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.