Appendices

Appendix I, EBT Reconciliation Process

Revision 17-1; Effective May 5, 2017

 

100 Introduction
110 Definition
120 State Liability
130 Coordinator
140 TF08E Report
150 Quality Assurance State Office Actions
160 Clearance of Report
200 TF-07E-1 Report
210 Clearance of Report
211 Section I
212 Section II
220 Submittal of Clearance
230 Clearance Due Dates
231 Overdue Notice
232 Final Notice
240 Related Management Reports
250 Transferred Cases
251 Location Known
252 Location Unknown
260 Prevention
300 TF-37E-1 Report
310 Clearance of Report
311 Section I
312 Section II
320 Submittal of Clearance
330 Clearance Due Dates
340 Related Management Report
350 Transferred Cases
360 Prevention
400 TF-36 Report
410 Clearance of Report
420 Case Review
430 Transferred Cases
440 Coding Error
450 Fraud Referral
451 Non-Fraud Referral
460 Reporting Case Findings
470 Submittal of Clearance
471 Amending the Clearance
480 Prevention
500 Corrective Action

 

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 II, On-Site Security Review

Revision 17-3; Effective July 1, 2017

 

On-Site Security Review

 

Appendix III, Security Procedures Format

Revision 17-3; Effective July 1, 2017

 

EBT Security Plan

Regional Security Procedures

 

Appendix IV, Reserved for Future Use

Revision 17-1; Effective May 5, 2017

 

Appendix V, AT Access Log

Revision 17-1; Effective May 5, 2017

 

AT Access Log

 

 

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.

Appendix VIII, Void/Return Log

Revision 17-1; Effective May 5, 2017

 

Void/Return Log