i o
_
V ^
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Spending Taxpayer Dollars
Time and Attendance Fraud
Not Identified for Employees
on Extended Absence, But
Matters of Concern Brought
to EPA's Attention
Report No. 15-P-0167
June 15, 2015

-------
Report Contributors:	Angela Bennett
Jean Bloom
Safiya Chambers
Kevin Collins
Lisa McCowan
Leah Nikaidoh
Darren Schorer
Lei a Wong
Abbreviations
AWL	Alternate Work Location
EPA	U.S. Environmental Protection Agency
IGEMS	Inspector General Enterprise Management System
OCFO	Office of the Chief Financial Officer
OEI	Office of Environmental Information
OIG	Office of Inspector General
RAC	Reasonable Accommodation
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
More information at www.epa.gov/oiq/hotline.html.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (241OT)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oig
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

-------
tftD STAf.
U.S. Environmental Protection Agency	15-P-0167
Office of Inspector General	June 15 2015
I
VPR0^°
At a Glance
Why We Did This Review
On August 27, 2013, a member
of the Senate Committee on
Environment and Public Works
requested that the
U.S. Environmental Protection
Agency (EPA), Office of
Inspector General (OIG),
initiate work in connection with
fraud committed by John C.
Beale, a former Senior Policy
Advisor with the EPA's Office of
Air and Radiation. One of the
areas we evaluated was the
EPA's time and attendance
process. This report addresses
potential time and attendance
fraud at the EPA in connection
with employees who received
salary payments while
appearing to be on extended
absence from their duties.
This report addresses the
following EPA goal or
cross-agency strategy:
• Embracing EPA as a high-
performing organization.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2015/
20150615-15-P-0167.pdf
Time and Attendance Fraud Not Identified for
Employees on Extended Absence, But Matters
of Concern Brought to EPA's Attention
We identified concerns over the
accuracy of time charges, use
of a personal computer, and
safety of telework space for
reasonable accommodations.
What We Found
Our audit did not identify any instances of
time and attendance fraud for employees
receiving salary payments while absent from
their duties for an extended period of time.
All employees interviewed provided evidence
of login or had a valid explanation for not
logging in to the agency's email system. We did not test for employees absent from
their duties for less than 4 consecutive weeks; if our sample period was reduced to
less than 4 consecutive weeks, additional issues may have been identified.
We identified matters of concern that warrant the agency's attention. These
matters pertain to:
•	Accuracy of time charges in the PeoplePlus timekeeping system.
•	Use of a personal computer to conduct official work.
•	Safety of reasonable accommodation employees on fulltime telework.
We did not fully evaluate these matters because they are outside the scope of this
audit. However, we are bringing these matters to the agency's attention due to the
frequency of occurrences. In our professional judgment, the number of such
occurrences is significant. We are bringing this to the agency's attention so that it
can address the specific issues noted as appropriate.
Recommendation and Planned Agency Corrective Actions
We recommend that the Deputy Administrator address the concerns regarding the
accuracy of time charges, use of personal computers for official work, and safety of
telework space for reasonable accommodation employees. The agency concurred,
has corrected the timekeeping errors, and is updating its policies and procedures
to address the remaining matters.
Noteworthy Achievements
In response to our December 2013 early warning report on Beale, the agency
identified corrective measures taken and planned regarding time and attendance.
These measures included generating additional payroll reports for management
review, conducting quarterly reviews and following up on employees who failed to
enter their time three pay periods during the quarter, removing the group
approval option in PeoplePlus, and amending the agency's time and attendance
policy to eliminate system-generated default pay and mass approval processes.

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.20460
THE INSPECTOR GENERAL
June 15,2015
MEMORANDUM
SUBJECT: Time and Attendance Fraud Not Identified for Employees on Extended Absence,
But Matters of Concern Brought to EPA's Attention
Report No. 15-P-0167
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe problems the
OIG has identified and corrective actions the OIG recommends. This report represents the opinion of the
OIG and does not necessarily represent the final EPA position. In accordance with established audit-
resolution procedures, EPA managers will make final determinations on matters in this report.
Action Required
In response to our discussion document, the agency provided an intended corrective actions plan that
addresses the recommendation and establishes planned completion dates. Therefore, a response to the
final report is not required. The agency should track unimplemented corrective actions in the
Management Audit Tracking System.
FROM: Arthur A. Elkins Jr.
TO:
A. Stanley Meiburg, Acting Deputy Administrator
This report will be available at http://www.epa.gov/oig.

