^tD sr-^ * v0 wi PRO^ U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF INSPECTOR GENERAL Operating efficiently and effectively EPA Telework Program Is Consistent With U.S. Office of Personnel Management Guidance Report No. 18-P-0024 October 16, 2017 ------- Report Contributors: Ming Chang Dwayne Crawford Andre von Hoyer II Eric Lewis Rodney Rice Abbreviations AFGE American Federation of Government Employees EPA U.S. Environmental Protection Agency OARM Office of Administration and Resources Management OIG Office of Inspector General OPM U.S. Office of Personnel Management Cover image: Possible tele work program enhancements suggested by EPA managers and supervisors in an OIG-fielded survey. (EPA OIG) 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 Hotiine@epa.gov Learn more about our OIG Hotline. EPA Office of Inspector General 1200 Pennsylvania Avenue, NW (2410T) Washington, DC 20460 (202) 566-2391 www.epa.aov/oia Subscribe to our Email Updates Follow us on Twitter @EPAoiq Send us your Project Suggestions ------- tftD SW * _I1_ J U.S. Environmental Protection Agency 18-P-0024 f ^ Office of Inspector General October 16,2017 iSSl ' At a Glance Why We Did This Review We conducted this review to determine whether (1) U.S. Environmental Protection Agency (EPA) telework policies are consistent with U.S. Office of Personnel Management (OPM) guidance, (2) managers received the required training to supervise teleworking employees, and (3) managers know of and have access to teleworking tools. The Telework Enhancement Act of 2010 supports the development and advancement of telework by outlining a number of requirements to ensure the appropriate policies and trained personnel are in place to achieve effective telework programs. The act directed OPM to provide agencies with policy and guidance for telework. OPM issued its guidance in 2011. This report addresses the following: Operating efficiently and effectively. EPA Telework Program Is Consistent With U.S. Office of Personnel Management Guidance What We Found EPA telework policies are consistent with OPM's guidance. We surveyed EPA managers and supervisors and found that 97 percent of respondents had received the required training to supervise their teleworking employees. The results of our evaluation showed that the EPA has implemented significant steps to ensure that those managers and supervisors who have not yet received the training come into compliance. The EPA's telework policies have resulted in nearly all managers being trained to supervise their teleworking employees. Our survey results also showed that EPA managers and supervisors use various agency-provided tools and methods to monitor the work accomplished by their teleworking staff, including work meetings, telephone calls, emails and business software. Some survey respondents also submitted written suggestions describing what additional training, tools and policies they believe are needed to improve the EPA's telework program. We grouped these suggestions into six categories of requested enhancements: Better communication tools. Consistent telework policy agencywide. Expanded telework training for staff. Need for American Federation of Government Employees policy ratification. Outcome-based management. More flexibility for managers. In response to our discussion document, the Office of Administration and Resources Management provided a response to the six categories of program- enhancing suggestions submitted by EPA managers and supervisors. There are no recommendations in this report. Send all inquiries to our public affairs office at (202) 566-2391 or visit www.epa.aov/oia. Listing of OIG reports. ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 THE INSPECTOR GENERAL October 16, 2017 MEMORANDUM SUBJECT: EPA Telework Program Is Consistent With U.S. Office of Personnel Management Guidance Report No. 18-P-002'1 FROM: Arthur A. Elkins Jr. TO: Donna Vizian, Acting Assistant Administrator Office of Administration and Resources Management This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA). The project number for this evaluation was OPE-FY16-0028. This report represents the opinion of the OIG and does not necessarily represent the final EPA position. Because this report contains no recommendations, you are not required to respond to this report. Should you choose to provide a final response, we will post your response on the OIG's public website, along with our memorandum commenting on your response. Your response should be provided as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want released to the public; if your response contains such data, you should identify the data for redaction or removal along with the corresponding justification. We will post this report to our website at www.epa.gov/oig. ------- EPA Telework Program Is Consistent With U.S. Office of Personnel Management Guidance 18-P-0024 Table of Contents Purpose 1 Background 1 Responsible Office 3 Scope and Methodology 3 Results of Evaluation 3 EPA's Telework Policies Are Consistent With OPM Guidance 3 Majority of EPA Managers Have Received Required Training 4 EPA Managers Know of and Have Access to Telework Tools, and Provided Responses for Suggested Improvements 5 Conclusions 7 Agency Response and OIG Evaluation 7 Appendices A OIG Analysis of Written Comments Provided by EPA Managers and Supervisors 8 B OARM Response to Discussion Document 10 C Distribution 12 ------- Purpose The purpose of this Office of Inspector General (OIG) evaluation was to assess the U.S. Environmental Protection Agency's (EPA's) compliance with and implementation of relevant telework policies and guidance issued by the U.S. Office of Personnel Management (OPM). Specifically, we evaluated whether: EPA telework policies are consistent with OPM guidance. EPA managers have received the required training to supervise their telework employees. EPA managers know of and have access to telework tools. Background Telework is a work arrangement that allows an employee to perform work at an approved alternate worksite