign or initial and date the EBT system report to validate reconciliation. Staff may use a reconciliation form to document the reconciliation of the EBT system report. Retain EBT reports for three years from the date of reconciliation.

Note: Review and document EBT reports from regional administrative offices weekly to ensure that unauthorized activities have not occurred.

Regional security procedures must identify the person responsible for ensuring that EBT system reconciliations are performed daily.

When an on-site security review is conducted, EBT reports for all local/benefit offices must be checked to ensure that no unauthorized activity occurred. The EBT regional coordinator must periodically review the reconciliation reports for administrative offices.

5400 Physical Security

Revision 17-1; Effective May 5, 2017

The local/benefit office EBT staff must ensure physical security of the EBT system, including data security. Staff must ensure EBT computers are placed so that individuals passing by cannot view the monitor screen.

5500 EBT Archive

Revision 17-1; Effective May 5, 2017

The EBT Archive stores benefit issuance and transaction detail for SNAP and TANF.

Staff authorized to have access to the EBT Archive are:

  • employees approved by Inspector General management;
  • state office employees approved by Field Operations (FO) or EBT Operations,
  • EBT regional coordinators approved by FO; and
  • Food and Nutrition Services (FNS) designated employees approved by FNS management and HHS.

6000, Retention of Forms

Revision 17-1; Effective May 5, 2017

6100 Retention

Revision 17-1; Effective May 5, 2017

Retain copies of Form H1172, EBT Card, PIN and Data Entry Request, and Form H1175, Authorization for Administrative Terminal Application Action, that are filed in the case record according to the retention period of the program.

  • Supplemental Nutrition Assistance Program (SNAP) – three years from the month the form was originated.
  • TANF – four years from the month the form was originated.

Retain copies of:

  • Form H1172, EBT Card, PIN and Data Entry Request;
  • Form H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log;
  • Form H1174, Inventory of EBT Cards/PIN Packets;
  • Form H1175, Authorization for Administrative Terminal Application Action;
  • Form H1177, Transmittal and Receipt for Controlled EBT Documents; and
  • the void/return log that is filed in an administrative record by local EBT issuance staff for three years from the date of signature.

Note: Retain Form H1177 or the regional log used for the daily transfer of Lone Star cards at least until the monthly Form H1174 is completed.

Retain the local/benefit office and regional office Administrative Terminal (EBTDS303-1 System Report) for three years from the date of reconciliation.

Retain the documentation on the weekly review of EBT reports from regional administrative offices for one year.

Retain EBT user request forms for three years from the date the EBT user leaves the EBT position.

6200 Archival and Destruction of EBT Records

Revision 17-1; Effective May 5, 2017

EBT records are stored at the HHS contracted records center for three years. The EBT site coordinator must  
contact the EBT regional coordinator or designee for information or instructions before EBT records are  
archived.

EBT records are those "administrative" records (that is, EBT security and accountability documentation)  
that local/benefit office EBT issuance staff keep, including regional and other administrative (non-delivery)  
office EBT records.

Store EBT records that are older than two years for a complete state fiscal year.

EBT records that were audited but less than three years old may also be stored for a complete state fiscal  
year.

Retain records at the local/benefit or regional office if an investigation or audit closure is pending.

Title acronym: SAH

7000, Region, Local and Benefit Office

Revision 17-1; Effective May 5, 2017

In addition to the policy and procedures outlined in this handbook and in the Texas Works Handbook, each region is responsible for maintaining regional and local/benefit office security procedures, such as regional management requirements, exceptions and clarifications. Procedures may vary between local/benefit offices within the region.

Each local/benefit office must maintain a copy of:

  • the regional security procedures, and
  • the local/benefit office security procedures.

7100 Content

Revision 17-1; Effective May 5, 2017

As determined by regional management, the content of the regional and local/benefit office security procedures should be more stringent than those found in this handbook or provide clarification on who, when, where, what and how resources are accounted for and safeguarded from fraud, abuse and misuse. The word "resources" refers to sensitive documents, negotiable instruments and automation equipment.

7110 Regional Security Procedures

Revision 17-1; Effective May 5, 2017

The regional security procedures should be standard operating procedures applicable to all local/benefit offices in the region (unless otherwise noted in regional security procedures). These procedures are those not already identified in this handbook and the Texas Works Handbook. Include the 9300, Sample Memorandum Regarding Authorization Signatures for Approving Lone Star Materials, and the current listing of regional staff with EBT user security permissions in the security procedures.

7120 Local/Benefit Office Security Procedures

Revision 17-1; Effective May 5, 2017

The local/benefit office security procedures should be standard operating procedures only applicable to that local/benefit office or similar unit (for example, hospital-based units). Include the current listing of local/benefit office staff with EBT system access.

7200 Approval

Revision 17-1; Effective May 5, 2017

The regional director electronically submits the EBT regional security procedures to EBT Program Operations with a copy to Eligibility Services – Field staff. The EBT regional coordinator is responsible for review and approval of the regional security procedures within 30 calendar days of any changes.

