\ Office of Inspector General
Report of Audit
REVIEW OF THE ACCURACY OF EPA's
PAYROLL AND PERSONNEL SYSTEM
(EPAYS)
D
D
E1AMF6-11-0005-6100275
August 15, 1996
-------
INSPECTOR GENERAL DIVISION
CONDUCTING THE AUDIT: HEADQUARTERS AUDIT DIVISION
PROGRAM OFFICE COVERED: OFFICE OF ADMINISTRATION AND
RESOURCES MANAGEMENT
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
AUG 15 1996
OFFICE OF
"WE. INSPECTOR GENERAL
MEMORANDUM
SUBJECT: Review of the Accuracy of EPA's Payroll and Personnel System (EPAYS)
(Audit Report No. El AMF6-11-0005-6100275)
FROM: Michael Simmons
Deputy Assistant Inspector General
for Internal and Performance Audits (2421)
TO: Alvin M. Pesachowitz
Acting Assistant Administrator
for Administration and Resources Management (3101)
Attached is our final report titled Accuracy of EPA*s Payroll and Personnel System
fEPAYSt. The primary objectives of our review were to determine whether: (1) EPAYS
provides accurate information for Reduction-in-force purposes; and (2) Management control
systems are in place to provide reasonable assurance that the relevant EPAYS information is
accurate.
This report identifies corrective actions the Office of Inspector General (OIG)
recommends involving the accuracy of the EPAYS system. As such, it represents the opinion
of the OIG. Final determinations on the matters in the report will be made by EPA managers
in accordance with established EPA audit resolution procedures. Accordingly, the findings
described in this report do not necessarily represent the final EPA position.
The response by the Office of Administration and Resources Management (OARM) to
our draft report is included as Appendix V. Our evaluation and comments on the response are
included throughout the report, as appropriate. Based on OARM's response to the draft report
and prior discussions, we made appropriate changes to this final report. Further, we believe
that the corrective actions planned and the milestones indicated are responsive to the
recommendations in the audit report, and are therefore closing the report in our tracking
system upon issuance.
We appreciate the cooperation extended to our auditors during this audit. If you or
your staff have any questions concerning this report, please contact Edward Gekosky,
Divisional Inspector General for Audit, or Frances E. Tafer of my staff, on (703) 308-8222.
Attachment
cAJ. HtcttttdltticttUt
I ink an paper mar
-------
-------
ACCURACY OF EPA's PAYROLL
AND PERSONNEL SYSTEM (EPAYS)
•
E1AMF6-11-0005-6100275
-------
Report of the Accuracy of EPA'» Pem>tmel and PayroU System (EPAYS) _ El AMF6-1 l-OOOS-6 100275
TART.F OK
EXECUTIVE SUMMARY
CHAPTERS
1. INTRODUCTION . . ...... . ............................. 1
PURPOSE ................. . . • ............. . ......... 1
BACKGROUND ...................................... 1
SCOPE AND METHODOLOGY . . . ................. ........ 4
2. OHROS EFFORT IMPROVES ACCURACY OF PERSONNEL
INFORMATION MAINTAINED IN EPAYS, BUT MANAGEMENT
CONTROLS ARE NEEDED TO MAINTAIN ACCURACY ........... 7
3. CONTROL OVER OFFICIAL PERSONNEL FOLDERS COULD BE
IMPROVED .......... . ........... . ...... . .......... 15
4. EPAYS SYSTEM SECURITY COULD BE COMPROMISED ......... 19
r
APPENDIX I - ACRONYMS ................................ ...... 21
APPENDK H - OVERVIEW OF A REDUCTION-IN-FORCE ................ 22
APPENDIX ffl - METHODOLOGY ................................. 24
APPENDK IV - OHRQS PERSONNEL OPERATIONS WORKGROUP ........... 26
APPENDK V - AGENCY COMMENTS ......... .............. . ...... 28
APPENDK VI - DISTRIBUTION ....... ..... ........................ 31
-------
Report of the Accuracy of EPA't Peraonnel and Payroll Syrtam (HPAYS)
EXECUTIVE SUMMARY
EIAMF6-11-0005-6100275
PURPOSE
As a result of a potential $2.5 billion (34%) cut by the House of
Representatives to the Agency's fiscal 1996 budget, the Agency
had to prepare quickly for a reduction-in-force (RTF). In view of
this and as a result of several other OIG audits which identified
problems associated with the Agency's information management
systems, we initiated an audit of EPA's Payroll and Personnel
System (EPAYS). EPAYS contains the employees' personnel
information which would be used in conducting a RIF (see
Appendix II). The emphasis of the audit was to determine
whether the personnel information contained in EPAYS was
complete and accurate, and whether the system could be used
quickly and with confidence during a required RIF, furlough, or
other minor or mass personnel action. Specific objectives were
to determine whether:
1. EPAYS provides accurate information for RIF purposes;
and
2. Management control systems are in place to provide
reasonable assurance that the relevant EPAYS information
is accurate.
BACKGROUND
EPAYS is an acronym for the Environmental Protection
Agency's integrated Payroll and Personnel System. EPA has
used the system since 1970, and has made major modifications to
comply with new governmental requirements to provide expanded
services and flexibility to EPA employees.
EPAYS integrates the functions formally performed
independently by the personnel, payroll and timekeeper's offices.
EPAYS now automates the tasks which at one time were done
manually, and all EPA offices throughout the United States
manage their EPAYS tasks (and others) through the Agency's
IBM 3090 mainframe computer located at Research Triangle Park
(RTP), North Carolina.
The Assistant Administrator for Administration and Resources
Management (OARM) has responsibility for EPAYS. Within
OARM, two offices have the responsibility for entering data into
EPAYS. The Office of Human Resources and Organizational
Services (OHROS) is responsible for entering employees'
personnel information into EPAYS, while the Office of the
11
-------
Report of the Accuracy of EPA'a Personnel and Payroll System (EPAYS) El AMF6-1 l-OOOS-6100275
Comptroller (OC) is responsible for entering employee financial
and payroll information into EPAYS.
OHROS is also responsible for the management and control of all
Official Personnel files (OPFs) for EPA employees serviced by
the Headquarters's Human Resources Staff. OPFs are the official
repositories of the records, reports of personnel actions, and the
documents and papers required concerning actions affected during
an employee's federal service. These records provide the basic
source of data about a person's employment while in the federal
service and after separation.
RESULTS. Our audit found that OHROS, since September 1995 has been
IN BRIEF expending a considerable amount of time reviewing and cleaning
up the OPFs and in making corrections to the personnel
information contained in EPAYS. We found that between
November 27, 1995 and January 31, 1996, the OHROS review
had reduced the number of EPAYS personnel information
inaccuracies by more than 65 %. OHROS staff has continued to
review OPFs and enter information beyond our computer report
date of January 31,1996. We were told by an Agency official,
that before a reduction-in-force would be fully executed, each
employee's OPF will be checked three times for accuracy, along
with a check by the employee.
However, we noted that OHROS apparently viewed the accuracy
of EPAYS and the currency of the OPFs as a low priority.
Although OHROS had conducted at least two reorganizations
devoted.to improving customer service and improving the filing
of OPFs, it was not until EPA was faced with a potential RIF
that OHROS begin a comprehensive review of the OPFs and of
the accuracy of the EPAYS information. We found that OHROS
had not identified the accuracy or reliability of EPAYS personnel
information in any of its FMFIA documentation, had not planned
or conducted any quality assurance reviews of the EPAYS
system, and had not assigned responsibility for system accuracy
in any of its position descriptions for Personnel Management
Specialists. We were told by OHROS officials, that the
developing and executing of new procedures would not take place
until the potential RIF concerns are eliminated.