-------
Time and Attendance Fraud Not Identified
for Employees on Extended Absence,
But Matters of Concern Brought to EPA's Attention
15-P-0167
Table of C
Purpose		1
Background		1
Responsible Offices		1
Other OIG Audits		2
Noteworthy Achievements		2
Scope and Methodology		3
Results of Review		4
Time and Attendance Fraud Not Identified for Employees on
Extended Absence		4
Additional Matters of Concern		4
Accuracy of Time Charges in PeoplePlus		5
Use of Personal Computer to Conduct Official Work		5
Safety of Employees on Reasonable Accommodation Telework		6
Recommendation		7
Agency Comments and OIG Evaluation		8
Status of Recommendations and Potential Monetary Benefits		9
Appendices
A Prior OIG Reports Related to Time and Attendance 		10
B Sampling Methodology 		11
C Agency Response to Discussion Draft 		12
D Distribution 		15

-------
Purpose
We conducted this audit to identify potential time and attendance fraud at the
U.S. Environmental Protection Agency (EPA) in connection with employees who
received salary payments while on extended absence from their duties.
Background
On September 27, 2013, John C. Beale, a former Senior Policy Advisor with the
EPA's Office of Air and Radiation, pleaded guilty to a federal charge stemming
from a long-running scheme in which he defrauded the government in salary
payments and other costs. From January 2000 to April 2013, Beale was absent from
his duties at the EPA for about 2V2 years but continued to receive his salary and
benefits. On December 11, 2013, the EPA Office of Inspector General (OIG) issued
an Early Warning Report: Internal Controls and Management Actions Concerning
John C. Beale Pay Issues. The OIG report disclosed that one of the factors that
facilitated Beale's fraud was the agency's lack of adequate controls over
timekeeping. As a result, we initiated this audit to identify similar potential time
and attendance fraud.
The EPA uses PeoplePlus as its official payroll system for reporting employee
time and attendance. Employees are required to prepare biweekly time cards in
PeoplePlus and attest to the accuracy of the data on the time cards. If employees
cannot input their time, the timekeeper or approving official may prepare their
time cards. Supervisors and managers are responsible for approving an
employee's time once it has been attested or verified.
Employees must have an EPA-issued Active Directory Local Area Network user
identification to log into the agency's computer network. Log-in authentication
methods vary depending on the system. Access to PeoplePlus is authenticated
through Novell Identity Vault and access to the agency's email system Outlook is
through Active Directory. The agency's Active Directory database tracks all
Outlook authentication, except for access through mobile phones, for
approximately 6 months.
Responsible Offices
The EPA's Office of the Chief Financial Officer (OCFO) is responsible for
formulating and providing time and attendance reporting policies. In addition,
OCFO is responsible for the PeoplePlus system, including:
•	Enforcing internal control policies and standards.
•	Monitoring records to confirm that appropriate individuals are entering,
attesting, submitting, verifying and approving time worked.
•	Providing systems administration.
•	Coordinating training.
15-P-0167
1