7300 Revisions

Revision 17-1; Effective May 5, 2017

Each region is responsible for revising their regional and local/benefit office security procedures as changes occur. The EBT regional coordinator:

  • revises only the page(s) with the change(s),
  • notes the date of the revision on the revised page(s), and
  • submits a copy of each revised page of the regional security procedures to EBT Program Operations and Eligibility Services – Field if there are changes to the procedures.

8000, Performance and Conduct Management

Revision 17-1; Effective May 5, 2017

Refer to Chapter 10 of the Human Services Manual, Performance and Conduct Management, for more information about management evaluation reviews.

8100 Security Reviews

Revision 17-1; Effective May 5, 2017

The Electronic Benefit Transfer (EBT) regional coordinator or RD's designee must:

  • conduct an on-site security review on each local/benefit office at least once every three years, with the due date being no later than the last workday of the month in the 36th month; and
  • conduct a follow-up security review (through either a desk review or on-site review) of local/benefit offices with corrective action plans to ensure compliance with security and accountability operations.

The RD may increase the frequency of security reviews as deemed necessary. Also, the RD may direct a security review before an employee vacates the position of EBT site coordinator so that deficiencies may be corrected before the newly assigned EBT site coordinator becomes responsible for the security and accountability operations in the local/benefit office.

The EBT regional coordinator or RD's designee uses the instrument for on-site security reviews in Appendix II, On-Site Security Review. The areas of concern listed on the instrument are the minimum requirements for the on-site security review. However, regional management may include other areas of concern.

9000, Acronyms and References

Revision 17-1; Effective May 5, 2017

9100 Acronyms

Revision 17-1; Effective May 5, 2017

AcronymDefinition
ATAdministrative Terminal
CAPCorrective Action Plan
EBTElectronic Benefit Transfer
ERCEBT Regional Coordinator
FNSFood and Nutrition Services
FOField Operations
HHSTexas Health and Human Services
HHSCNHealth and Human Services Consolidated Network
IGInspector General
LSBSLone Star Business Services
PANPersonal Account Number
PCNPacket Control Number
PINPersonal Identification Number
PMProgram Manager (Texas Works)
RDRegional Director (Texas Works)
QASOQuality Assurance State Office
SNAPSupplemental Nutrition Assistance Program
TANFTemporary Assistance for Needy Families
TIERSTexas Integrated Eligibility Redesign System

9200 References

Revision 17-1; Effective May 5, 2017

The following handbooks should be used in conjunction with this handbook:

9300 Sample Memorandum Regarding Authorization Signatures for Approving Lone Star Materials

Revision 17-1; Effective May 5, 2017

Sample Memorandum (Word)

Appendix I, EBT Reconciliation Process

Revision 17-1; Effective May 5, 2017

100 Introduction

The reconciliation process compares Electronic Benefit Transfer (EBT) system authorized benefits with the benefit issuance records on the Texas Integrated Eligibility Redesign System (TIERS) database. Issued benefits are reconciled daily with a weekly process to update the benefit issuance records on TIERS for any late reporting or correction of issued benefits. Completion of the process for an issuance month occurs six days after the end of that issuance month.

110 Definition

The reconciliation process:

  • confirms whether or not an issued benefit is authorized, and
  • identifies authorized benefits that do not match TIERS benefit issuance records.

Mismatches occur when:

  • an authorized amount differs from the amount on the TIERS benefit issuance record;
  • there is no case or benefit issuance record established on TIERS for the authorized benefit; or
  • there is more than one Supplemental Nutrition Assistance Program (SNAP) benefit authorized for the same month, which indicates a potential problem.

TIERS generates the following exception reports to record mismatches:

  • TF-07E-1, EBT Reconciliation Exception Report
  • TF-37E-1, EBT Reconciliation Exception
  • TF-36, More Than One SNAP Benefit Authorized
  • TF-08E, SNAP EBT Balancing Worksheet

120 State Liability

Federal regulations require that the state reimburse the federal government for the dollar amount of any:

  • unreconciled authorized benefits, and
  • overissuance when:
    • an authorized benefit duplicates a valid benefit issuance;
    • both benefits are accessed; and
    • the Texas Health and Human Services (HHS) cannot process an intentional program violation because of the failure to secure Form H1855, Affidavit for Non-Receipt or Destroyed Food Stamp Benefits, when the duplicate benefit was issued.

These dollar amounts are defined as state liabilities. State liabilities, including recovery monies, are paid with state funds. Consequently, they impact HHS' administrative budget.

HHS reports state liabilities to the federal government 90 days after the issuance month. If after the 90th day field staff are able to clear any reported state liabilities, the federal government reimburses HHS for the cleared dollar amount.

130 Coordinator

The Electronic Benefit Transfer (EBT) program operations financial manager (Mail Code 2098) is the state office coordinator for clearances of EBT reconciliation exceptions.