-------
Report of the Accuracy of EPA'i Personnel and Payroll System (EPAYS)
El AMF6-1 1.000S-610027S
PRINCIPAL
FINDINGS
OHROS Aware of
need for corrections
Management Control
Reviews of EPAYS
Accuracy and Official
Personnel Files Not
Conducted
We summarized below and discussed our principal findings in
detail in Chapters 2 through 4 of this report.
On September 18, 1995, OHROS sent a memorandum to
all Headquarters' employees requesting that they review the
attached personnel data profile. OHROS created the profile
based on the information in the Agency's automated personnel
system (EPAYS) and the employees' official personnel files.
Employees were requested to examine all the data elements on
the profile and make any corrections necessary, complete the
certification at the bottom of the profile page, and return the
profile sheet (along with any supporting documentation .to prove
changes to be made) by September 29, 1995. However, our
review of a sample of OPFs and "profiles" received from Agency
staff identified a need for OHROS to develop Management
Controls to verify that employee personnel information is entered
accurately in EPAYS.
We reviewed the fiscal 1993 Office of Human Resources
Management (OHRM) event cycle1 documentation and
related annual management control summaries conducted
between fiscal 1993 and 1995. We found that OHRM had not
identified, as an event cycle, reviews of the OPFs and accuracy
of personnel information contained in EPAYS. We also noted
that OHRM had not conducted any reviews to validate and ensure
the accuracy of the data in EPAYS compared with the
information contained within the OPFs.
Because of the lack of management control reviews and a
potential reduction-in-force caused by a potential $2.5 billion
(34%) cut by the House of Representatives to the Agency's fiscal
1996 budget, the Agency had to expend at least $55,300 in
overtime costs and countless hours in Agency staff time
correcting system errors and omissions, and updating missing
information in the official personnel folders. If the event cycle
controls had been in place, the additional Agency staff time
expanded might have been reduced.
1 Operations within a program or function are activities that fulfill the mission of the
program or function. These are the event cycles. They are the processes followed to perform
related activities, create the necessary documentation, and gather and report data. Typical
examples of event cycles are: (1) Policy and planning; (2) Program cycles; (3) Admin-
istrative cycles (personnel, procurement, budget, etc.); and (4) Assets management.
IV
-------
Report of the Accuracy of EPA's Personnel and Payroll System (HPAYS)
El AMF6-11-0005-6100275
OHROS Needs To
Implement A
Written Policy On
Personnel Actions
Data Entry Verification
Control Over
Official Personnel
Folders Needs
Improvement
To identify management controls established by OHROS,
we requested copies of policies, procedures, or guidelines
provided to OHROS staff. We interviewed several personnel
management specialists to determine procedures used in
processing personnel actions. The procedures used by the staff
contained a verification process. However, the staff we
interviewed also told us that it was not their responsibility to
verify data entry. Although verification procedures we discussed
with them were consistent among the staff, no written policy
existed.
As of February 20, 1996, based on our review of 379 folders, we
identified that 58 individuals (15.3% of the folders we reviewed)
had performance appraisals in their official personnel folders for
fiscal years 1991 through 1994, but did not have those ratings
entered in EPAYS based on a November 27, 1995 computer
report. As a result of the on-going reviews of OPFs conducted
by OHROS, we requested a second EPAYS report (January 31,
1996) to determine if OFF information was being updated in
EPAYS. Based on the January report, OHROS reduced the
number of individuals missing information from 58 to 20 out of
379 or 5.3%.
Although OHROS has significantly reduced the number of
inaccuracies, improvements to its management controls over the
verification of data entry are still needed to ensure the future
accuracy of EPAYS. Computer reports are available which could
assist OHROS in identifying potentially missing, inaccurate, or
incomplete personnel information. Also, OHROS should, at least
annually, notify EPA employees of the need to periodically
review and update the OPFs.
Over the five months (October 30, 1995 through March 15,
1996) of our review, the OPF Center staff had difficulty
in the timely retrieval of the OPFs for our review. We would
receive only a portion of the OPFs requested and had to
continually request, through the project officer, OPFs not
initially provided. During our review, we observed a Personnel
Management Specialist being told that she already had OPFs
signed out to her which she was requesting, but the specialist
insisted that she had returned the folders. Further, during a
discussion with one of the Human Resources Team Directors, we
were told the Director also had difficulty in obtaining folders.
Individual staff team members may have had the folders at their
desks while awaiting additional information. However,
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
maintaining the folders at their desks versus the Central fileroom
compromises the security of the folders and increases the risk of
the folders being misplaced.
EPAYS System
Security Could
Be Compromised
RECOMMENDATIONS
We noted that 52.6% (41 out of 78) of the personnel
management specialists have supervisory data entry capability.
This capability permits the user to enter and modify information
contained in the personnel data base. We questioned several
OHROS staff about whether the personnel management
specialists could access their own files and make changes to those
files. Two individuals (the Chief of the Client Support Branch
and the previous Acting Chief of the Systems Support Staff) said
that the system does not prevent access to an individual's own
record. One individual, an OHROS staff Team Director, stated
that one of his individuals attempted to enter an award into
his/her own record but was blocked.
We did not identify any data entry activity, while reviewing the
EPAYS computer reports, which would have caused additional
fieldwork. However, we did not review the activities of the
personnel specialists in the regional offices who have the
capability of entering both payroll and personnel information.
The system should contain a security control which would
prohibit an individual from entering information into their own
record. Without such a security control, information in the
system could be compromised and lead to potential fraudulent
activity.
Our detailed recommendations are listed following the findings in
Chapters 2 through 4. However, in summary, we are
recommending that the Acting Assistant Administrator for
Administration and Resources Management:
1. Require semiannual briefings on the status of the
implementation of planned quality assurance activities
until a system is in place and effectively functioning.
2. Require the workgroup to generate a computer report, as
we did, to identify employees with missing performance
rating information in EPAYS.
3. Request that the OHROS Team Directors work with their
staff to ensure that folders being reviewed for
completeness and accuracy be returned to the OPF Center
as timely as possible.
VI
-------
Report of the Accuracy of EPA'a Personnel and Payroll System (HPAYS)
El AMF6-11-0005-6100275
4. Require that an automated control be added to EPAYS to
prevent an individual from accessing their own file and
making changes to that file.
AGENCY COMMENTS
OIG COMMENTS
We met with Agency officials on April 4, 1996, to discuss the
position papers we provided them so they could preview our
potential audit findings. At that meeting, the Agency officials
commented on our draft material saying:
The thorough manual rechecking they feel is necessary for
any RIF listing, or similar iteration which could affect
, EPA employees in such an important way, negates
auditors* concerns with the accuracy of EPAYS data.
Indeed, $55,000 in overtime is a minor cost in
comparison with the high amount of effort officials
believe must be expended to ensure absolute accuracy of
any RIF listing prepared for the Agency.
The error rate the OIG auditor found through testing is a
low error rate (5%) for a system such as EPAYS2.
The agency in its July 24, 1996 response to our draft audit
report, agreed with our principal findings and indicated that its
Office of Human Resources and Organizational Services
(OHROS) has gone beyond our recommendations to ensure the
accuracy of EPAYS data (see Appendix V for the full response).
