Overview
We asked DTA for the CIS Daily Reconciliation Logs for all 20 TAOs for July 14, 2022. DTA could not provide us with the logs for the Framingham and Hyannis TAOs. As a result, we determined that DTA did not always perform daily reconciliations of EBT cards as required by Section IX of DTA’s “TAO Card Issuance System (CIS) Security & Handling Procedures.”
It is important for DTA to maintain effective monitoring controls over all aspects of EBT card distribution, including the retention of daily reconciliation logs at all TAOs. If DTA does not properly retain these daily reconciliation logs, then it may increase the risk that blank EBT cards go missing or are unaccounted for, potentially leading to the misuse of DTA benefits.
Authoritative Guidance
Section IX of DTA’s “TAO Card Issuance System (CIS) Security & Handling Procedures” states,
All EBT-related documents (EBT Card Signature Cover Sheets, EBT Card Signature Sheets, CIS Safe Inventory Logs, CIS Daily Card Reconciliation Logs, Weekly Safe Inspection Logs, Emergency Card Issuance Logs, and CIS Supply Discrepancy Forms) must be retained by the TAOs for three (3) years in a secure area of the TAO. These documents must be organized in an orderly manner for easy retrievable access.
Reasons for Issue
DTA officials told us that DTA could not locate the logs for the Framingham and Hyannis TAOs for the requested date.
Recommendations
- DTA should further enhance its monitoring controls over EBT card distribution.
- DTA should retain daily reconciliation logs at all TAOs for at least three years.
- DTA should maintain all daily reconciliation logs in an orderly manner for easy, retrievable access.
Auditee’s Response
Regarding the first recommendation, DTA agrees that it is important to maintain effective monitoring controls over EBT card distribution, including but not limited to maintaining its CIS Daily Reconciliation Logs. It is unfortunate that DTA was unable to produce its CIS Daily Reconciliation Log for two of its 20 TAOs for the date requested by [the Office of the State Auditor (OSA)]. DTA will review its EBT card inventory procedures and evaluate if they can be further enhanced. However, DTA disagrees with the OSA’s conclusion that its inability to produce the CIS Daily Reconciliation Log suggests that DTA did not complete an EBT card reconciliation on the days in question, leading to potential benefit misuse.
DTA’s EBT card inventory processes are distinct from its reconciliation processes. While the name of the CIS Daily Reconciliation Log includes the word “reconciliation,” the reports are in fact EBT card inventory tracking logs used to monitor the physical inventory of blank EBT cards in each office’s possession. Reconciliation of the amounts of benefits issued to unique clients on cards is not accomplished through these logs.
The Daily Reconciliation Log is part of DTA’s EBT card inventory process and is not a relevant tool to monitor for benefit misuse. DTA monitors for benefit misuse in a variety of ways including utilizing data analytics to review transaction data to identify potentially fraudulent spending, reviewing instances of excessive EBT card replacement requests which may indicate fraud, and examining questionable addresses to which EBT cards are sent. In addition, DTA adheres to Massachusetts laws prohibiting the use of cash benefits for specific purchases and at specific locations. See [Sections 5I and 5J of Chapter 18 of the Massachusetts General Laws]. SNAP benefits can also only be redeemed at United States Department of Agriculture — Food and Nutrition Service (FNS) authorized retailers for specific approved items as outlined in [Section 274.7 of Title 7 of the Code of Federal Regulations].
Regarding the second recommendation, DTA agrees it should maintain its CIS Daily Reconciliation Logs in accordance with the Commonwealth’s records retention schedule and DTA’s applicable policies and procedures. DTA’s CIS TAO Card Issuance System Security Handling Procedures mandate that TAOs must maintain all EBT related documents, including the CIS Daily Reconciliation Logs, for a period of at least 3 years. In addition, as of May 2023, DTA implemented an additional monitoring control that requires TAOs to upload all EBT related documents, including CIS Daily Reconciliation Logs, to the Benefit Issuance team’s secure electronic shared drive. Benefit Issuance staff then review these documents weekly for accuracy and adherence to internal control procedures. If a TAO fails to submit the required documents, the Benefit Issuance team contacts them and directs them to do so.
Regarding the third recommendation, DTA agrees that it should maintain all its CIS Daily Reconciliation Logs in an orderly manner for easy access and retrieval. As already noted, the Benefit Issuance team implemented this arrangement in May of 2023 with its electronic shared drive.
Auditor’s Reply
We acknowledge DTA’s response and its agreement with the recommendations regarding the maintenance and retention of CIS Daily Reconciliation Logs. However, we maintain our finding that DTA did not produce the required logs for 2 of the 20 TAOs for the requested date and that without the production of these logs, DTA is unable to demonstrate to itself, to auditors, or to others (1) whether or not it conducted such verifications or (2) the accuracy of the verifications it conducted. This could contribute to the agency being unaware of missing cards, which could result in attempts to defraud the Commonwealth of public benefits.
While DTA stated that the missing documents do not indicate that reconciliations were not performed, we emphasize that the absence of these logs prevents us from determining whether DTA completed EBT reconciliations on the specified date. The purpose of this finding is to highlight deficiencies in inventory control documentation that may hinder DTA’s ability to demonstrate compliance or detect anomalies.
We also acknowledge that DTA employs various methods to monitor potential misuse of benefits. However, these controls do not replace the retention of CIS Daily Reconciliation Logs, which serve as a key control for managing blank EBT card inventory.
Additionally, we recognize DTA’s efforts to implement procedures to strengthen its controls over the retention of CIS Daily Reconciliation Logs to address the deficiencies identified in the audit. Based on its response, DTA is taking steps to address our concerns in this area. We will monitor progress on this matter as part of our post-audit review process in approximately six months.
| Date published: | January 30, 2026 |
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