-------
The Office of Human Resources within the Office of Administration and
Resources Management is responsible for providing policies and guidance on
employment, pay and leave administration, and employee conduct. The Office of
Human Resources also maintains data on employment and pay status.
The Office of Environmental Information (OEI) is responsible for maintaining the
Active Directory database. OEI is also the agency's focal point for collecting,
managing, providing and safeguarding environmental information. This includes
establishing policies for the agency's information security and records
management and overseeing the implementation of these policies.
Other OIG Audits
The OIG recently issued audit reports related to other aspects of time and
attendance. These reports pertain to EPA employees on administrative leave, OIG
compliance with its internal time and attendance reporting requirements, and OIG
compliance with overtime polices. These reports are discussed in Appendix A.
Noteworthy Achievements
In response to our December 2013 early warning report on Beale, the agency
identified corrective measures taken and planned regarding time and attendance.1
These corrective measures include:
•	Generating reports each pay period to identify and follow up on instances
where the employee's time was not entered by the employee or his/her
timekeeper, or were not approved by his/her supervisor or approver.
•	Conducting quarterly reviews and following up on employees who failed
to enter their time three pay periods during the quarter, and those instances
where the time was approved by someone other than the employees' direct
supervisors more than three times during the quarter.
•	Removing the group approval option from PeoplePlus and requiring
managers to approve each time card individually.
•	Amending the agency's time and attendance policy to eliminate system-
generated default pay and mass approval processes. The revised policy
was implemented in June 2014 with the migration to the EPA's new
payroll service provider—the Interior Business Center—which is a
division of the U.S. Department of the Interior.
The OIG has not audited the above corrective measures reported by the agency;
therefore, we are unable to provide, and we do not provide, any conclusions or
opinions regarding the effectiveness of these corrective measures.
1 Report of Evaluation and Corrective Actions, dated December 5, 2013, issued by former Deputy Administrator
Bob Perciasepe to the OIG.
15-P-0167
2

-------
Scope and Methodology
We conducted this audit from November 5, 2013, to March 20, 2015, in
accordance with generally accepted government auditing standards issued by the
Comptroller General of the United States. Those standards require that we plan
and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objective.
We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
To assess the risk of employees receiving salary payments while absent from their
duties, we evaluated the agency's time and attendance policies. We also discussed
the controls for time card review and approval with agency officials. Based on our
evaluation and discussion, the controls over time and attendance vary depending
on the time card approver. The approvers are usually at the supervisor or manager
level. Each approver would have at least one alternate approver and a timekeeper.
The EPA estimated that it has more than 3,300 supervisors, managers and
timekeepers. Because of the large number of control points and lack of
consistency among time card approvers, testing of the individual controls would
be cost prohibitive and ineffective for projecting results. As a result, we decided
to base our conclusions on substantive testing rather than trying to test the varying
internal controls; we designed a substantive test to cover the maximum assumed
control risk.
We selected two sample periods for testing—November 2013 and May 2014. Each
sample period represents two consecutive pay periods, or 4 weeks. For each sample
period, we compared employees who received salary payments to those who
logged into the agency's email system—Outlook—at least once. We identified the
employees receiving salary payments from the agency's accounting system—
Compass Data Warehouse. To identify the employees who logged into Outlook, we
used the Active Directory login data and computer user identification provided by
OEI. Based on the comparison, we identified the initial exceptions for follow-up.
We then used a multi-phased process to identify and eliminate any false exceptions
(i.e., exceptions that could be justified or explained). We interviewed
approximately 54 percent of the remaining employees to determine whether they
could provide evidence that they logged into the agency's systems, or an
explanation for not logging in. Details of our sampling methodology are in
Appendix B.
The purpose of this audit was to identify potential time and attendance fraud at the
EPA where employees may have received salary payments while on extended
absence from their duties. We did not audit the agency's overall time and
attendance system or payroll system and the related controls. As a result, we are
unable to provide, and we do not provide, any conclusions or opinions regarding
the agency's internal controls over time and attendance and payroll.
15-P-0167
3

-------
Results of Review
Time and Attendance Fraud Not Identified for Employees on
Extended Absence
Our audit did not identify any instances of time and attendance fraud for employees
receiving salary payments while absent from their duties for an extended period of
time. All employees interviewed provided evidence of login or had a valid
explanation for not logging into the agency's email system.
We interviewed 63 employees, of which 11 did not log into the network during our
sample periods. One of the 11 employees chose to not log into the system unless
necessary and he did not access the network during one of our sample periods. The
remaining 10 employees were on extended sick leave, on temporary duty through
Intergovernmental Personnel Action, or unable to access the system.
The remaining 52 employees were false positives. Five of the employees came up
as exceptions because their user names changed, and we confirmed that the
employees had logged into the network under their prior user names. Data obtained
during interviews show that the remaining 47 employees also logged into the
network and accessed Outlook.
We did not test for employees who were absent from their duties for less than 4
consecutive weeks; if our sample period was reduced to less than 4 consecutive
weeks, additional issues may have been identified.
Additional Matters of Concern
We identified additional matters of concern that warrant the agency's attention.
These matters pertain to the:
•	Accuracy of time charges in PeoplePlus.
•	Use of a personal computer to conduct official work.
•	Safety of reasonable accommodation (RAC) employees on fulltime telework.
We did not fully evaluate these matters because they are outside the scope of this
audit. However, we are bringing these matters to the agency's attention due to the
frequency of occurrences. In our professional judgment, the number of such
occurrences (11 percent, or seven occurrences of the total sample size of 63) is
significant. We are bringing this to the agency's attention so that it can address the
specific issues noted as appropriate.
15-P-0167
4