We continue to believe much less effort would have had to have
been expended on preparing for a potential RIF if management
controls had been in place and EPAYS and OPFs had been more
accurate. The overtime and during business hours time expended
to provide the necessary accuracy for preparation for a potential *
RIF would have been much less or even unnecessary. In regard
to the error rate, the OIG believes, although it is low, it is
significant based on the amount of time which has been and
continues to be spent in reviewing OPFs and entering ratings into
EPAYS. It reflects two concerns: (1) a lack of management
controls in place to verify that information has been accurately
At the time we presented our position papers to Agency officials for their
review, we expressed separate individual error rates based on two sample
reviews. When the samples were combined, based on the same factors, the
combined error rate increased from 5.3 percent to 15.3 percent. Agency
officials expressed their opinion on the lower error rate.
vii
-------
Report of tho Accuracy of EPA'« Personnel and Payroll System (EPAYS) ElAMF6-11-0005-6100275
entered into EPAYS and (2) it increases EPA staffs concern
about the accuracy of EPAYS when they discover that
information supplied still was not entered into EPAYS.
Vlll
-------
Report of the Accuracy of EPA'« Personnel and Payroll System (EPAYS) E1AMF6-J1-0005-6100275
[This page intentionally left blank]
IX
-------
Report of die Accuracy of EPA'f Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
PURPOSE
CHAPTERl
INTRODUCTION
As a result of a potential $2.5 billion (34%) cut by the House of
Representatives to the Agency's fiscal 1996 budget, the Agency
had to prepare quickly for a potential reduction-in-force (RIF).
The Agency took preliminary steps to organize a RIF in case the
Senate failed to restore some of the agency's funding. It is for
this reason, and because several other Office of Inspector General
(OIG) and General Accounting Office (GAO) audits had
identified problems associated with the Agency's information
management systems, that the OIG conducted an audit of the
accuracy of the Agency's Personnel and Payroll System
(EPAYS). The emphasis of the audit was to determine whether
the personnel information contained in EPAYS was complete and
accurate and whether the system could be used quickly and with
confidence during a required reduction-in-force, furlough, or
other minor or mass personnel action.
Although the fiscal 1996 budget impasse has recently been
resolved, and the Administrator has announced that no RIFs or
furloughs will occur during the remainder of fiscal 1996, doubt
about the future remains. Congress will soon debate the fiscal
1997 budget. In the near future, EPA may again have to plan for
potential RIFs and furloughs.
Specific objectives of our review were to determine whether: (1)
EPAYS provides accurate information for RIF purposes and (2)
management control systems are in place to provide reasonable
assurance that the relevant EPAYS information is accurate.
BACKGROUND
Environmental Protection EPAYS is an acronym for the Environmental Protection
Agency '$ Payroll and
Personnel System
(EPAYS)
Agency's integrated Payroll and Personnel System.
The Department of the Interior originally developed it and called
it DIPS (Departmental Integrated Personal Services System).
EPA has used the system since 1970, and since then
has made major modifications to comply with new governmental
requirements, and has enhanced the system to provide expanded
services and flexibility to EPA employees.
-------
Report of th« Accuracy of EPA'« Personnel mid Payroll System (EPAYSL
E1AMF6-11-0005-6100275
System Responsibility
Personnel Management
Staff
Central Systems
Branch
The Office of Hitman
Resources Management
and Organizational
Services (OHROS)
The Assistant Administrator for Administration and Resources
Management (OARM) has the responsibility for EPAYS. Within
the Office of Administration and Resources Management
(OARM), two offices carry out most of the EPAYS Personnel
system functions.
• The personnel management staff under the personnel
teams conducts personnel data entry, and they are
responsible for the Human Resources functions of specific
AA ships. The personnel teams are in the Headquarters
Operations and Client Services Division of the Office of
Human Resources Management.
• Monitoring and maintaining the programs and systems are
handled by the Central Systems Branch (CSB) in the
Enterprise Systems Division (BSD) of the Office of
Information Resources Management (OIRM). CSB works
very closely with the staff at Research Triangle Park
(RTF), North Carolina, who maintain the Agency's
mainframe system and share the task of monitoring
EPAYS in all its stages. Any change in pay structure,
benefits, etc., required of EPA by Congress or other
governmental bodies and enhancements to EPAYS
requiring program modification, are dealt with by CSB.
The Office of Human Resources Management and Organizational
Services is responsible for the management and control of all
OPFs for EPA employees serviced by the Headquarters'
Human Resources Staff. OPFs are the official repository of the
records, reports of personnel actions, and the documents and
papers required in connection with these actions effected during
an employee's Federal service. These records provide the basic
source of data about a person's Federal employment while that
person is in the service and after separation.
OHROS has custodial responsibilities for OPFs and is responsible
for ensuring that they maintain them according to the Office of
Personnel Management (OPM) and EPA regulations and policies.
These responsibilities include:
• Establishing personnel folders and ensuring that
documents are filed appropriately and in order.
• Filing and refiling documents into OPFs following
guidelines established by EPA and OPM.
-------
Report of the Accuracy of EPA't Personnel «id P^II »
El AMF6-1 l-OOOS.*innrK
fOUOWin8 StandardS established
Official Personnel
Folders Center (OPFQ
Reduction-in-Force
ding °nly authorized
staff access to the
• Completing requests to review, copy, and charge out/in
folders to authorized personnel.
• Retiring or transferring OPFs when an employee
separates. F J
Document maintained in the Center consist of OPFs of all
SS^JLT^ KTViC* by *" *•*!»«• Human
Resources Staff. Approx,mately 8,000 OPFs are managed by
to demote, separate, or furlough one or more
employees because of lack of work, shortage of funds or
reorganization. The cause of a RIF may come from action of
£ S '-e PreSidem' the °fflce of M^gement and Budget
hL ^ r^ °J ** head °f ** a*en<* or «>me official who
has been authorized to decide. Whatever the source of the
SSZSSZ RIF' °ffiCialS °f ^ ^^ must decide ^w to
distribute the remaining resources and what parts and programs
of the agency to cut, and how much.
, must,first1describe the Kmits within which employees
compete with each other for retention of their jobs. The first
him (compete area) is organizational and geographical
Next, the agency identifies the competitive level. It consists of
^positions in a competitive area in the same grade and series,
rtLSf?? '"I"8" ^ ^ «uaUfication requirements, piy
^S, drrldng C°nditions (an incumbe« of one could
successfully perform critical elements of any other
"
n
T ne
qualified employee). The names of all employees in a
competitive level are listed on a retention register in the order of
the r reiatwe retention standing. Their relative standing is b^ed
on the four factors named in section 3502a of title 5, US Code-
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS)
E1AMF6-H-OOOS-6100275
• Tenure of Employment,
• Veteran's Preference,
• Service Computation Date, and
• Performance Appraisal.
In the normal order of release from the competitive level, no
employee is released unless everyone below him or her on the
retention register is released.
SCOPE AND
METHODOLOGY
The audit was performed in accordance with the Governmental
Auditing Standards issued by the Comptroller General of the
United States (1994 revision). The audit field work was
performed from November 1995 through March 1996 and
included on-site work in the Office of Human Resources
Organizational Services (OHROS) in Headquarters. Our audit
covered management procedures in effect as of December 31,
1995.
Methodology
Evidence Examined
To evaluate the accuracy of information contained in the OPFs as
compared with information contained in EPAYS, we selected a
sample of 416 OPFs from the program offices which make up
headquarters' twelve (12) Assistant Administrators (AAships).
(see Appendix III for methodology). However, as a result of the
OPF Center not being able to timely provide us with 37 OPFs
(see Chapter 3), we were only able to base our review on 379
OPFs.
At the time of this audit, EPA's fiscal 1996 budget had not been
approved, resulting in a limited travel budget. We decided that a
review of the accuracy of EPAYS within headquarters would just
as readily assist the Agency as would a review of selected
regional offices.
