DEPARTMENT OF ASSISTIVE AND REHABILITATIVE SERVICES INTERNAL AUDIT DIVISION EXCELLENT SERVICE EVERY CUSTOMER EVERY TIME Fiscal Year 2013 Annual Internal Audit Report October 2013 MISSION The Internal Audit Division serves as a resource dedicated to support DARS’ mission by providing independent and objective assurance and advisory services to increase agency control awareness, improve the effectiveness of risk management and governance processes, and promote continuous improvement of agency operations. 2013 Team Members Christy Alvarado, CGAP Gail Ates, CFE Jeannie Coale, CPA Angel Flores, CGAP Paul Gentry, CPA, CIA Karen Henry, CPA Lissette Nadal-Hogan, CIA, CISA, CRISC Blanca Rodriguez Internal Audit Director Karin Hill, CIA, CGAP, CRMA TO: Veronda L. Durden, Commissioner FROM: Karin Hill, Internal Audit Director SUBJECT: Fiscal Year 2013 Annual Internal Audit Report DATE: October 17, 2013 Attached for your approval is the Fiscal Year 2013 Annual Internal Audit Report from the Texas Department of Assistive and Rehabilitative Service’s (DARS) Internal Audit Division. This report is provided in accordance with the Texas Internal Auditing Act requirements for internal auditors to prepare and distribute an annual report of activities and complies with the guidelines set forth by the State Auditor’s Office. The DARS Internal Audit Division completed audit work and provided management with information and analyses to assist in initiating improvements to operations and to strengthen internal controls. In addition to audit work, DARS Internal Audit provided advice and assistance on governance, risk management, and controls, and management actively engages the Division as they continue to work toward more effective and efficient processes in the agency. DARS Internal Audit staff continues to be active in the local internal audit community through participation in the State Agency Internal Audit Forum, the Austin Chapter of the Institute of Internal Auditors, and the Information Systems Audit and Control Association. Staff also continues to attend training courses offered by the State Auditor’s Office and other local trainers as well as completing work toward professional certification. If you have any questions please contact Karin Hill, Director of Internal Audit at (512)424-4021. Partnerships for Independence A+ Internal Audit Division, 4800 N. Lamar Blvd. MC-3030, Austin, TX, 78756 DARS Annual Internal Audit Report Table of Contents Section I Compliance with House Bill 16: Posting the Internal Audit Plan, Internal Audit Annual Report, and Other Audit Information on Internet Web Site ............................................................................ 1 Section II DARS Internal Audit Plan for Fiscal Year 2013 ................................................................................. 1 Section III Consulting Services and Non-audit Services Completed ................................................................ 2 Section IV External Quality Assurance Review .................................................................................................... 4 Section V DARS Internal Audit Plan for Fiscal Year 2014 ................................................................................. 5 Section VI External Audit Services Procured in Fiscal Year 2013 ..................................................................... 6 Section VII Reporting Suspected Fraud and Abuse.............................................................................................. 7 DARS Internal Audit Division i DARS Annual Internal Audit Report Section I Compliance with House Bill 16: Posting the Internal Audit Plan, Internal Audit Annual Report, and Other Audit Information on Internet Web Site The Department of Assistive and Rehabilitative Services (DARS) has organized a section of its Internet site to include the approved audit plan and annual report for the Internal Audit Division. This can be located under “Annual Reports & Plans” in the “News & Information” section of the agency’s website. The DARS Fiscal Year 2014 Audit Plan was approved by Commissioner Durden on August 21, 2013and posted on this site on September 11, 2013. Section II DARS Internal Audit Plan for Fiscal Year 2013 Report Number 11-004 12-002 13-001 13-002 Audit/Project Title Division of Rehabilitation Services – Community Rehabilitation Programs Contract Management A Special Project on Inventory, Management, and Storage of Agency Confidential Data Division for Rehabilitation Services – Specialized Telecommunications Assistance Program Information Resources – Contract Management 13-003 Division for Blind Services – Budget Management and Monitoring of Consumer Purchases 13-101 Independent Assessment of Information Resources Audit-Related Action Plans Follow Up of DARS Internal Audit Report on Controls over the Access Termination Process 13-202 13-201 Follow Up of DARS Internal Audit Report on the Centers for Independent Living Program and HHSC OIG Report on Texas State Independent Living Centers Division for Rehabilitation Services – Comprehensive Rehabilitation Services Contract Management DARS Internal Audit Division Report