-------
Accuracy of Time Charges in PeoplePlus
Of the 63 employees interviewed, we identified three with a time card error. The
three employees were on extended leave. However, the approved time cards
showed the employees working regular hours, resulting in an overstatement of the
employees' leave balances. In all three cases, the time cards were prepared by
someone other than the employee.
One of the errors was detected by the employee upon her return from extended
sick leave. The error was for the pay period ended May 17, 2014. The employee
initiated a request for correction and the leave balance was corrected during the pay
period ended September 6, 2014. The remaining two errors—one each in Region 5
and Region 9—were for the pay period ended November 30, 2013. The OIG
notified agency officials in December 2014 and January 2015, respectively, and
management officials took actions to correct the errors. In addition, Region 9
management issued new standard operating procedures to ensure similar errors
would be detected and prevented in the future. The new standard operating
procedures outline steps for the timekeeper to verify time card entries and monitor
employee corrections.
Use of Personal Computer to Conduct Official Work
One of the interviewed employees chose to use his personal computer and tablet to
conduct official work. The employee did not use his EPA-issued computer even
when working in the office; the employee connected to the EPA network using his
personal computer and/or tablet. His work, including any documents downloaded
from the network, were stored in his personal computer and/or tablet. The
employee emailed his work products to his supervisor from his personal devices
using a personal email account. To meet records management requirements, the
employee copied the emails to his work email account.
According to the agency's Information Security - Interim Access Control
Procedures V3.2, dated July 13, 2012, all non-EPA mobile devices are prohibited
from connecting to an EPA network unless the device has been approved, scanned
and inspected. Mobile devices include portable computing and communications
devices with information storage capability, such as notebook/tablet/laptop
computers and personal digital assistants. The EPA's Mobile Computing Policy:
6.1 Mobile Computing Requirements states that EPA employees or other users who
are granted permission to use the EPA's network must use government-furnished
information management and technology solutions to access the EPA's network
outside of the EPA's secured physical location, and states that no waivers will be
accepted from the requirements of this policy.
Based on our review of the two policies, there appears to be a conflict regarding the
use of personal computers for conducting EPA work. The Information Security
Procedures appear to allow the use of a non-EPA device as long as the non-EPA
device has been properly approved, scanned and encrypted. However, the Mobile
15-P-0167
5

-------
Computing Policy requires employees to use government-furnished devices when
working remotely.
The agency explained that the two policies do not conflict. Both policies allow the
employee to either use EPA-furnished equipment to directly access the EPA
network, or use non-EPA equipment to connect to the resources on the EPA
network through an EPA technology solution (such as the EPA's remote access
solution). Employees are not allowed to directly access the EPA network using
personal devices. The agency stated that the Access Control Procedure is in the
process of being revised to mirror the language of the Mobile Computing Policy.
Safety of Employees on Reasonable Accommodation Telework
Of the 63 employees interviewed, the EPA had approved seven employees for
fulltime RAC telework. We conducted interviews with these employees at their
residences in the same manner and for the same purpose as those conducted with
non-RAC employees at their EPA offices.
For three of the seven employees, we observed potentially unsafe conditions within
the employee's work space and general work environment. We observed extremely
cluttered and poorly lit work spaces, and pathways to the workspaces filled with
boxes and miscellaneous items that made movement difficult and potentially
unsafe. We believe the conditions observed put the employees at risk of injury and
the agency at risk for potential liability claims if injury occurs. We discussed our
concerns with the employees' supervisors, and they were unaware of the potentially
unsafe conditions.
The supervisors provided us with the employees' approved telework agreements
and the self-certification safety checklists on file. The supervisors also indicated
that they had never conducted site visits to the employees' residences. The safety
checklist is designed to assess the overall safety of the alternate work location
(AWL) and must be completed by the employee and given to the employee's
supervisor with the telework application. The form states that signing the form does
not guarantee that the AWL is hazard free, but does verify that the employee has
made a reasonably careful inspection for potential hazards. The form also states
that the employees are responsible for informing their supervisors of any changes
to their AWL which could impact on health and safety of the employee and others.
Based on the OIG's observations during the interviews, we believe that the
employees are in potential noncompliance with some or all of the following
checklist items shown in Table 1.
15-P-0167
6