To accomplish our objectives, we:
• Interviewed selected OHROS program office
team directors and Washington Financial Management
Center (WFMQ staff;
• Selected and reviewed a sample of OPFs of headquarters
employees;
-------
Report of the Accuracy of EPA't Personnel and Payroll System (EPAYS)
E1AMF6-11-OOOS-6100275
• Obtained and reviewed computer printouts (profile),
contract delivery orders, administrative guidance and
procedures, and management control summaries
conducted.
Our audit did not include reviews of information
contained in regional personnel offices.
FMFIA Review
Internal Controls
Prior Audit
Coverage
The fieldwork performed included tests of only those
management controls and procedures specifically related to the
audit objectives. The audit included tests of management and
related Federal Manager's Financial Integrity Act (FMFIA)
controls, policies, and procedures specifically related to the audit
objectives. We reviewed OHROS FMFIA documentation
including: assessable unit assurance letters which summarized
internal/management control reviews (I/MCRs) and alternate
internal/management control reviews (AI/MCRs) from fiscal
1993 to fiscal 1995; and OHROS's event cycle documentation.
We reviewed the internal controls associated with the accuracy of
key data fields within the EPAYS system and the security of the
Official Personnel Folders (OPFs). The controls we evaluated
included data entry verification, management information
systems, and operation of the OPF Center.
The internal control weaknesses noted in our review are discussed
in detail in Chapters 2 through 4 of this report. Our
recommendations, if implemented, should improve the internal
controls in these areas.
Based on our review, no other issues came to our attention which
we believed were significant enough to warrant expanding the
scope of this audit.
Although the OIG and GAO have issued audit reports concerning
the Agency's information management systems, neither the OIG
nor GAO have issued any audit reports concerning the accuracy
of EPAYS data, security of OPFs, or any issues involving the
Office of Human Resources.
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
[This page intentionally left blank]
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
CHAPTER 2
OHROS EFFORT IMPROVES ACCURACY OF PERSONNEL INFORMATION
MAINTAINED IN EPAYS, BUT MANAGEMENT CONTROLS ARE NEEDED TO
MAINTAIN ACCURACY
OHROS, since September 1995 and its reorganization on October
1, has been expending a considerable amount of time reviewing
and cleaning up the Official Personnel files (OPFs) and in
making corrections to the personnel information contained in
EPAYS. We found that between November 27, 1995 and
January 31,1996, the OHROS review had reduced the number of
EPAYS personnel information inaccuracies we identified in our
sample from 58 out of 379 (15.3%) to 20 out of 379 (5.3%).
OHROS staff continued reviewing OPFs and entering information
beyond our computer report date of January 31, 1996. We were
told by an Agency official, that before a reduction-in-force would
be fully executed, each employees' OPF will be checked three
times for accuracy, along with a check by the employee.
However, we noted that OHROS apparently viewed the accuracy
of EPAYS and the currency of the OPFs as a low priority.
Although OHROS had conducted at least two reorganizations
devoted to improving customer service and improving the filing
of OPFs, it was not until EPA was faced with a potential RIF
that OHROS begin a comprehensive review of the OPFs and of
the accuracy of the EPAYS information. We found that OHROS
had not identified the accuracy or reliability of EPAYS personnel
information in any of its FMFIA documentation, had not planned
or conducted any quality assurance reviews of the EPAYS
system, and had not assigned responsibility for system accuracy
in any of its position descriptions for Personnel Management
Specialists. We were told by OHROS officials, that the
developing and executing of new procedures would hot take place
until the potential RIF concerns are eliminated.
BACKGROUND As a result of the lack of management control reviews and a
potential reduction-in-force caused by a reported $2.5 billion
(34%) cut by the House of Representatives to the Agency's fiscal
1996 budget, the Agency, in order to prepare for a potential RIF,
expended at least $55,300 in overtime costs and countless hours
during the regular business day in staff time updating OPF
information in EPAYS, correcting errors and omissions, and
updating missing information in the official personnel folders.
The information contained in EPAYS will be used to generate the
-------
Report of the Accuracy of EPA's Personnel mid Payroll System (EPAYS)
El AMF6-11-0005-6100275
Management Control
Reviews of the Accuracy
ofEPAYS
Personnel Information
and the Official
Personnel Files
Not Conducted
retention register, which prioritizes EPA staff based on
competitive level, tenure of employment, veteran's preference,
service computation date, and performance appraisal ratings. We
believe that as a result of the inaccuracies identified in the
EPAYS personnel fields, the Agency would be unable to quickly
and accurately prioritize EPA staff on the retention register.
However, during discussions with OHROS personnel, we were
told that the RIF procedure also requires that all employees on
the retention register would have an additional opportunity to
review their personnel information to verify its accuracy. Also,
as employees left for new employment or retired, new retention
registers would be compiled.
In accordance with the Integrity Act and OMB Circular A-123,
each executive agency must annually evaluate its system of
internal accounting and administrative controls and .report to
Congress and the President on whether its internal control
systems comply with the goals of the Act. If systems do not
comply, the agency head must identify material weaknesses and
present plans for corrective action.
EPA Resources Management Directive 2560 (Internal Control),
section 5 states: All EPA organizations shall develop and
maintain effective systems of internal control over their program
operations and administrative functions. Also, section 4(h) states
that all EPA managers are responsible for operating effective and
efficient systems of internal control. They must also evaluate the
control system periodically and take timely corrective actions on
all identified weaknesses.
We reviewed the fiscal 1993 Office of Human Resources
and Management (OHRM) event cycle documentation
and related annual management control summaries
conducted between fiscal 1993 and 1995. We found that
OHRM had not identified, as an event cycle, reviews of the
OPFs and accuracy of personnel information contained in
EPAYS. We also noted that OHRM had not conducted any
reviews to validate and ensure the accuracy of the data in EPA's
Personnel and Payroll System compared with the information
contained within the Official Personnel Files.
It appears that OHROS considered the accuracy of EPAYS
personnel information to be a low priority. This is based on the
lack of not identifying the accuracy of EPAYS personnel
information, as a potential risk in FMFIA documentation.
8
-------
Report of the Accuracy of EPA'i Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
OHROS Needs to
Implement a Written
Policy on Performance
Ratings Data Entry
Verification
OMB Circular A-123 Revised, dated August 4, 1986, prescribes
policies and procedures to be followed by executive departments
and agencies in establishing, maintaining, evaluating, improving,
and reporting on internal controls in their program and
administrative activities. OMB Circular A-123 Revised, dated
June 21, 1995, updated the 1986 circular,'and defined
management controls as the organization, policies, and
procedures used to reasonably ensure that (1) programs achieve
their intended results; (2) resources are used consistent with
agency missions; (3) programs and resources are protected from
waste, fraud, and mismanagement; (4) laws and regulations are
followed; and (5) reliable and timely information is obtained,
maintained, reported and used for decision making.
Agencies and individual federal managers must take systematic
and proactive measures to (1) develop and implement
appropriate, costreffective management controls for results-
oriented management; (2) assess the adequacy of management
controls in federal programs and operations; (3) identify needed
improvements; (4) take corresponding corrective action; and (5)
report annually on management controls.
We were told by several of the Personnel Management
Specialists that employee performance ratings were processed as
follows. Program Offices submit Personal Appraisals by
December 31. A certification form, containing a list of
individuals within the program office, is included with the
performance appraisals. The certification form is a listing of the
employees in the program office and includes their performance
ratings. Performance ratings listed on the certification are
compared against the actual performance appraisal for accuracy.