during regular, paid hours. The Telework Enhancement Act of 2010 requires that the head of each executive agency establish a policy under which eligible employees of the agency may be authorized to telework. In addition, the act requires that a determination be made regarding which employees are eligible to telework and that all employees of the agency be notified of their eligibility. The act also supports the development and advancement of telework by outlining a number of requirements to establish appropriate support structures (such as policies) and capabilities (via training). Furthermore, the act directs OPM to assist executive agencies in developing telework programs and to provide guidance in numerous areas, including performance management. OPM issued a Guide to Telework in the Federal Government in April 2011 and provided telework training for federal employees and managers at www.telework. gov. EPA Order 3110.32 establishes policy for the agency in accordance with the act. Revised April 3, 2017, EPA Order 3110.32 supports the use of telework and establishes the eligibility of employees to participate in telework based on two factors: the extent to which their work is portable and the employee eligibility requirements outlined in the policy. Because telework requires collaboration between management and employees, the policy states that both parties have responsibilities in its successful implementation and operation. In addition, EPA Order 3110.32 specifies that an employee's participation in telework is voluntary and that teleworkers will receive the same treatment and opportunities as non-tele workers (e.g., work assignments, awards and recognition, development opportunities, promotions, etc.). The act directs that teleworkers and non-teleworkers be treated the same for the following purposes: Performing periodic appraisals of job performance of employees. Training, rewarding, reassigning, promoting, reducing in grade, retaining and removing employees. 18-P-0024 1 ------- Administering work requirements and other acts involving managerial discretion. According to OPM, agencies should establish protocols, performance standards and expectations applicable to both in-office and telework employees. OPM states that a monitoring plan should not be so rigid as to hinder productivity and to create an environment of distrust. The EPA's Office of Administration and Resources Management (OARM) is responsible for ensuring that the agency's telework policies are consistent with the Telework Enhancement Act and OPM guidance. In addition, OARM establishes agency telework training requirements. In June 2016, OARM issued a memorandum titled Next Steps in Implementing EPA's Updated Telework Policy and Training, which states that in-person, webinar and eLearning training courses are available and required for all managers and supervisors with teleworking employees. The EPA has six telework policies: five bargaining unit policies and one non- bargaining unit policy.1 The five bargaining unit policies are established with the following entities: Engineers and Scientists of California. National Association of Government Employees. National Association of Independent Labor. National Treasury Employee Union. American Federation of Government Employees (AFGE). AFGE does not have a current, ratified telework policy and works under its previous bargaining unit policy, titled 1998 Final American Federation of Government Employees National Collective Bargaining Agreement for Flexiplace. The non-bargaining unit policy is for all non-union employees, except those in the OIG, which has its own telework policy.2 EPA employees may participate in telework subject to the limitations described in the Telework Enhancement Act and as defined by agency telework policies and applicable collective bargaining agreements. 1 OARM managers stated that the EPA has a total of five unions and one non-bargaining unit and that they are required to collectively bargain on all agency policies. 2 The OIG was not included in the scope of this review. 18-P-0024 2 ------- Responsible Office The EPA's OARM manages the agency's telework program. Scope and Methodology We performed our work from August 2016 to June 2017. We conducted this performance audit in accordance with generally accepted government auditing standards. 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 objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. To address our objectives, we reviewed applicable criteria and compared agency telework policies to OPM guidance. As directed by the act, OPM provided guidance for federal agencies regarding their responsibilities under the act for implementing telework programs. We compared OPM's 2011 guidance with key elements of the act to confirm they were aligned. We interviewed OARM staff; a representative from AFGE, which requested a meeting with the OIG on this assignment; and managers from OPM. In addition, we interviewed a regional EPA official who contacted us to provide perspective on telework management issues. Using personnel data obtained from OARM, we fielded an electronic survey from November 9, 2016, through December 3, 2016, to 1,534 EPA headquarters and regional employees who either supervise or manage telework employees. We received 886 responses, a response rate of 58 percent. Results of Evaluation EPA's Telework Policies Are Consistent With OPM Guidance All EPA telework policies are consistent with OPM guidance. The OIG identified the following key parameters of the agency's telework policies, which OPM confirmed are key elements in its Guide to Telework in the Federal Government. Establishment of a telework policy under which eligible employees of the agency may be authorized to telework. Determination of eligibility criteria for all agency employees to participate in telework. Development of mandatory telework training for designated managers and supervisors. 