-------
Table 1: Potential noncompliance items based on OIG observations
Checklist
item no.
Checklist description
13.
Are aisles, doorways and corners free of obstructions to permit visibility
and movement?
17.
Are the phone lines, electrical cords, and extension wires safely secured?
19.
Is there adequate electrical lighting to accomplish work assignments?
Source: EPA Flexiplace Policy, Employee Self-Certification Safety Checklist.
Our review of the safety checklists for the three employees showed that the
employees had marked "yes" to each of the items in Table 1. Since the supervisors
were unaware of the potentially unsafe conditions, we can assume that the
employees did not provide notification of changes to their AWL, as agreed to by
signing the form.
We reviewed the agency's telework policy to determine whether telework
requirements—including the employee self-certification safety checklist—are
applicable to employees on RAC telework. Our review showed no specific
reference to RAC telework.
The agency clarified that all governing telework policies and procedures apply to
employees who telework as a RAC, unless these policies and procedures are
modified by virtue of the disability/accommodation. The agency stated that any
policy change involving employees who telework as a RAC would need to be a
collaborative effort between the Office of Human Resources and the Office of
Civil Rights and subject to bargaining requirements pursuant to collective
bargaining agreements. The agency has been working with the American
Federation of Government Employees—the EPA's largest union—on an
agreement that will confirm that employees teleworking as a RAC are required to
meet telework recertification requirements, including annual safety checklist
recertifi cation.
Recommendation
We recommend that the Deputy Administrator:
1. Address the specific matters of concern noted in this report pertaining to:
•	Accuracy of time charges in PeoplePlus.
•	Use of a personal computer to conduct official work.
•	Safety of the work space for employees on RAC telework.
15-P-0167
7

-------
Agency Comments and OIG Evaluation
A discussion document was provided to the agency for comment on March 20,
2015. The agency provided us its initial response on April 9, 2015, and we held a
final exit conference with agency officials on April 23, 2015. The agency
followed up with a formal response on May 4, 2015.
The agency concurred with our recommendation and has corrected the
timekeeping errors identified. The agency is currently updating its network access
control procedures and evaluating its telework policies to address our concerns
regarding the use of personal computers for official work and the safety of RAC
employees.
The agency's full response to our discussion draft is in Appendix C of this report.
15-P-0167
8

-------
Status of Recommendations and
Potential Monetary Benefits
POTENTIAL MONETARY
BENEFITS (In $000s)
Claimed Agreed-To
Amount Amount
report pertaining to:
•	Accuracy of time charges in PeoplePlus.
•	Use of a personal computer to conduct
official work.
•	Safety of the work space for employees on
RAC telework.
RECOMMENDATIONS
Planned
Rec. Page	Completion
No. No.	Subject	Status1 Action Official	Date
1 7 Address the specific matters of concern noted in this 0 Deputy Administrator 4/30/16
1 0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
15-P-0167
9