The certification is then given to a staff assistant for data entry
into EPAYS of individual performance ratings. The certification
along with the edit report received the next day are returned to
the personnel specialist for verification of correct and accurate
data entry. However, we were told that there was no
requirement to retain the certification. Then the performance
appraisals are given to the file room contractor who places the
appraisals into the individual's official personnel folder.
t
We requested a copy of the policy, but were told it was not in
writing. A written policy provides criteria which can be used in
conducting management control reviews and in measuring
performance during performance appraisal time. We were able
to review a 1994 certification form retained by one personnel
management specialist, and found that 5 out of 148 employees
-------
Report of tho Accuracy of EPA's Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
(3.4%) identified did not have their performance ratings entered
into EPAYS. To establish milestone dates for the timeliness of
data entry, we reviewed two memorandums issued by the
Director of the Policy and Research Division. Pursuant to the
memorandums, performance ratings for 1993 and 1994 should
have been entered by January 31 of the following calendar year.
In addition, several OHROS Personnel Management staff told us
that it was not their responsibility to verify data entry. Our
review of 379 OPFs identified 58 individuals (15.3%) who had
performance appraisals in their official personnel folders, but
those ratings (for fiscal years 1992 through 1994) were not in
EPAYS as of a November 27, 1995 computer report. There was
a total of 75 missing ratings in EPAYS for the 58 individuals as
identified in the chart below.
We requested a second EPAYS profile report for January 31,
1996. We noted that OHROS had corrected 36 of the 75 (48%)
missing ratings. Based on the January report, OHROS reduced
the number of individuals missing information from 58 to 20 out
of 379 or 5.3%.
Fiscal Years
1992
1993
1994
Total
Performance Ratings
Missing As of
11/27/95 '
15
22
38
75
Performance Ratings
Missing As of
1/31/96
10
11
17'
38
Performance Ratings
Corrected
5
11
20
36
OHROS Aware of
need for corrections
On September 18, 1995, OHROS sent a memorandum to
all Headquarters' employees requesting that they review the
attached personnel data profile. OHROS created the profile
based on the information in the Agency's automated personnel
system (EPAYS) and in employees' official personnel files.
Employees were requested to examine all the data elements on
the profile and make any corrections necessary, complete the
certification at the bottom of the profile page and return the
profile sheet (along with any supporting documentation to prove
changes to be made) by September 29, 1995.
One individual who was listed on the November 27, 1995 EPAYS Report was
not listed on the January 31, 1996 Report.
10
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
Although OHROS has significantly reduced the number of
inaccuracies, improvements to its management controls over the
verification of data entry are still needed to ensure future
accuracy. Computer reports are available which could assist
OHROS in identifying potential missing, inaccurate, or
incomplete personnel information. We are concerned that even
though OHROS has conducted a massive effort to review all
headquarters OPFs, little attention has been paid to data entry of
information supplied by headquarters personnel. Delaying data
entry increases the risk that information will not be entered into
EPAYS, resulting in inaccurate employee personnel file
information.
We were told that the development of management controls
would not be considered until all the reviews had been completed
and the system was determined to be accurate. OFF reviews had
started in late September 1995 and were continuing through
March 1996. Inaccuracies identified during our field work
(November - March) were brought to the attention of the OHROS
staff, but controls were still not initiated. We believe that the
instituting of at least controls over the verification and timely data
entry of performance ratings received would reduce the amount
of time devoted to reviewing OPFs again to verify the accuracy
of EPAYS personnel information.
OHROS provided a description of the process to be used when
conducting a reduction-in-force (see Appendix II). Although the
procedure identified will assure that no employee is RIFed
without a thorough review, inaccurate information increases
employee concerns and the cost and amount of time needed to
correct the information and potentially generate a new retention
register.
As a result of not conducting management control reviews,
assigning a low priority to ensuring the accuracy of EPAYS
information, and not having a written policy concerning the
accuracy of data entry, OHROS has had to spend a considerable
amount of staff time and more than $55,000 in overtime to
review more than 6,000 official personnel folders for
headquarters personnel and attempt to improve EPAYS data
accuracy. OHROS is depending on these failsafe procedures to
catch any inaccuracies, and they do not believe the length of time
or cost to attain accuracy is a concern. However, we believe that
the process could be ineffective. For example, if an individual
was incorrectly placed on the retention register based on
11
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS)
EIAMF6-11.0005-6100275
inaccurate performance rating(s), the individual's OPF may or
may not be reviewed by OHROS. OHROS would be reviewing
only the QPFs of individuals who had received a RIF
notification.
OHROS forms
Personnel Operations
Workgroup
RECOMMENDATIONS
After we began our audit, we were told that OHROS had
formed the "personnel operations workgroup" which has been
charged with developing policies and procedures to address the
problem areas identified during the OHROS Official Personnel
Folder (OPF) review.
The Workgroup, formed as a result of the problems found while
OHROS was conducting the OPF review, has developed an
action plan which identifies responsible individual(s) and
determines milestone dates. We were provided a memorandum
which described some of the areas the action plan addresses (see
appendix IV).
Although we received an explanation of the action plan of the
workgroup, we have not received a copy of the formal
management request to form the workgroup, nor a document
which describes the workgroup's mission, goals and objectives.
We are, therefore, not sure whether the workgroup has
management support for potential recommendations. The effect
of the Human Resources Staff not having a formalized policy for
processing performance appraisals, along with the lack of data
entry verification resulted in inconsistent reviews of the accuracy
of performance rating information entered into EPAYS. This has
resulted in the inability of EPAYS to provide management with
an accurate, reliable, and timely RIF report information during
the first half of fiscal 1996.
We recommend that the Acting Assistant Administrator for
Administration and Resources Management:
1. Require semiannual briefings on the status of the
implementation of planned quality assurance activities
until a system is in place and effectively functioning.
•v,
2. Require the workgroup to generate a computer report, as
we did, to identify employees with missing performance
rating information in EPAYS.
12
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) ElAMF6-11-0005-6100275
AGENCY RESPONSE
The agency stated that the Office of Administration and
Resources Management (OARM) will require OHROS to
establish a system of management controls and quality
assurance activities that ensures accuracy of EPAYS data
and conduct a briefing on them prior to the beginning of
Fiscal 1997. Further, that OHROS has completed a 100
percent review and correction of performance rating
information for Fiscal Years 1991 through 1994. The
staff is in the process of reviewing and inputting
performance ratings for Fiscal 1995 into EPAYS. Newly
implemented internal controls will ensure these ratings are
accurate in the data base.
13
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
[TWs page intentionally left blank]
14
-------
Report of the Accuracy of EPA't Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
CHAPTERS
CONTROL OVER OFFICIAL PERSONNEL FOLDERS COULD BE IMPROVED
Over the five months (November 1, 1995 through March 15,
1996) of our review, the OFF Center staff had difficulty in the
timely retrieval of the OPFs for our review. We would receive
only a portion of the OPFs requested and had to continually
request, through the project officer, OPFs not initially provided.
We were aware that the personnel specialists were continually
reviewing the OPFs and attempted to work with the project
officer so as not to disrupt the OPF review process. We were told
repeatedly by the OPF Center staff that numerous folders in our
review sample (37 out of 379, or 9.8%) were out with the
Personnel Management Specialists; and near the completion of
our work, we were told it could take several weeks before we
could obtain the folders. Based on our review, we determined
that the remaining OPFs would not materially effect our audit
objective concerning whether EPAYS provides accurate
information for RIF purposes and decided not to continue to wait
for the OPFs. However, we observed a situation where a
personnel management specialist, who had requested several
OPFs, was told by the OPF Center contractor that the specialist
already had the requested OPFs signed out to her. The specialist
insisted she had returned the folders earlier. Further, during a
discussion with one of the Human Resources Team Directors, we
were told that the Director also had difficulty in obtaining
folders. We were told by one of the OHROS Team Directors,
that OPFs could be rotated among the staff who were responsible
for the review, which could result in delays in obtaining folders
by Agency employees to review their folders and by the OIG
auditors in conducting this audit.