Date 3/26/2013 2/22/2013 9/23/2013 In Progress Estimated Completion 11/2013 In Progress Estimated Completion 11/2013 6/19/2013 In Progress Estimated Completion 11/2013 4/12/2013 Cancelled 1 DARS Annual Internal Audit Report Section III Consulting Services and Non-audit Services Completed The DARS Internal Audit Division completed the following non-audit services during fiscal year 2013: Special Project on Inventory, Management, and Storage of Agency Confidential Data This special project was initiated in fiscal year 2012 at the request of DARS management in response to an enterprise audit and a DARS information security assessment. The objective of this project was to identify where agency confidential information is located, how it is managed and stored, and communicate risks associated with current business practices. This project was included on the Fiscal Year 2013 Audit Plan and issued as report #12-002 in February 2013. The high level observations/results were as follows: Agency staff comes in contact with, downloads, and consistently stores confidential data from the information systems to mobile devices as part of their job responsibilities. Agency procedures do not specifically provide guidance related to the security and storage of confidential data processed in stand-alone databases. The agency is improving existing controls over the management and storage of confidential data. The agency promotes the protection of confidential data within its divisions or programs, and with service providers, vendors, and contractors. Confidential data is shared with service providers that may not have a contract with the agency. Recommendations were not issued for this project. DARS management continues to work with the HHS Enterprise to address confidential data as well as to strengthen agency controls. Independent Assessment of Information Resources Audit-Related Action Plans This assessment was requested as part of an initiative of management, to ensure appropriate actions were being taken to address audit recommendations from three reports: The SAO Audit on the ReHabWorks System; the HHSC Audit of HHS Information Security; and the HHSC Audit of Proxy Server and Batch File Processing Security and Compliance, and report the results to the DARS Chief Operating Officer. DARS Internal Audit Division 2 DARS Annual Internal Audit Report This project was included on the Fiscal Year 2013 Audit Plan and issued as report #13101 in April 2013. The high-level observations/results were that 24 of the 25 recommendations assessed were identified as either implemented or substantially implemented. Recommendations were not issued for this project. Management utilized the information to determine whether additional actions were necessary to fully implement the recommendations. Early Childhood Intervention Family Cost Share Project This was a special project completed by a team of University of Texas, McCombs School of Business students under the supervision and guidance of the DARS Internal Audit Division. The objective of the project was to identify the factors that needed to be taken into consideration for the agency to implement the recommendations made by the Texas State Government Effectiveness and Efficiency Report to improve the cost effectiveness of family share provisions. The report issued for this project was limited to the students’ report that was submitted for their class project. The high-level observation/result for this project was a proposed model to calculate family cost share and considerations the agency should take into account during implementation. There were no recommendations issued with this project. Early Childhood Intervention Funding Chronology This special project was requested to document the chronology of the changes in the Early Childhood Intervention program’s payment methodology since the chronology prepared by the Internal Audit Division in 2009. There were no recommendations issued with this project. Board for Evaluation of Interpreters This special project was conducted to evaluate and document selected current Board for Evaluation of Interpreter processes; identify risks and determine whether the risks are adequately mitigated; and to provide advice on considerations for improvement and implementing statutory requirements. The high-level observations/results for this project were detailed flowcharts of the fees collection, interpreter testing, and interpreter training processes and identification of existing and missing controls in each of them. As a result of this project the DARS Internal Audit Division included an audit of the processes related to fees in the Fiscal Year 2014 Audit Plan. DARS Internal Audit Division 3 DARS Annual Internal Audit Report Fraud Training to Early Childhood Intervention Staff Two members of the Internal Audit Division developed and provided a four-hour training session on fraud. During this time they discussed such topics as how to identify fraud and what action to take if they have concerns that fraud exists. Respondents found this training helpful and rated it as 3.4 out of 4.0 in the survey that was conducted. Section IV External Quality