-------
Appendix A
Prior OIG Reports Related to
Time and Attendance
In addition to the Beale report, the OIG recently issued three other reports related to time and
attendance, as follows.
Early Warning Report: Some EPA Employees Found to Be on Paid Administrative
Leave for Years (15-N-0025), issued November 19, 2014
This report identified eight employees who had recorded significant amounts of administrative
leave. We issued the report to provide the information to the EPA Administrator.
No recommendations were made.
http://www.epa.gov/oig/reports/2014/20141119-15-N-0025.pdf.
EPA OIG Not Fully Compliant With OIG Policy on Time and Attendance Reporting
(15-B-0074), issued February 4, 2015
The audit noted that the OIG did not always comply with its policy for using its Inspector
General Enterprise Management System (IGEMS) as the official internal system for recording
time and attendance in both its planning and timesheet modules. As a result, some employees
did not submit or have approved planned or actual timesheets in IGEMS when required under
OIG policy. This occurred because the policy needed clarity and OIG employees did not
appear to view IGEMS time and attendance recording as a high priority. We recommended
that the Deputy Inspector General require employees and management to correct the instances
of noncompliance identified and review future IGEMS records for appropriateness, and review
pertinent policy. The Deputy Inspector General agreed with our recommendations and
provided corrective actions and planned completion dates to address all recommendations.
http://www.epa.gov/oig/reports/2015/20150204-15-B-0074.pdf.
EPA OIG Not Fully Compliant With Overtime Policies (15-B-0075), issued February 4,
2015
The audit disclosed that the OIG did not always use EPA Form 2560-7, Request for
Authorization of Overtime Work, for overtime requests and authorization as required by EPA
Pay Administration Manual 3155. Also, the OIG did not always comply with its own policy
on the use of the planned timesheet for advance approval of overtime. This occurred because
OIG management did not provide sufficient oversight, and OIG policies were not clear. We
also noted the OIG did not retain EPA authorization forms supporting overtime requests. We
recommended that the Deputy Inspector General revise OIG policy as needed and emphasize
EPA policy to staff. The Deputy Inspector General agreed with our recommendations and
provided corrective actions and planned completion dates to address all recommendations.
http://www.epa.gov/oig/reports/2015/20150204-15-B-0Q75.pdf
15-P-0167
10

-------
Appendix B
Sampling Methodology
The purpose of our sample testing was to identify employees who potentially received salary
payments while absent from their duties for an extended period of time. We held numerous
discussions with representatives from OEI, OCFO, and the Office of Administration and
Resources Management to determine the availability of data and potential testing methodologies.
Based on these discussions, we developed the most feasible test to address our purpose. We
shared our methodology with the agency and addressed its concerns. We also solicited ideas
from the agency for alternative testing methodologies, but the agency provided no suggestions.
The agency agreed with our general sampling methodology.
We selected two sample periods for testing—November 2013 and May 2014. Each sample
period represented two consecutive pay periods, or 4 weeks. For each sample period, we
compared payroll to computer login records to identify employees who received salary payments
but had not logged into the agency's email system (Outlook) at least once. We based the test on
the assumptions that if employees are logged into the agency's email system, there is some
assurance that the employees are present to perform their duties.
For the sample periods November 2013 and May 2014, the number of employees receiving
salary payments totaled 16,116 and 15,355, respectively, according to the agency's Compass
Data Warehouse accounting system. We used the Active Directory login data and computer user
names provided by OEI to identify employees who logged into the email system. Anyone who
received a salary payment but had not logged into the system at least once during the sample
period was identified as an exception. Initially, we identified 528 exceptions. We used a multi-
phased process to identify and eliminate "false exceptions" (i.e., any exceptions that could be
readily justified or explained). We reviewed time cards, personnel records, and additional
information provided by the agency. Examples of a justified basis for the eliminations included:
•	Employees who were on payroll but charged zero hours.
•	Employees who were on leave most of the time.
•	Special government employees who were hired on an as-needed basis and not issued a
government computer for logging into the EPA's systems regularly.
•	Employees who mistakenly came up in the initial exceptions due to computer user name
changes.
•	Employees who had an employment status change during the sample periods.
•	Employees who were double counted because they were exceptions for both sample periods.
As a result of these justifications, we eliminated 412 exceptions from further review, reducing
the exceptions requiring follow-up to 116. Based on employee availabilities and further risk
assessment, we interviewed 63 employees, or 54 percent of our remaining 116 exceptions. We
conducted the interviews to determine whether the employees actually logged into the agency's
email system and to identify explanations for those who did not log in.
15-P-0167
11