The EBT regional coordinator (ERC) assists local/benefit office staff with the EBT reconciliation clearance process. Regional management may implement regional procedures in excess of those documented in this section in an effort to reduce state liabilities at the regional level.

140 TF08E Report

The TF08E, Food Benefit/SNAP EBT Balancing Worksheet, identifies administrative terminal (AT) issuances that do not match TIERS certifications. TIERS issues the report weekly and monthly for the prior month. The TF report is obtained from TIERS reports online.

150 Quality Assurance State Office Actions

After obtaining the report, Quality Assurance State Office (QASO) performs inquiry on the TIERS and AT systems to determine the validity of each exception. Valid exceptions are those containing:

  • AT issuances with unmatched SNAP certifications in TIERS,
  • AT issuances when the AT amount is greater than the TIERS, or
  • AT issuances where no case certification exists on TIERS.

AT issuances with unmatched SNAP certifications, or where the AT amount is greater than the TIERS amount, generate TF-07E-1, EBT Reconciliation Exception Report. AT issuances where no case certification exists on either system generate TF-37E-1, EBT Reconciliation Exception.

160 Clearance of Report

QASO staff must perform data entry in TIERS, to post the matching benefit to the SNAP case for all valid exceptions. QASO contacts Production Control (TIERS) to remove all invalid exceptions from TF-08E.

After data entry is completed, TF-07E-1 and TF-37E-1 forms are produced. TF-07E-1 and TF-37E-1 forms are accessed online the day after data entry is performed.

200 TF-07E-1 Report

TF-07E-1 identifies EBT authorized benefits that are not reconciled. EBT authorized benefits will not reconcile when field staff:

  • fail to report the authorized benefit,
  • report the benefit untimely (after state office posting),
  • authorize the incorrect amount,
  • authorize the amount to an incorrect case, or
  • fail to report the certification period.

TF-07E-1 is organized in memorandum format to provide an efficient method for:

  • state office to report the exception, and
  • field staff to clear the exception.

The top portion of the report contains case information for the unreconciled authorized benefit. The bottom portion allows room for field clearance, including:

  • the reason for the reconciliation exception,
  • action taken on the overpayment or underpayment, if appropriate, and
  • identification of the person clearing the report.

The TF-07E-1 report is a two-part form sorted by unit. QASO sends the reports to the regional coordinator. The regional coordinator distributes the reports to unit supervisors. Unit supervisors forward the reports to responsible staff for clearance.

Note: Regions may use different distribution procedures for TF-07E-1 reports.

210 Clearance of Report

Sections I and II of TF-07E-1 are completed to satisfy clearance.

211 Section I

For incorrectly reported authorized benefits (i.e., the administrative terminal authorized dollar amount does not equal the benefits issued in the TIERS reported dollar amount), staff:

  • check the Authorized The Wrong Amount On Administrative Terminal option on TF-07E-1, or
  • explain the discrepancy under Additional Comments.

For never reported authorized benefits (i.e., the administrative terminal authorized dollar amount equals a dollar value, but the TIERS reported dollar amount equals zero), staff check one of the following options:

  • Reported Benefit After State Office Posted It,
  • Authorized EBT Amount To Wrong Case, or
  • explain what happened under Additional Comments.

For authorized benefits without a certification period, staff:

  • check Failed To Report Certification Period on the exception report, and
  • ensure the certification period is entered in TIERS.

Note: A failed-to-report certification period sometimes occurs in combination with one of the other reconciliation exception reasons.

212 Section II

Staff complete this section to indicate whether the amount of the authorized benefits was:

  • correct, or
  • incorrect.

Normally, correct is checked when the reason for the reconciliation exception is one of the following:

  • Failed To Report The Benefit via TIERS,
  • Reported Benefit After State Office Posted It, or
  • Authorized EBT Amount To Wrong Case.

Normally, incorrect is checked when the reason for the reconciliation exception is Authorized The Wrong Amount On EBT.

When the authorized benefit is incorrect, staff complete one of the following:

  • Incorrect, Dollar Overpayment, or
  • Incorrect, Dollar Underpayment.

When Incorrect, Dollar Overpayment is completed, staff must also enter the following information on TF-07E-1 for the clearance to be considered complete:

  • amount of overpayment, and
  • date/method taken to recover the overpayment.

When Incorrect, Dollar Underpayment is completed, staff must also enter the following information on TF-07E-1 for the clearance to be considered complete:

  • amount of underpayment, and
  • date benefits are restored/offset.

220 Submittal of Clearance

After completing TF-07E-1, responsible staff:

  • return the original to QASO, Mail Code 2052, and
  • submit a copy into the eligibility system.

Responsible staff should coordinate clearance with the unit supervisor to ensure proper documentation of clearance.

QASO:

  • handles completed TF-07E-1 reports,
  • returns incomplete TF-07E-1 reports to appropriate staff, or
  • calls staff to finish incomplete TF-07E-1 reports.

If a certification period for TF-07E-1 is required, responsible staff must process a record of case action in TIERS.