18-P-0024 3 ------- Telework Eligibility Factors Are Identified in EPA Policies Employee eligibility criteria to participate in the telework programincluding the following requirementsare established and included in all of the agency's telework policies: Supervisory approval. Work portability. Current performance rating of at least fully successful. Defined performance standards in place. Signed telework agreement. Appropriate work location/equipment. Ability to work independently. EPA Has Established Mandatory Telework Training for Managers O ARM's June 2016 memorandum, Next Steps in Implementing EPA's Updated Telework Policy and Training, details the types of agency telework training available and establishes telework training as mandatory for supervisors and managers of teleworking employees. Majority of EPA Managers Have Received Required Training The agency's Telework Training for Supervisors is a 4-hour course designed for EPA supervisors and managers. The course teaches participants to accomplish the following objectives: Recognize the benefits and challenges of telework. Become a virtual leader. Determine telework agreements. Establish and manage accountability. Establish communication protocols. Develop work plans and tasks. Establish standards for providing feedback and updates on work products and projects. Determine telework collaboration and remote access tools. Our survey of EPA headquarters and regional managers and supervisors showed that 97 percent of respondents stated they had received the training, while approximately 3 percent of respondents stated they had not received the training. In response to those managers and supervisors who stated that they had not received the training, OARM provided the following courses of action: Senior leaders from each program and regional office will ensure that all of their managers have completed the training. 18-P-0024 4 ------- Deputy Assistant Administrators and Assistant Regional Administrators will receive individual office tracking reports that identify the managers and supervisors who have not completed the training. These officials will be strongly encouraged to ensure that all managers within their respective offices have completed the training. Regional Human Resources Officers and Program Management Officers will also receive these individual office tracking reports. These staff members will be asked to review the reports for accuracy and notify any managers listed in the reports that training must be completed. EPA Managers Know of and Have Access to Telework Tools, and Provided Responses for Suggested Improvements Our survey showed that EPA managers and supervisors have been using the following agency-provided tools and other methods to monitor work accomplished by their telework staff: a software application and online service that enables voice and video calls over the internet, such as Skype for Business;3 emails; telephone calls; work meetings; timesheets; monitoring workplans; tracking deliverables; and regular check-ins (Figure 1). Additionally, 84 percent of EPA managers and supervisors who responded to our survey considered the available telework management tools sufficient to oversee part-time telework staff. Figure 1: Types of telework management tools used a 65% | I 61% 46% 27% 16% 8% ¦ 1 MEETINGS PHONE CALLS OTHER EMAILS TIMESHEETS SKYPE Source: OIG's 2016 telework survey of EPA managers and supervisors. a Since respondents provided multiple examples of telework management tools, the percentages in this graph total greater than 100%. 3 The use of product names in this report is only to illustrate survey responses and does not constitute the OIG's endorsement of these products. 18-P-0024 5 ------- EPA Managers Find Telework Policies Useful Our survey results showed that, when asked about the usefulness of the EPA's telework policies, approximately two-thirds of the responses were above the midpoint (3) on a 5-point scale, where 1 is "not at all useful" and 5 is "very useful" (Figure 2). Figure 2: Management perspectives regarding usefulness of telework policies 5% 2% 5-VERY USEFUL 1-NOT AT ALL USEFUL Source: OIG's 2016 telework survey of EPA managers and supervisors. EPA Managers Provided Responses on Additional Improvements Through the use of our survey instrument, we asked EPA managers and supervisors to submit written responses describing what additional training, tools or policies they believe are needed to improve the EPA's telework program. From the survey responses, we identified 428 suggestions for improvements.4 We characterized these suggestions into the following six categories shown in Table 1: 4 We reviewed all responses. Not eveiy comment was germane or responsive to the OIG's request. We excluded all responses that were non-responsive to program enhancements for improving EPA's telework program. These exclusions included responses such as nothing, none and not sure, and those that were not germane or responsive to the question asked. 18-P-0024 6 ------- Table 1: Categories of program-enhancing suggestions submitted by managers and supervisors Category Percentage Better communication tools 37 Consistent telework policy agencywide 27 Expanded telework training for staff 13 AFGE policy ratification 10 Outcome-based management 9 More flexibility for managers 4 Source: OIG's 2016 telework survey of EPA managers and supervisors. Further analysis of the comments is in Appendix A. Conclusions We reached the following conclusions regarding the EPA's telework program: The EPA's telework policies are consistent with OPM guidance. The majority of agency managers and supervisors who responded to our survey believe the policies are also useful. Of the agency managers and supervisors who responded to our survey questions related to telework training, 97 percent indicated they had taken the required training. The EPA established controls to identify those who had not taken the training and encourage them to come into compliance with the agency's policies. EPA managers know of and have access to telework tools, and 84 percent believe the available telework management tools are sufficient to oversee part-time telework staff. Agency Response and OIG Evaluation We met with OARM staff and officials to discuss our results. In response to our discussion document, OARM provided a response to the six categories of program-enhancing suggestions submitted by EPA managers and supervisors. There are no recommendations in this report. No final agency response is required. 