Although the OPF Center had developed control procedures over
the removal and return of OPFs, the inability of die personnel
management specialist to, within a reasonable time period, return
OPFs causes us some concern over the location of the OPFs
within the individual human resources teams. As a result of the
ongoing OPF review, the time constraints which OHROS staff
was under, and the findings we had already discussed with the
staff, we elected not to require OHROS to provide the 37 folders.
BACKGROUND Each Human Resources Staff Team is responsible for servicing
specific program offices. Within each team several personnel
specialists are responsible for reviewing personnel actions and
15
-------
Report of the Accuracy of EPA'8 Personnel and Payroll System (EPAYS) Ei AMF6-1 i-0005-6100275
data entry. During the time of our review, OHROS was
conducting a 100 percent review of the OPFs. Their review
entailed verifying information contained in the OFF against
information contained in various personnel files in EPAYS. If
additional information was needed to be obtained and placed in
the individual's OFF, the personnel management specialist would
contact the particular individual. Folders would then sometimes
be held by the personnel management specialist until the
information requested from the individual was received and then
placed in the OFF. We observed several personnel management
specialists obtaining numerous OPFs from OFF Central files for
this and other purposes.
The Office of Human Resources Management and Organizational
Services (OHROS) is responsible for the management and control
of all Official Personnel Files (OFF) for EPA employees serviced
by the Headquarters' Human Resources Staff. OPFs are the
official repository of the records, reports of personnel actions,
and the documents and papers required concerning these actions
effected during an employee's Federal service. These records
provide the basic source of data about a person's Federal
employment while in the service and after separation.
OHROS has custodial responsibilities for OPFs and is responsible
for ensuring that they maintain them according to the Office of
Personnel Management (OPM) and EPA regulations and policies.
These responsibilities include:
• Establishing personnel folders and ensuring that
documents are filed appropriately and in order.
• Filing and refiling documents into OPFs following
guidelines established by EPA and OPM.
• Updating labels on OPFs following standards established
by EPA.
• Providing only authorized Agency staff access to the
OPFs.
• Completing request to review, copy, charge out/in folders
to authorized personnel.
• Retiring or transferring OPFs when an employee
separates.
16
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
OPM Delegation
CONCLUSION
On September 6, 1995, the Procurement Operations Branch
issued a delivery order against an existing contract to provide
records management support staff so that the demands for
increased service can be met and the timeliness of those services
can be improved, that employees can be assured that documents
are filed in their folder in a timely and accurate manner, and that
authorized personnel can charge out/in personnel folders in an
efficient and timely manner.
The Office of Personnel Management owns the personnel folders
and their contents. 0PM has delegated to the agencies the
authority to maintain these personnel folders. The OPF is a file
containing records and documents related to civilian employment
under title 5 of the U.S. Code.
Agency staff have various uses for OPFs including screening
qualifications, eligibility, and employee's rights and benefits
under pertinent laws and regulations governing Federal
employment computing length of service, and other information
needed to provide a full range of human resources services.
These records may be used for personnel research and individual
employees may also review their OPFs. Therefore, the potential
for OPFs to be misplaced, misfiled, or lost is a cause for
concern.
While we understand that the personnel management specialists
were conducting an intensive review and attempting to complete
the review by December 1st, we are concerned about the security
and possible misplacement of OPFs. By holding OPFs until the
full review, and any requested information, has been received,
there is ah increased risk that an OPF may be misplaced and
require additional time to locate when requested by the OPF
Center.
RECOMMENDATION
AGENCY COMMENTS
We recommend that the Acting Assistant Administrator for
Administration and Resources Management request that the
OHROS Team Directors work with their staff to ensure that
folders being reviewed for completeness and accuracy be returned
to the OPF Center as timely as possible.
The Agency stated that OHROS Human Resources Staff
Directors recognize the importance of returning OPFs to the
Center as soon as possible and have stressed this with their staffs.
Additionally, OHROS is initiating a bar-code tracking system for
OPFs that will notify personnel management specialists who have
17
-------
Report of the Accuracy of EPA'a Personnel mid Payroll System (EPAYS) El AMF6-114)005-6100275
exceeded their allotted time for retaining OPFs. Human
Resources Staff Directors will be provided the same information
to ensure the files are returned to the Center in a timely manner.
This system will be in place by the end of September 1996.
18
-------
Report of the Accuracy of EPA't Personnel and Payroll System (EPA YS)
CHAPTER4
El AMF6-11-0005-6100275
EPAYS SYSTEM SECURITY COULD BE COMPROMISED
Lack of System
Security
We identified that 52.6% (41 out of 78) personnel management
specialists have a supervisory data entry capability. This
capability permits the user to enter and modify information
contained in the personnel data base. We asked about whether
these specialists could access their own files and make changes to
those files. The previous acting Chief of the Systems Support
Staff, said that he knew of no protocol in TAPP/EPAYS which
would prevent an employee with system access from entering
personnel, payroll, or time and attendance (T&A) actions on
themselves. We also requested the same information from the
Chief of the Client Support Branch of OARM's Enterprise
Systems Division, with the same result.
An individual with the ability to modify their own files could
result in the individual making changes to specific data fields
giving them a competitive advantage during a RIF. This ability
is also a weakness in system controls.
We did not identify data entry activity which would have caused
additional audit fieldwork, but the potential for unauthorized
activity requires that a protocol be developed which would
prohibit an individual's access to their own personnel, payroll or
time and attendance files. We did not review the activities of the
personnel specialists in the regional offices; however, we
understand that they have the capability of entering both payroll
and personnel information.
BACKGROUND
OMB Circular No. A-130, Transmittal 3, dated February 8,
1996, requires that agencies implement and maintain a computer
systems security program, including the preparation of policies,
standards, and procedures. The circular also implies that
agencies:
Establish a management control process to assure that
appropriate administrative, physical, and technical
safeguards are incorporated into all new applications, and
into significant modifications to existing applications.
19
-------
Report of the Accuracy of EPA'» Personnel MM! Payroll System (EPA YS> El AMF6-11-0005-6100275
Conduct periodic audits or reviews of sensitive
applications and recertify the adequacy of security
safeguards.
Establish and manage personnel security policies and
procedures to assure an adequate level of security for
Federal automated'information systems. Such policies
and procedures shall include requirements for screening
all individuals participating in the design, development,
operation, or maintenance of sensitive applications as well
as those having access to sensitive data.
RECOMMENDATION We recommend that the Acting Assistant Administrator for
Administration and Resources Management require that an
automated control be added to EPAYS to prevent an individual
from accessing their own file and making changes to that file.
AGENCY COMMENTS OHROS will work with the Office of Information Resources
Management (OIRM) to explore the feasibility of incorporating
. such a control into the EPAYS system. The analysis will be
completed by the end of September 1996.