230 Clearance Due Dates

TIERS automatically enters the due date on the original TF-07E-1. The due date is 30 workdays after the report run date.

231 Overdue Notice

After the original due date, QASO:

  • generates TF-07E-1 reports on delinquent exceptions,
  • sends the generated reports to the regional coordinator, and
  • notifies the state office coordinator of the delinquencies.

The due date for the overdue notice is 30 days after the report run date.

Note: The agency reports the dollar amount of these delinquencies as a state liability to the federal government until the TF-07E-1 reports are cleared.

The EBT regional coordinator (ERC) checks the reports against the delinquent exception reports file and discards any that have since been cleared before forwarding the reports to unit supervisors for clearance.

Note: Regions may use different distribution procedures for the overdue notices.

232 Final Notice

If there are still uncleared TF-07E-1 reports after the due date of the overdue notice, QASO notifies the state office coordinator. The state office coordinator notifies the EBT regional coordinator about the uncleared TF-07E-1 reports with a copy to the regional director (RD).

If the ERC determines that all means to clear the delinquent reports have been exhausted, the ERC notifies the state office coordinator with a copy to the RD.

The state office coordinator then:

  • obtains a copy of TF-07E-1 from QASO, and
  • sends Fiscal Management Services a memo indicating the final amount of state liability.

A copy of the memo is sent to regional management.

240 Related Management Reports

The supervisor receives TF-07E-2, EBT Reconciliation Exceptions Unit Summary, which lists the cases in the unit for which TF-07E-1 was generated. TF-07E-2 also includes the unit total. The report is intended to be a management tool for supervisors to monitor clearance of TF-07E-1 reports.

The RD receives TF-07E, EBT Reconciliation Exceptions Regional Summary, which lists cases by unit in the region for which TF-07E-1 was generated. TF-07E includes unit totals as well as a regional total. The RD forwards TF-07E to the ERC to monitor unit clearances.

250 Transferred Cases

Responsible staff use the following procedures to clear TF-07E-1 reports on transferred cases.

251 Location Known

When responsible staff know the location of the transferred case, they:

  • annotate the location, if known, on TF-07E-1;
  • attach a copy of the transfer card to TF-07E-1; and
  • send both to the unit supervisor.

Note: Local/benefit office staff receiving TF-07E-1 reports for cases that have been transferred within the region may clear TF-07E-1 reports instead of forwarding them to the other local/benefit office. Regional management may require this option.

The supervisor:

  • notes the new case location on TF-07E-2;
  • redlines the case on TF-07E-2;
  • forwards the annotated TF-07E-1 for clearance; and
  • notifies the regional coordinator of the action.

Note: Regions may use different distribution and/or notification procedures.

After receiving the annotated TF-07E-1, QASO:

  • updates the TF-07E MAPPER file with the new mail code, and
  • forwards the updated TF-07E-1 to the new mail code.

Note: State office sends overdue notices to the appropriate gaining regional staff.

252 Location Unknown

When responsible regional staff do not know the location of the transferred case after a thorough regional search, they:

  • annotate the reason (for example, unable to locate case record) on TF-07E-1, and
  • send TF-07E-1 to the supervisor.

The supervisor:

  • redlines the case on TF-07E-2;
  • returns TF-07E-1 to QASO; and
  • notifies the EBT regional coordinator of the action.

Note: Regions may use different distribution and/or notification procedures.

After receiving the annotated TF-07E-1, QASO researches the location of the case. If QASO locates the case, unit staff:

  • update the TF-07E MAPPER file with the new mail code, and
  • forward the updated TF-07E-1 to the new mail code.

Note: State office sends overdue notices to the appropriate gaining regional staff.

If QASO is unable to locate the case, unit staff:

  • update the TF-07E file indicating a state liability; and
  • report the amount of the uncleared TF-07E-1 to QASO.

QASO sends a memo to Fiscal Management Services reporting the amount of the uncleared TF-07E-1 to be paid as a state liability to the federal government. A copy of the memo is sent to regional management.

260 Prevention

To prevent these exception reports, staff must take the following actions:

  • HHS advisors/disposition workers must:
    • complete Part II of Form H1175, Authorization for Administrative Terminal Application Action.
  • The supervisor or designated staff person must:
    • generate the EBT report daily — EBTDS303-1 Report,
    • use it to check benefits authorized on the EBTDS303-1 Report for the previous day against the TIERS inquiry, and
    • reconcile this information on a daily basis.

If the EBT authorized benefit has not been reported on TIERS, prompt the HHS advisor/disposition worker to process the benefit issuance in TIERS by the fifth day to prevent an exception report.

Note: Do not use manual data entry on the EBT system to authorize benefits when TIERS is available unless approved. Refer to the regional security procedures regarding this topic.

300 TF-37E-1 Report

State office generates TF-37E-1, EBT Reconciliation Exception when no existing Supplemental Nutrition Assistance Program case on TIERS corresponds with the case number for which benefits are authorized on the AT. This usually occurs when field staff fail to establish the case on TIERS.

