DHS’ funding and payments for PALMS violated Federal appropriations law.  Specifically, DHS violated the bona fide needs rule in using fiscal year (FY) 2011 component funds in FYs 2012 and 2013 for e-Training services and PALMS implementation respectively, when the funds were not legally available for those needs.  As a result of the bona fide needs rule and purpose statute violations, DHS may also have violated the Antideficiency Act in FYs 2013 – 2015 when the Department augmented appropriations for the Human Resources Information Technology program with component funds. We made nine recommendations to address violations of Federal appropriations law and to improve controls to prevent such potential violations in the future.