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.


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.


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.


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.