The TF-37E-1 is also a two-part form. It is an exact duplicate of TF-07E-1, except for reflecting its own report number.

QASO sends the reports to the EBT regional coordinator, who in turn distributes the reports to supervisors for clearance.

Note: Regions may use different distribution procedures for TF-37E-1 reports.

310 Clearance of Report

Responsible staff complete Sections I and II of TF-37E-1 to satisfy clearance.

311 Section I

For authorized benefits without an established TIERS case, staff:

  • check Failed To Report The Certification Period, and
  • establish the case on TIERS.

Note: If an authorized EBT amount was posted to the wrong case, please contact your ERC for assistance in clearing the duplicate issuance.

312 Section II

Completion of this section indicates whether the amount of benefits authorized was:

  • correct, or
  • incorrect.

Normally, correct is checked for authorized benefits without an established TIERS case. However, when authorized benefits are incorrect, staff complete one of the following:

  1. Incorrect, Dollar Overpayment
  2. Incorrect, Dollar Underpayment

When number 1 is completed, staff must also enter the following on TF-37E-1 for the clearance to be considered complete:

  • amount of overpayment, and
  • date/method taken to recover the overpayment.

When number 2 is completed, staff must also enter the following on TF-37E-1 for the clearance to be considered complete:

  • amount of underpayment, and
  • date benefits are restored/offset.

320 Submittal of Clearance

After completing TF-37E-1, responsible staff:

  • send the original TF-37E-1 to QASO, Mail Code 2052; and
  • submit a copy into the eligibility.

Note: Responsible staff should coordinate clearance with the unit supervisor to ensure proper documentation of clearance.

If both documents are processed correctly, QASO considers TF-37E-1 cleared.

If TF-37E-1 is incomplete, QASO contacts field staff to complete the document.

QASO contacts the ERC requesting a certification of the case for the authorized benefit. The ERC follows up on the request with the supervisor.

If the region fails to comply with QASO's request, QASO staff notify the state office coordinator, who in turn contacts the ERC for action.

When the TIERS EDG is processed, QASO considers TF-37E-1 cleared.

330 Clearance Due Dates

Clearance due dates and procedures for TF-37E-1 are the same as those documented for TF-07E-1.

340 Related Management Report

The ERC receives TF-37E, Report of Dummy Cases, which lists the cases in the region for which TF-37E-1 was generated. TF-37E also includes the regional total. The coordinator makes a copy of TF-37E for supervisors receiving TF-37E-1 reports. The report is intended to be a management tool for ERCs and supervisors to monitor clearance of TF-37E-1 reports.

350 Transferred Cases

Since the case was never established on TIERS, responsible staff cannot clear a case listed on TF-37E by indicating "it was transferred to another region." Responsible staff contact the ERC for assistance.

360 Prevention

Staff must apply policy and procedures of the Texas Works Handbook in certifying cases before issuing benefits to prevent TF-37E-1. Since TF-37E-1 is similar to TF-07E-1, refer to the TF-07E-1 information on prevention.

400 TF-36 Report

Report TF-36, More Than One Food Benefit/SNAP Authorized, identifies cases with more than one benefit in a benefit month, which indicates a potential problem. The problem may be:

  • a coding error,
  • an over-issuance, or
  • both.

Benefits coded as supplemental or restored may appear on TF-36 if the household was authorized these benefits in a month that it was also authorized an incompatible combination of benefits, or if the supplemental or restored benefits are a part of the incompatible combination.

Types of multiple authorized benefits with potential problems appearing on TF-36 are initial-initial benefit combinations:

  • Benefit issuance type = A, E, L
  • Priority issuance type = 1, 2, 3

State office produces TF-36 reports in quadruple, sorted unit. The report also includes unit and regional summaries.

State office sends all copies of the report to the RD. The RD routes the copies to the ERC. The ERC maintains a copy of each unit's report and distributes the remaining copies to supervisors. Supervisors forward a copy of the report to appropriate staff for clearance.

Note: Regions may use different distribution procedures for TF-36 reports.

410 Clearance of Report

Responsible staff complete the following steps to satisfy clearance of the report:

  1. Review the eligibility system (Section 420).
  2. Take action (Sections 430, 440, 450, and 451).
  3. Report case findings to the ERC (Sections 460, 470, and 471).

420 Case Review

In the case review, responsible staff determine if the:

  • case was transferred;
  • correct issuance code and/or benefit month were used and/or entered on TIERS;
  • household received duplicate benefits; and
  • case contains a valid Form H1855, Affidavit for Nonreceipt or Destroyed Food Stamp Benefits.

If the case was transferred, staff follow procedures in Section 430.

If the issuance code and/or benefit month were incorrectly used and/or entered on TIERS, staff follow procedures in Section 440.

If the issuance code and benefit month were correctly used and entered on TIERS and a fraud over-issuance occurred, staff follow procedures in Section 450.

