ESBD_527220_1782835809704_Responses to Questions RFP 240q FINAL.docx

TEXAS COMPTROLLER OF PUBLIC ACCOUNTS

Request for Proposals for Auditing Services on Behalf of the Education Savings Account Program (RFP# 240q)

Official Responses to Questions from Potential Respondents (June 30, 2026)

1. Section 2.2; Page 10: Can the Comptroller clarify whether the CEAO contract includes any requirements, controls, or performance expectations that extend beyond those defined in SB2 and Program rules, and if so, will the Comptroller share the relevant areas within the CEAO contract that should be reflected in the proposed audit methodologies?

RESPONSE: The CEAO contract (CEAO Contract) is available at: https://cms.lbb.texas.gov/Public/SearchedList.aspx?Search=Y&aid=304&cid=0000000000000000000202395

2. Section 2.2; Page 11: Can the Comptroller clarify the audit period to be covered for the initial audit, specifically whether the audit scope is expected to include transactions and program activities from July 1, 2026 through September 30, 2026, given that audit fieldwork is anticipated to occur from September 1, 2026 through December 31, 2026 and SB2 requires annual audits?

RESPONSE: Comptroller is not requesting Proposals for an annual financial audit. Texas Education Code, Subchapter J, Section 29.363(a) requires the Comptroller to contract with a private entity to audit accounts and program participant eligibility data not less than once per year to ensure compliance with applicable law and program requirements. Respondent should submit a proposed Project Work Plan detailing the scope of work that will be accomplished during the initial audit period and propose timing and scope of audit work to be completed in future years included in the Contract Term, including possible extensions. An example of auditing Program Participant eligibility data might be a review of such things as an applicant’s income and citizenship documentation used in determining eligibility. See RFP Sections 1.2, 2.1, and 4.2.J.

3. Section 2.2.2; Page 11: When performing compliance testing on providers/vendors, will the Comptroller provide the successful respondent access to data from other state agencies (e.g., Texas Education Agency), so risk tiering analysis may incorporate certification records, disciplinary actions or indicators of prior audit or investigation procedures?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby added, as follows:

Comptroller uses data from DPS, TEA, and SEMARC when screening marketplace vendors who will have in-person or virtual direct contact with Program Participants. Access to those systems is restricted; however, Comptroller staff may provide data obtained from those systems that was used in screening individuals.

4. Section 2.2.3; Page 11: Will a successful respondent have direct system access to the CEAO's software platform (i.e. through API) in order to support efficient data transfer and data validation procedures?

RESPONSE: Section 2.2 is hereby amended with the following addition:

Successful Respondent will not have direct access to the CEAO’s system(s) or platform(s) (i.e., via API), but will be provided relevant raw data via file share.

5. Section 4.2.J; Page 20: For the required multi-year Project Work Plan, does the Comptroller expect subsequent audit periods (including renewals) to follow a similar annual audit cadence and timeline as the initial audit (e.g., approximately September through December), or should respondents propose alternative timing for future audit cycles based on program evolution and risk considerations?

RESPONSE: See Response to Question 2,

6. Section 4.2.J; Page 20: The anticipated contract execution date is September 1, 2026 with the first audit requested to be completed by December 31, 2026, does the Comptroller anticipate providing feedback and approving the Work Plan within the first 30 days of the contract to support timely initiation of field work procedures?

RESPONSE: The Project Work Plan will be negotiated and approved during contract development, prior to contract execution. See RFP Section 4.2.J and RFP Sample Contract Exhibit D.

7. Section 4.2.J; Pages 20 – 21; Section 4.2.J requires respondents to define the volume of records to be analyzed across subject areas. Can the Comptroller provide any available information on estimated population sizes (e.g., participant eligibility records, transactions, providers/vendors, and appeals)?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby amended to add the following:

The approximate volume of TEFA records: ~270,000 applications; ~120,000 awardees; ~4,000 private schools; ~10,000 vendors; and ~4,400 appeals . Each of those records could have multiple pieces of support documentation, resulting in millions of transactions. The number of transactions on the marketplace cannot be estimated as the marketplace does not open until July 1, 2026 for parents to begin authorizing purchases of educational goods and services and approval of tuition and fees.

8. Section 4.2.J; Pages 20 – 21: If estimated population sizes cannot be provided, would the Comptroller consider it acceptable for respondents to define their approach using a risk-based methodology, with final sample sizes determined upon access to population data?

RESPONSE: See Response to Question 7.

9. Section 14.41, Item f; Page 43: Will the Comptroller allow respondent personnel's supporting technology administrators or service providers located outside the United States to access CPA data securely hosted and maintained in the United States?

RESPONSE: See RFP Section 4.2.A and RFP Sample Contract Section 14.41.