-------
Appendix C
Agency Response to Discussion Draft
May 4, 2015
MEMORANDUM
SUBJECT: EPA Comments on Discussion Draft, "No Instances of Time and Attendance
Fraud Identified, But Other Matters of Concern Brought to EPA 's Attention, "
dated March 20, 2015
FROM: Stefan Silzer, Director /signed/
Office of Financial Management
TO:	Robert Adachi, Director
Forensic Audits
Office of Audits
Thank you for the opportunity to review the subject Discussion Draft. Below is a summary of the
agency's comments regarding the factual accuracy of the information, conclusions, and
recommendations contained therein.
AGENCY'S COMMENTS ON DISCUSSION DRAFT LANGUAGE
OIG Issue: "Safety of Employees on Reasonable Accommodation Telework"
Agency Comments:
•	All governing telework policies and procedures apply to employees that telework as a
reasonable accommodation unless these policies and procedures are modified by virtue of
the disability/accommodation.
•	The safety checklist represents the employee's signed certification that they have
inspected their alternative work location (AWL) for potential hazards and that it is a safe
space; however, this certification states that signing the form "does not guarantee that the
AWL is hazard free." The certification requires employees to inform their supervisors of
any changes to their AWL which could impact their health and safety.
•	Any policy change involving employees that telework as a reasonable accommodation
would need to be a collaborative effort between OHR and OCR (who handles agency RA
matters) and are subject to bargaining requirements pursuant to collective bargaining
agreements.
•	The Agency has been working with AFGE, EPA's largest Union on an agreement that
will confirm that employees teleworking as a reasonable accommodation are required to
15-P-0167
12

-------
meettelework recertification requirements, including annual safety checklist
recertifi cation.
AGENCY'S RESPONSE TO RECOMMENDATIONS
The agency concurs with the Discussion Draft recommendation.
Agreements
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
by Quarter and FY
1
Address the specific
matters of concern noted in
this report pertaining to:
•	Accuracy of time
charges in PeoplePlus
•	Use of a personal
computer to conduct
official work
•	Safety of the work space
for employees on RAC
tele work
1.1 The discussion draft
identified 3 employees with
timecard errors. Corrections to
these timecards have been
made by the employees and
approved by their supervisors.
Complete


1.2 A revised access control
procedure is currently
undergoing Agency wide
review and is expected to be
signed by the CIO later this
year. The new access control
procedure states that "users
shall connect non-EPA owned
mobile devices only to
authorized EPA information
management and technology
solutions."
September 30, 2015


1.3 The agency will evaluate
its telework policies and
procedures related to
reasonable accommodations
and modify them, as needed,
to ensure the safety of the
work space for employees on
RAC telework. Note that
changes to RAC/ telework
may be subject to the
collective bargaining
agreements.
April 30, 2016
15-P-0167
13

-------
cc: David Bloom
Renee Wynn
Donna Vizian
Kevin Minoli
John Reeder
Jeanne Conklin
John Showman
Meshell Jones-Peeler
Richard Gray
Leo Gueriguian
Harrell Watkins
Liza Hearn
Patricia Hilton
Judi Maguire
Iesha Alexander
Brandon McDowell
Janice Kern
Lorna Washington
15-P-0167
14

-------
Appendix D
Distribution
Office of the Administrator
Deputy Administrator
Chief of Staff
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Chief Information Officer, Office of Environmental Information
Assistant Administrator for Administration and Resources Management
Regional Administrator, Region 3
Regional Administrator, Region 5
Regional Administrator, Region 9
Principal Deputy Assistant Administrator for Administration and Resources Management
Assistant Administrator and Principal Deputy Assistant Administrator for
Environmental Information
Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Deputy Director, Office of Policy and Resource Management, Office of Administration and
Resources Management
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Environmental Information
Audit Follow-Up Coordinator, Region 3
Audit Follow-Up Coordinator, Region 5
Audit Follow-Up Coordinator, Region 9
15-P-0167
15

-------