If the issuance code and benefit month were correctly used and entered on TIERS and a non-fraud over-issuance occurred, staff follow procedures in Section 451.

If the second benefit issuance is for replaced benefits, responsible staff must notify the ERC for assistance.

Note: Only state office can authorize replacement of benefits (refer to Section B-340, Replacing Benefits, of the Texas Works Handbook).

430 Transferred Cases

If the case review concludes that the case was transferred to another region, responsible staff:

  • annotate the location, if known, on their copy of the TF-36 report;
  • attach a copy of the transfer card to their copy of the TF-36 report; and
  • send both to the supervisor.

The supervisor:

  • notes the new case location on his copy of the TF-36 report,
  • redlines the case on his copy of the TF-36 report, and
  • sends a copy of the TF-36 report to the ERC.

Note: Regional management may require that the unit supervisor route the report through appropriate channels.

The ERC:

  • sends a memo to the TF-36 coordinator in the gaining region,
  • attaches a copy of the TF-36 report,
  • sends a copy of the memo to the EBT financial manager at Mail Code 2098, and
  • notes the action for the regional clearance.

The gaining region is responsible for the clearance.

440 Coding Error

If the case review concludes that the issuance code and/or benefit month were incorrectly used and/or entered on TIERS, and no overissuance occurred, responsible staff:

  • annotate the correct information on their copy of TF-36, and
  • send their copy of TF-36 to the supervisor.

The supervisor notes the action for the regional clearance.

450 Fraud Referral

For the case action to be a fraud referral:

  • the issuance code and benefit month are correctly used and entered on TIERS;
  • an over-issuance occurred; and
  • the case record contains a correctly completed Form H1855, Affidavit for Nonreceipt or Destroyed Food Stamp Benefits, including correct signature and reference to the appropriate benefit month.

Note: Refer to Form H1855 and instructions in the Forms section of the Texas Works Handbook.

Depending on regional procedures, responsible staff complete and send the referral to OIG or ERC for validation of a fraud over-issuance. If OIG or ERC determines the over-issuance is non-fraud, follow the procedures in Section 451.

451 Non-Fraud Referral

For the case action to be a non-fraud referral:

  • the issuance code and benefit month are used and entered correctly on TIERS;
  • an over-issuance occurred; and
  • there is no valid Form H1855, Affidavit for Nonreceipt or Destroyed Food Stamp Benefits, on file, or the HHS advisor/disposition worker has good reason to believe the individual did not intend to commit fraud, or the case cannot be located.

Depending on regional procedures, responsible staff process a non-fraud claim.

Note: Refer to Section B-770, Claims Collection, in the Texas Works Handbook for a listing of the various forms used in processing a non-fraud claim.

After receiving regional clearance, the EBT financial manager sends a memo to Fiscal Management Services reporting the total amount of the state liability. Copies of the memo are sent to regional management.

Note: Fiscal Management Services reports the total amount of the state liability to the federal government.

If the initial regional TF-36 clearance report had cases pending a clearance, or if new information on a reported liability case is found, an amended regional TF-36 clearance report is due.

460 Reporting Case Findings

Each region has a form on which responsible staff report case findings to the ERC. Responsible staff file a copy of the form in the case record.

Findings indicate one of the following:

  • Case is transferred to another region.
  • Second benefit issuance is correct.
  • Second benefit issuance is not a state liability.
  • Second benefit issuance is a state liability.
  • Second benefit issuance is a state liability from another region.

Note: Regional management may require that responsible staff route the findings through the channels or send a copy of the findings to regional management.

470 Submittal of Clearance

The due date for the regional clearance is 45 workdays from the run date of the TF-36 report.

Note: For any case that is not cleared by the due date, the amount of the second benefit issuance for the uncleared case is reported as a state liability.

The ERC sends a memo to EBT Program Operations (Mail Code 2033) reporting the liability cases. The list of liability cases includes the following:

  • Case number
  • Benefit number
  • Case name
  • Value of over-issuance
  • Issuance type
  • Issuance date
  • Benefit date
  • Recovery action

Information on transferred cases may be attached to the clearance memo, if desired.

After receiving regional clearances, the EBT financial manager sends a memo to Fiscal Management Services reporting the total amount of the state liability. Copies of the memo are sent to regional management.

Note: Fiscal Management Services reports the total amount of the state liability to the federal government.

If the initial regional TF-36 clearance report had cases pending a clearance, or if new information on a reported liability case is found, an amended regional TF-36 clearance report is due.

471 Amending the Clearance

When missing case records, documents (for example, Form H1855, Affidavit for Nonreceipt or Destroyed Food Stamp Benefits), or other facts are found after reporting case findings, responsible staff determine if the new information changes the previously reported liability amount.

For any change to the previously reported liability amount, responsible staff notify the EBT regional coordinator (ERC) through channels.

The ERC sends an amended regional clearance memo to the state office coordinator reflecting the:

  • adjusted liability amount, and
  • corrected liability case listings.