10. Section 14.41, Item s; Page 45: Can the Comptroller share which AI software/tools are currently in use by personnel involved in the Education Savings Account Program (e.g., Microsoft Copilot, Perplexity, Claude) and for each software whether there are example leading practices in use and configuration?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby updated to add the following:

The CEAO uses AI to help provide insight and make recommendations. AI is not used for programmatic decisions. Various U.S. based AI services are used to help analyze customer service data, provide summarized support responses based on the knowledge base, extract data from documents, to detect fraud, and for overall data analysis.

11. Section 14.41 Item s; Page 45: Do the AI-related requirements include embedded AI features in underlying third-party platforms and software tools used to support delivery (e.g., Microsoft Document Intelligence)?

RESPONSE: Yes. See RFP Sample Contract Section 14.41.

12. Section 14.41, Item s.d; Page 45: Considering the successful respondent will be performing compliance reviews after transactions have been completed, can the Comptroller confirm that the AI Disclosure Notice is not applicable since information will be received from the CEAO with no direct interaction with the public?

RESPONSE: Yes. If auditors are using AI tools only internally and not offering any AI features to the general public, this disclosure requirement does not apply. See RFP Sample Contract Section 14.41.

13. Section 1.2.3: As of the date of RFP question submission (6/23/26) how many unique awards and award dollars have been granted?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby amended to add the following:

Approximately 106,000 TEFA awards have been granted totaling approximately $880 million. A limited number of additional awards are expected as parents whose students received awards opt out of participation and the reserve budget set aside for appeals is released.

14. Section 1.2.3: How many unique awards and award dollars are expected to be granted by 8/31/26?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby amended to add the following:

The TEFA application period closed on March 31, 2026. While the Program will continue to bring students off the wait list as awarded students opt out of participation between now and August 31, 2026, the number of Participants that will be added between now and August 31, 2026 will be relatively small and additional dollars that will be awarded are estimated at less than $50 million.

15. Section 1.2: Does the CEAO maintain all documentation supporting award decisions? If so, is that documentation available to the auditors in support of this project?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby updated to include the following:

The CEAO maintains all documentation related to TEFA award decisions and the documentation will be available to Successful Respondent for audit purposes.

16. Section 1.2: Does the Comptroller and/or CEAO have a preference over remote versus on-site work?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby updated to add the following:

Comptroller does not have a preference regarding remote versus on-site work.

17. Section 2.1: Has the CEAO documented its internal controls over program transactions, accounts, participant eligibility data and provider and vendor transactions? If so, how many controls have been identified?

RESPONSE: RFP Section 1.2.9 (Additional Information) is hereby amended to add the following:

The CEAO has implemented numerous internal controls, including those required by the Contract and related to best practices. While no count of documented internal controls exists, total internal controls are estimated to be in the hundreds.

18. Section 2.1: If the Comptroller awards more than one contract for auditing services, what is the anticipated allocation of work among the services listed in this section or the audit objections in Section 2.2?

RESPONSE: CPA is unable to determine whether there will be one or more contracts until Proposals are received and evaluated. There is no pre-determined allocation of work if more than one contract is awarded. See RFP Section 1.1 (Introduction).

19. Section 3.1: This section states a contract period of 9/1/26 through 8/31/27, but RFP Section 4.2.J sets a report deadline of 12/31/26; can you clarify what project deliverables are expected by what dates?

RESPONSE: The Respondent’s proposed Project Work Plan should indicate the project deliverables. See RFP Section 4.2.J.

20. Exhibit G:, Pages 65 – 66: The Vendor Reference Form is prepopulated for Type of Product/Service Provided with “Auditing Services for Educational Savings Account Program (the “Services”). Can this field be changed to submit vendor references for other relevant past performance?

RESPONSE: Respondent may change the description in that field if requesting a reference for other types of relevant services. See Exhibit G.

21. Section 4.2.F.3, Page 18: If the reference submits a form to the Comptroller and the response indicates the past performance is evaluated in the Vendor Performance Tracking System (VPTS) will the submission be considered complete?

RESPONSE: Yes. The Client Reference Form is intended to provide the Evaluation Committee with a more robust reference than that provided in VPTS. See RFP Section 4.2.F.3.

22. Section 2.2, Page 11: Does the contract between the Comptroller and the CEAO require the CEAO to have an annual System and Organization Controls (SOC) 1 or 2 audit?

RESPONSE: See Response to Question 1.

23. Section 2.2, Page 11: Does the contract between the Comptroller and the CEAO have specific response times related to request for information and documentation that would be applicable to an audit timeline?

RESPONSE: See Response to Question 1 and CEAO Contract, Attachment B.

24. Section 4.2.J, Page 20: The solicitation has multiple audit objectives and the work plan requests completion of the initial audit by December 31, 2026. Is the solicitation requesting multiple audits of the full scope or a break down of audit objectives into multiple audits with the first audit scope being defined by the responder?

RESPONSE: Respondent’s proposed Project Work Plan should indicate the audit work and deliverables that will be completed by the December 31, 2026 deadline. See RFP Sections 2.1 and 4.2.J.

Official Responses to Questions from Potential Respondents – RFP 240q Page 1 of 1