20
-------
Report of the Accuracy of EPA'» Personnel and Payroll System CEP AYS)
E1AMF6-11-0005-6100275
Appendix I
Page 1 of 1
ACRONYMS
ASD ADMINISTRATIVE SYSTEMS DIVISION
ASSB APPLICATIONS SOFTWARE BRANCH
DOPS DEPARTMENTAL INTEGRATED PERSONAL SERVICES SYSTEM
EOD ENTRY ON DUTY
EPA ENVIRONMENTAL PROTECTION AGENCY
EPAYS EPA'S PAYROLL AND PERSONNEL SYSTEM
FMFIA FEDERAL MANAGER'S FINANCIAL INTEGRITY ACT
I/MCR INTERNAL/MANAGEMENT CONTROL REVIEWS
MCP MANAGEMENT CONTROL PLANS
OAR OFFICE OF AIR AND RADIATION
OARM OFFICE OF ADMINISTRATION AND RESOURCES MANAGEMENT
OECA OFFICE OF ENFORCEMENT AND COMPLIANCE ASSURANCE
OGC OFFICE OF GENERAL COUNSEL
OHRM OFFICE OF HUMAN RESOURCES MANAGEMENT
OHROS OFFICE OF HUMAN RESOURCES MANAGEMENT AND
ORGANIZATIONAL SERVICES
OIA OFFICE OF INTERNATIONAL ACTIVITIES
OIG OFFICE OF INSPECTOR GENERAL
OIRM OFFICE OF INFORMATION RESOURCES MANAGEMENT
OPF OFFICIAL PERSONNEL FILES
OPFC OFFICIAL PERSONNEL FOLDERS CENTER
OPM OFFICE OF PERSONNEL MANAGEMENT
OPPE OFFICE POLICY, PLANNING AND EVALUATION
OPPTS OFFICE OF PREVENTION, PESTICIDES, AND TOXIC SUBSTANCES
ORD OFFICE OF RESEARCH DEVELOPMENT
OSWER OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
OW OFFICE OF WATER
RIF REDUCTION-IN-FORCE
RTP RESEARCH TRIANGLE PARK, NORTH CAROLINA
T&A TIME AND ATTENDANCE
TAP? TIME AND ATTENDANCE PAYROLL
WFMC WASHINGTON FINANCIAL MANAGEMENT CENTER
21
-------
Report of the Accuracy of EPA'g Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
Appendix n
. Page 1 of 2
OVERVIEW OF A REDUCTION-IN-FORCE
OHROS provided the following as the process used to conduct
a Reduction-in-Force:
Set the ground rules for the RIF (use of vacancies, cut-off
date for performance ratings, waivers, etc.).
Review-recheck-have ready references available (current
RIF regulations, pay setting guides, severance pay
formula, representative rate charts, pay tables, etc.)
Establish-review-rccheck competitive level definitions to
be sure they are complete and correct.
Establish the effective date of the RIF.
Verify that each employee is in the correct competitive
level.
Have OPF's for affected orgamzation(s) available and
complete a review of pertinent RIF- related information
(correctness of employees title, series, grade, service
computation date, retention sub-group, last three
performance ratings, positions held, experience, training,
etc.).
Encourage/provide for employees review of "personal"
information that is used in the RIF process (service
computation date, performance ratings, experience on
record review of all information in their OFF).
Review employee job descriptions for accuracy.
Prepare retention registers for the organizations^)
affected. Review and recheck the information.
Identify positions to be abolished and identify affected
employees.
Review qualifications of affected employees.
22
-------
Report of the Accuracy of EPA't Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
Appendix H
Page 2 of 2
In using an automated RIF processing system, input necessary
information. Generate reports, review and correct data elements
as necessary.
AutoRIF is an automated RIF processing application that EPA
will be using. It uses data from EPAYS and information input
from the OPF to assist the human resources office (HRO) in
processing RIF actions.
AutoRIF assists the HRO to keep track of employees affected by
the RIF, the actions taken, qualification determinations made etc.
AutoRIF processes the RIF, develops retention registers,
processes employee's bump and retreat lights, and generates RIF
letters.
AutoRIF processes the additional iterations that may be necessary
in conducting the RIF based on employees resigning, retiring
during the course of the RIF.
The RIF is re-run and new offers are made to employees as
other employees decline RIF offers, resign from the Agency,
retire, etc.
Check and re-check the automated decisions made through
AutoRIF,
Re-check displaced employees data and qualifications for
placement.
Issue RIF notices to employees. Explain RIF decisions to
employees.
Issue updated RIF notices to employees as a result of
additional iterations of the RIF process (based on
employees resigning, retiring, declining RIF offers).
Provide counseling to interested employees (career, out
placement, retirement, etc.)
Provide out placement and job referral services.
Address appeals.
23
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPA YS) El AMF6-11-0005-6100275
Appendix in
Page 1 of 2
METHODOLOGY
To determine our sample size of OPFs to review, based on the
objectives of our review and the impact of a potential RIP on the
Agency, we wanted a high confidence level in which to assure
ourselves of the accuracy of the information to be used in
conducting the RIF. We, therefore, selected our sample size by
using a 95 percent confidence level and a maximum error rate of
5 percent. This resulted in a sample of 363 OPFs based on 6,306
individuals. The 6,306 universe of individuals was determined
by reviewing a computer listing of headquarters employees
serviced by OHROS as of October 14, 1995. We initially selected
every 15th name on the listing for our OPF review.
In addition, we also reviewed a November 27, 1995 computer
report and identified 910 headquarters employees who were
missing either one or more performance ratings (indicated by an
"x" in the year missing a rating), and who had been at EPA since
the 1991 rating period. From the November 27th list, we
judgementally selected an additional 53 headquarters employees
for our review.
We anticipated using the OPF sample to project the results of the
testing to the universe as a whole. However, as we were
requesting the project officer to have the contractor pull our
selected OPFs, we were told that the OIG's Financial Audit
Division (FAD) had already started to pull OPFs as part of their
Chief Financial Officers (CFO) Audit. We were asked by the
project officer if we could use the OPFs being pulled for FAD as
part of our sample, which would help OHROS by reducing the
amount of time needed to search for and pull some of our
requested OPFs.
In order to work cooperatively with OHROS and use OPFs
already obtained for another OIG audit, we agreed to review 64
of the OPFs selected by FAD as part of our OPF sample. FAD's
OPF sample selection technique was based on dollar-unit
sampling which is a form of variable sampling. Our initial
sampling method was based on attribute sampling. By combining
these two methods of sampling, we are unable to statistically
project our testing on the universe as a whole. Considering the
enormous pressure OHROS was under to ready EPAYS for a RIF
and our desire to work cooperatively with them, we believe this
24
-------
Report of the Accuracy of EPA'i Personnel and Payroll System (HPAYS)
El AMF6-11-0005-6100275
Appendix III
Page 2 of 2
modification to sampling methodology was justified. The results
of our sample are representative of the accuracy of EPAYS,
though they are not statistically projectable.
We analyzed each OPF to determine if the information contained
in the file was entered into EPAYS. Our universe is shown below
in table 1.
^S:-S-SS;--<>i|^*':^-.. ;5S:';- :'•
11 by Program Office •^•-- • '
IKr. ' :: ; . Table 1 " :"""
AAShip
100-
Administration
210 - OPPE
220 - OECA
230 - OGC
240 - OIG
260 - OIA
300 - OARM
400 -OW
500 - OSWER
600 - Air Radiation
700 - OPPTS
800 - ORD
Total
Universe
750
301
600
180
179
67
956
557
632
500
1,295
289
6,306
25
-------
P«*»onnel «nd P^U System REPAYS) El AMF6-11-0005 4100275
Appendix IV
Page 1 of 2
APR I 9 1996
MEMORANDUM
SUBJECT: OIG Review — Accuracy of EPAYS Payroll and
Personnel System Data
Dave Boyce
During your discussion with Daiva Balkus and the Human
Resources Staff Directors regarding your review of the accuracy
of EPAYS oavroll and personnel system data, we agreed to forward
you"'additional ififoritiation "regaTratiTg th"e~ CHfcOS Personnel
Operations Workgroup.