The EBT financial manager:

  • amends the previous clearance from the region,
  • prepares an amended state summary of the reported state liability, and
  • sends a memo to Fiscal Management Services reporting the amended state liability owed to the federal government. Copies of the amended memo are sent to regional management.

Fiscal Management Services submits an amended state liability to the federal government.

480 Prevention

Staff must apply the policy and procedures in the Texas Works Handbook when issuing initial benefits. Furthermore, having a correctly completed Form H1855, Affidavit for Nonreceipt or Destroyed Food Stamp Benefits, on file for cases being issued initial benefits can prevent state liabilities.

500 Corrective Action

EBT reconciliation liabilities are within HHS' control. Each region has responsibility for designing and implementing corrective action to prevent such liabilities. If the region requires technical assistance and support with corrective action or clearance of reconciliation exceptions, the ERC contacts the state office coordinator.

Appendix VI, Security Reviews by EBT Regional Coordinators

Revision 17-1; Effective May 5, 2017

Before the Review

Local benefit office staff must request a Health and Human Services (HHS) employee identification badge before the review and daily during the review.

During the Review

Local office staff must answer the security review questions pertaining to the review, be supportive and cooperative with the reviewer, and confer with the reviewer on potential findings.

Note: The EBT site coordinator or backup should be available for the reviewer to answer any questions or concerns on local benefit office security and accountability operations.

After the Review

The reviewer has an exit conference with the EBT site coordinator or backup (other staff may attend, if appropriate).

Review Documentation

After the exit conference, the reviewer prepares a security review report (see Appendix II, On-Site Security Review). If operations records, systems and processes are found inadequate in accounting for and safeguarding program benefits from fraud, abuse and misuse, the security review report will state a finding and a recommendation for each finding. Each finding will reference the appropriate section number of the controlling policy or regulations, including the following:

  • This handbook; and/or
  • Texas Works Handbook

Review Distribution

Within 15 days after the exit conference, the reviewer will send a report to the program manager and regional director and local office supervisor.

Review Clearance and Corrective Action Plan (CAP)

Upon receipt of the audit report, the local office initiates the region's process to develop the corrective action plan. The CAP must include:

  • the physical address of the local benefit office,
  • the time period that the audit covered, and
  • a response to each finding.

Agreement with Finding

If the local office agrees with the finding noted as a deficiency or discrepancy, corrective action to prevent it from reoccurring is described in the CAP.

Disagreement with Finding

If the office disagrees with the finding noted as a deficiency or discrepancy, the office explains in detail the basis for its disagreement.

CAP Due Date

The CAP is due within 15 workdays from the date the local office receives the report. Send the original CAP to the EBT regional coordinator, the program manager and the regional director.

Review Resolution and Closure

Upon receipt of the CAP, the EBT regional coordinator will review and approve the CAP for resolution of each finding. Closure or final approval of the CAP occurs when the resolution for each finding is reached.

If the resolution for the finding is inadequate, the EBT regional coordinator notifies the local office within 10 workdays and the region has 10 workdays to resolve the problem with the CAP.

When resolution is reached, the EBT regional coordinator confirms closure in writing to the local office. Final resolution of CAP closure is reported to the regional director and Field Operations state office.

Appendix VII, Exception List

Revision 17-1; Effective May 5, 2017

Criteria for Categorizing What Normally Would Be a Low Risk to a High Risk Audit Exception [note applicable explanation/justification]:

  1. Finding noted during the review; no corrective action plan in place.
  2. Finding noted in a prior audit; remains uncorrected.
  3. Total number of findings on a specific low risk item exceeds three. Example: Form H1172, EBT Card, PIN and Data Entry Request, was not signed by the Electronic Benefit Transfer (EBT) clerk on three separate forms.
  4. Frequency of a specific finding.
  5. Degree of inaccuracy or missing records (re: forms, logs, etc.).