Assurance Review The Division’s External Quality Assurance Review was completed in July, 2013, by an independent consultant. The opinion that was reported was as follows: Based on the original work and the follow up work outlined above, it is the opinion of the reviewer that the internal audit activity at the Texas Department of Assistive and Rehabilitative Services generally conforms to the IIA Standards, the Government Auditing Standards, and the Texas Internal Auditing Act. This opinion, representing the best possible evaluation, means that policies, procedures, and an internal audit charter are in place, and that the practices that are followed provide reasonable assurance that the audit work conducted is in compliance with the requirements of the applicable professional standards and the Texas Internal Auditing Act. DARS Internal Audit Division 4 DARS Annual Internal Audit Report Section V DARS Internal Audit Plan for Fiscal Year 2014 The audit plan, as listed below, was approved by the DARS Commissioner on August 21, 2013. Audit/Project Division for Rehabilitation Services – Vocational Rehabilitation Financial Controls Autism Program Blind Children’s Vocational Discovery & Development Program Deaf and Hard of Hearing Division for Blind Services – Budget Management and Monitoring of Consumer Purchases (carryover from FY 2013) Division for Blind Services – Independent Living Program Information Technology Governance Follow Up on the CRS Management Review conducted by HHSC Internal Audit Follow Up of DARS Internal Audit Report on Controls over the Access Termination Process (carryover from FY 2013) Risk Assessment Model for Consumer Programs Estimated Budget Hours 1500 800 750 750 750 750 750 750 500 250 125 The areas identified as high risk that were not included in the Fiscal Year 2014 Audit Plan and the reason are as follows: Early Childhood Intervention – significant consulting/non-audit work was conducted in this area during fiscal year 2013. Specifically, the Internal Audit Division completed a special project on the funding chronology, led a group of University of Texas students through a project to identify the factors that needed to be taken into consideration for the agency to implement the recommendations made by the Texas State Government Effectiveness and Efficiency Report to improve the cost effectiveness of family share provisions, and provided a fourhour training session on fraud for ECI staff. Criss Cole Rehabilitation Center – the center is currently undergoing a significant review and revision of all policies and procedures. Review of the risks and discussions with management determined that more value could be gained through auditing this at a later date. Division for Rehabilitation Services Independent Living – portions of this program were included in the Audit of Centers for Independent Living, which was completed in 2011. DARS Internal Audit Division 5 DARS Annual Internal Audit Report Centers for Independent Living – as stated above, this audit was completed in 2011. Additionally, a follow up of the audit was completed in 2013. The results of the risk assessment were discussed with management. Management understands its responsibilities regarding risk and the importance of mitigating it to the extent possible. Dialogue between the Internal Audit Division and management is conducted as a matter of day-to-day business and any changes in risk will be discussed and adjustments made to the audit plan if determined necessary. The risk assessment was conducted using a combination of methodologies. A survey was sent to management who directly report to members of the Executive Management Team requesting their views on where risks are the highest in their area as well as across the agency along with other questions pertaining to controls, and executive management was interviewed to gain their opinions and concerns. The identified list of auditable areas was risk assessed, by DARS Internal Audit staff, using the following risk factors with additional weight added to those that executive management and/or the Internal Audit Division identified interest or concerns about: Impact on the consumers Potential for Fraud, Waste, and Abuse Violation of State and/or Federal Regulations Negative Publicity/Loss of Public Trust Complexity of Operations Finally, review of the history of audit coverage over the past five years was conducted to assist in determining the areas that would be included in the Fiscal Year 2014 Audit Plan. Section VI External Audit Services Procured in Fiscal Year 2013 The Department of Assistive and Rehabilitative Services did not contract for audit services during fiscal year 2013. DARS Internal Audit Division 6 DARS Annual Internal Audit Report Section VII Reporting Suspected Fraud and Abuse The DARS Internet and Intranet, and HHS Circular C-027, HHS Enterprise Fraud Prevention and Awareness, provide information on how to report suspected fraud, waste, and abuse directly to the State Auditor’s Office (SAO). To our knowledge, these reports are being made in accordance with Section 7.09, Fraud Reporting, in the General Appropriations Act. DARS Internal Audit Division 7