«
The following information is submitted:
o The Personnel Operations Workgroup, comprised of senior
level personnel specialists from each Human Resources Staff,
was formed to analyze personnel data issues identified
during the OHROS-initiated review of Official Personnel
Folders (OPFs) and to determine a strategy to resolve these
issues, it was recognized that OHROS needed to institute a
comprehensive, systemic approach to assuring personnel data
quality. The Workgroup developed an action plan which
identified responsible individual(s) and determined
milestone dates. Currently, th« action plan is being
implemented.
o The action plan addresses the following areas:
1. Guidance/Tools
Assure all Staff members have up-to-date guidance
and tools.
Provide general overview and specific in-house
training sessions regarding the guidance and
tools.
Implement LAN based support systems for guidance
and tools to facilitate Staff member use, i.e.,
competitive level definitions and 'codes and
service computation date calculation software.
26
-------
Report of the Accuracy of EPA'a Personnel and Payroll System (EPAYS) _ El AMF6-1 1-0005-6100275
Appendix IV
-2- Page 2 of 2
2. Quality Review/Control
Conduct test of a Coding Guide for Personnel
Actions used by Team Vegas to determine
applicability to Human Resources Staff functions
Ensure the accuracy of data and that OPFs remain
current by conducting random samplings of OPFs and
internal reviews of TAPP/EPAYS data input.
Require a second-level review on all personnel
actions being processed and a signature by an
authorized Staff member on all SF~50s.
Develop written standard operating -procedures
(SOPs) for the operations handled by the Human
Resources Staffs, including retention of
performance rating and award certification
reports.
3. Long-Term System Controls
— Work with the Office of Information Resources
Management (OIRM) to improve the personnel action
edit process and the. print quality for SF-50s.
— Develop formal systems for improvement of internal
controls, e.g., annual sampling of OFF data and
evaluations of specific personnel processes and
personnel action processing,
Engage in streamlining and process improvement
aUtoaation of Personnel systems,
Should you have any questions, please call me on 260-2012.
27
-------
Report of tho Accuracy of EPA'* Personnel and Payroll System (EPAYS)
El AMF6-11-0005-6100275
Appendix V
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY page j Qf 3
WASHINGTON, D.C. 20460
JUL 24(996
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT:
FROM:
TO:
DjtfrVReport aCChfe^ccuracy^of EPA's PS
y$tot>
sachowitz
Acting Assistant Administrator
Michael D. Simmons
Deputy Assistant Inspector General
For Internal and Performance Audits (2421)
Personnel System (EPAYS)
This is in response to your draft audit report regarding the accuracy of EPA's Payroll and
Personnel System (EPAYS\ The Office of Administration and Resources Management (OARM)
agrees with your principal f ndings, and we have every intention of forcefully dealing with your
recommendations. In fact, he Office of Human Resources and Organizational Services
(OHROS) has gone beyond your recommendations to ensure the accuracy of EPAYS data.
Specifically, the following corrective actions have been taken or planned based on the
report's recommendations:
1. Require semiannual briefings on the status of the implementation of planned quality
assurance activities until a system is in place and effectively functioning.
Planned Corrective Action: OARM will require OHROS to establish a system of
management controls and quality assurance activities that ensures accuracy of EPAYS
data and conduct a briefing on them prior to the beginning of Fiscal 1997.
2. Require the workgroup to generate a computer report, as the OIG did, to identify
employees with missing performance rating information in EPAYS.
Corrective Action: OHROS has completed a 100 percent review and correction of
performance rating information for Fiscal Years 1991 through 1994. The staff is in the
process of reviewing and inputting performance ratings for Fiscal 1995 into EPAYS.
Newly implemented intenal controls, as described below, will ensure these ratings are
accurate in the data base.
28
-------
Report of the Accuracy of EPA's Personnel and Payroll System (EPAYS) El AMF6-1 l-OOOS-6100275
Appendix V
Page 2 of 3
-2-
3. Request that the OHROS Team Directors work with their staff to ensure that folders
being reviewed for completeness and accuracy be returned to the OFF Center as timely as
possible.
Corrective Action: The OHROS Human Resources Staff Directors recognize the
importance of returning OPFs to the Center as soon as possible and have stressed this
with their staffs. Additionally, OHROS is initiating a bar-code tracking system for OPFs
that will notify personnel management specialists who have exceeded their allotted time
for retaining OPFs. Human Resources Staff Directors will be provided the same
information to ensure the files are returned to the Center in a timely manner. This
system will be in place by the end of September 1996.
4. Require that an automated control be added to EPAYS to prevent an individual from
accessing their own file and making changes to that file.
Planned Corrective Action: OHROS will work with the Office of Information
Resources Management (OIRM) to. explore the feasibility of incorporating such a control
into the EPAYS system. The analysis will be completed by the end of September 1996 '
In addition to our responses to your helpful recommendations, OHROS has gone well
beyond them to ensure the accuracy of EPAYS data:
-In February 1996 OHROS issued an updated profile to all Headquarters
employees asking them to again review the accuracy of their personal data elements.
OHROS addressed all employees' remaining concerns regarding this information.
-OHROS has implemented an effective Standing Operating Procedure (SOP) that
requires a second-level review of all personnel transactions prior to inputting into
EPAYS. To ensure accountability, personnel management specialists are signing their
SF-50s, Notification of Personnel Action.
-Fiscal 1995 Performance Ratings are being 100% inventoried, checked for
accuracy, input into EPAYS, and re-checked prior to filing.
-Competitive Levels have been established and assigned for all Headquarters
employees. We have implemented an internal control system that requires prior approval
•of the Competitive Level Committee of any new competitive level.
-Standard Operating Procedures will be developed by the end of September 1996
to ensure consistency and compliance with appropriate regulations.
29 .
-------
Report of the Accuracy of EPA'a Personnel and Payroll System (EPAYS) El AMF6-11-0005-6100275
Appendix V
Page 3 of 3
.3-
Again, we are pleased to have an outside evaluation of the accuracy of EPAYS data. We
are well aware of the seriousness of this information and its effect on the careers of EPA
employees. OHROS is putting forth a considerable amount of effort to ensure the accuracy of
the data, and I have complete confidence they will be successful.
Should you have any questions about this response, please contact David J. O'Connor,
Director, Office of Human Resources and Organizational Services, at 260-4467,
30
-------
Report of the Accuracy of EPA'» Personnel and Payroll System (EPAYS) _ El AMF6-1 1-0005-6100275
Appendix VI
Page 1 of 1
IWSTRfRf mON
Office of Inspector General
Inspector General (2410)
Deputy Inspector General (2410)
Headquarters Office
Acting Assistant Administrator for
Administration and Resources Management (3101)
Director, Office of Human Resources and Organizational Services (3610)
Agency Follow-up Coordinator, Office of Administration
and Resources Management, Attn: Director, Program and
Policy Coordinator Office (3 1 02)
Headquarters Library (3304)
Regional Offices
Regional Administrator, Region 1
Regional Administrator, Region 2
Regional Administrator, Region 3
Regional Administrator, Region 4
Regional Administrator, Region 5
Regional Administrator, Region 6
Regional Administrator, Region 7
Regional Administrator, Region 8
Regional Administrator, Region 9
Regional Administrator, Region 10
31
-------
------- |