High Risk

  1. There was improper or no separation of duties.
    1. Re: storing and issuing [write in brief description such as: The issuance staff also performed the administrative terminal (AT) reconciliation]. (Security and Accountability Handbook [SAH] 3100)
  2. Local office staff did not request proper identification from the auditor at the start of the audit. (SAH Appendix VI)
  3. Unauthorized staff had access to the AT and cards.
  4. There were no adequate procedures to void and /or account for voided/returned cards/PINs (SAH 4420), may add applicable description as:
    1. Designated staff did not disable (deactivate) voided/returned cards/PINs on the AT. (SAH 4420)
    2. Returned cards/PINs were not destroyed properly. (SAH 4420)
    3. Office did not maintain a void log. (SAH 4410)
    4. Responsible staff did not void and/or destroy activated cards that were not picked up at the end of the day.
  5. EBT clerk did not lock daily supply of card when they left their workstation.
  6. EBT site coordinator did not keep bulk supply of cards in secure locked file cabinets.
  7. File cabinet keys to bulk/daily supply were not secure. (SAH 2620)
  8. EBT designated staff failed to lock application/sign off the AT when they left their workstation. (SAH 5400)
  9. Site coordinator did not resolve discrepancies and/or report shortages in a timely manner. (SAH 2620, 4500)
  10. There were no adequate review/monitoring procedures in place.
    1. There was a lack of, or a weakness in, the current review procedures so discrepancies were undetected for _____months. (give a brief description of the discrepancy)
    2. EBT documents (specify document) were not properly monitored during office visits to ensure compliance with security and accountability. (SAH 2610)
  11. Reconciliation of AT reports was not occurring daily or was not performed properly. (SAH 5300), may add applicable description such as:
    1. Site coordinator did not reconcile the AT report with Forms H1172; H1173, EBT Card Issuance and PIN Self-Selection/Issuance Log; H1175, Authorization for Administrative Terminal Application Action; and other appropriate documents.
    2. Site coordinator did not reconcile AT reports for weekends and holidays.
    3. Site coordinator did not sign or date the AT report to validate reconciliation.
  12. There were no adequate procedures for mailing cards. Add applicable description such as:
    1. Cards were mailed in an active status. (SAH 2620)
    2. Cards for mailing were left in an unsecured location.
    3. Office does not log mailed cards. (SAH 4430)
  13. Cards delivered by Texas Works Advisor (TWA) staff during home visits were not properly documented.
  14. Site coordinator did not perform a physical inventory of cards monthly.
  15. Texas Health and Human Services (HHS) issuance staff compromised the security of self-selected PINs. (TWH B-236.1)
  16. The number of cards for the daily (working) supply did not conform to the Regional Security Plan (RSP) for overnight storage. (SAH 4330, RSP)

Low Risk

  1. EBT site coordinator did not issue cards to the EBT clerk in numerical order.
  2. EBT clerk did not issue cards in numerical order.
  3. EBT site coordinator did not complete or keep Forms H1177, Transmittal and Receipt for Controlled EBT Documents, or an approved regional document. (SAH 2620)
  4. EBT site coordinator did not prepare or properly complete Forms H1174, Inventory of EBT Cards.
  5. EBT clerk did not review Form H1172 and/or Form H1175 for accuracy and completeness before issuing a card/PIN packet. (SAH 2640)
  6. Local office security plan was not updated to reflect current staff and provisions. (SAH 2720), may add description such as:
    1. EBT site coordinator failed to delete AT permission for an employee [that is no longer involved with EBT issuance] [transferred] [separated from HHS]. (SAH 2620, 5100)
  7. No signed receipt for delivery of cards and no annotation that shipment was physically counted upon receipt.
  8. Form H1172 is incomplete, inaccurate or missing. (TWH — Instructions to Form H1172) (add description/specifics)
  9. Form H1173 is incomplete, inaccurate or missing. (SAH 2620, 2630 and TWH — Instructions to Form H1173) (add description/specifics)
  10. Card inventory exceeded maximum allowed per security procedures. (SAH 4320, RSP)
  11. Only one person counted card package received from the vendor. (SAH 4200)

Note: If several errors are noted on the same form, it will only be written as one finding. Other details will be mentioned under that one finding. Example: The "mailed card" box is not checked on Form H1172. Also, the person completing the form failed to date the form. This will be written up as high risk #12d. A statement will be added to the finding addressing the other issue (incomplete form). It will not be written up as both high risk finding #12d and low risk finding #8.

22-1, Appendix II Revised

Revision Notice 22-1; Effective June 3, 2022

The following change(s) were made:

SectionTitleChange
Appendix IIOn-Site Security ReviewUpdates the appendix used internally by office staff.

21-1, Appendix II Revised

Revision Notice 21-1; Effective June 25, 2021

The following change(s) were made:

Section Title Change
Appendix II On-Site Security Review Updates the appendix used internally by office staff.

18-1, Sections 4600 and 5200

Revision Notice 18-1; Effective December 19, 2018

The following change(s) were made:

Section Title Change
4600 Disaster Electronic Benefit Transfer (EBT) Card Reserve Adds a new section. The EBT card must be maintained in a secure storage location with limited access.
5200 Benefit Entry Restriction Updates the information. EBT staff may be required to issue benefits via the EBT Administrative Terminal (AT) system under certain very restricted situations.

17-3, Appendices II and III Changes

Revision Notice 17-3; Effective July 1, 2017

The following change(s) were made:

Section Title Change
Appendix II On-Site Security Review Updates chart, steps 10, 18 and 19, with revised section numbers.
Appendix III Security Procedures Format Adds information to the EBT Security Plan Chart clarifying that storage methods allow for name and signature of approving person and the regional coordinator.

Forms

ES = Spanish version available.

FormTitle 
H1111Card Order Discrepancy Verification 
H1172EBT Card, PIN and Data Entry RequestES
H1173EBT Card Issuance and PIN Self-Selection/Issuance Log 
H1174Inventory of EBT Cards/PIN Packets 
H1175Authorization for Administrative Terminal Application Action 
H1177Transmittal and Receipt for Controlled EBT Documents 
H4100Money ReceiptES