18-P-0024 7 ------- Appendix A OIG Analysis of Written Comments Provided by EPA Managers and Supervisors We administered our survey to EPA headquarters and regional employees who either supervise or manage tele work employees. Our survey provided an opportunity for EPA managers and supervisors to submit responses describing what additional training, tools or policies they believe are needed to improve the EPA's tele work program, as well as what methods they use to monitor work accomplished by their teleworking employees. We received 428 suggestions for improvements. We grouped these suggestions for improvements into six categories (Figure A-l). Figure A-1: Categories of program-enhancing responses submitted by managers and supervisors BETTER CONSISTENT COMMUNICATION POLICY TOOLS AGENCYWIDE EXPANDED TELEWORK TRAINING FOR STAFF NEED FOR AFGE OUTCOME-BASED MORE FLEXIBILITY POLICY MANAGEMENT FOR MANAGERS RATIFICATION Source: OIG's 2016 telework survey of EPA managers and supervisors. Better Communication Tools Of the suggestions for improvement received, 37 percent expressed the need for better tools, equipment or facilities to facilitate seamless communication between management and employees in telework status. Specifically mentioned were the use of a software application and online service that enables voice and video calls over the internet; a web-based, collaborative platform for document management and storage systems, such as SharePoint; software used to create information and general presentations; online training materials; web conferencing; learning modules; user desktop sharing and video teleconferencing applications, such as Adobe Connect; telephone/video equipment; and improved remote-access laptops. 18-P-0024 8 ------- Consistent Policy Agencywide Of the suggestions for improvement received, 27 percent expressed the need for a consistent, agencywide telework policy to ensure that it is applied the same to all employees. We found that, while each policy contained the main tenets of the OPM telework guidance, the unions have the right to bargain on the implementation of EPA policy. However, the telework training is the same regardless of the policy. Expanded Telework Training for EPA Staff Of the suggestions for improvement received, 13 percent expressed the need for more telework training. Some respondents were of the opinion that this training would inform employees of management expectations for employees in telework status. Need for AFGE Policy Ratification Of the suggestions for improvement received, 10 percent expressed the need for an AFGE telework agreement for their union employees. Some respondents believed that such an agreement would help facilitate seamless participation of union employees in the EPA's telework program. Outcome-Based Management Of the suggestions for improvement received, 9 percent expressed the need for more clearly defined expectations from both the employee and the manager or supervisor, more effective tracking of deliverables generated by employees while in telework status, more consistent ways to measure outcomes, or more support for managers and supervisors from all organizational levels. More Flexibility for Managers Of the suggestions for improvement received, 4 percent expressed the need for managers and supervisors to have more flexibility in documenting achievements by staff while in telework status. Specifically mentioned was assessing the productivity of employees when they are in telework status compared to when they are in the office. We reiterate however, that the act directs that teleworkers and non-teleworkers be treated the same for the purposes of administering work requirements. Furthermore, according to OPM, agencies should establish protocols, performance standards and expectations applicable to both in- office and telework employees. 18-P-0024 9 ------- Appendix B OARM Response to Discussion Document MEMORANDUM SUBJECT: Response to the June 30, 2017, "Assessment of EPA Telework Policies and Tools" Discussion Document: Appendix A FROM: Linda R. Gray, Director Office of Human Resources TO: Eric Lewis, Product Line Director Special Program Reviews, Office of Program Evaluations Office of Inspector General On Thursday, July 27, 2017, Office of Human Resources personnel met with Office of Inspector General personnel regarding the OIG's "Assessment of EPA Telework Policies and Tools" discussion document. The purpose of the meeting was to further clarify concerns with the Office of Administration and Resources Management's July 14, 2017, response to the aforementioned document. Appendix A of the document, entitled "OIG Analysis of Written Comments Provided by EPA Managers and Supervisors" identified the following six categories of program-enhancing comments submitted by managers and supervisors: The need for better communication and tools; A consistent agencywide policy; The need for expanded telework training for staff; The need to complete an agreement with the American Federation of Government Employees; The need for better outcome-based management; and The need for more flexibility for managers. OHR personnel discussed in-depth the agency's limitations with the recommendations as follows: The Office of Environmental Information is constantly working to improve the technology, resources and access for employees to be able to telework. However, for the majority of teleworkers, having access to a phone, internet, audio conference capabilities and a computer is sufficient to allow them to perform the majority of their work. In regards to a consistent policy, the agency's ability to have one policy covering both bargaining and non-bargaining unit employees is significantly impacted by the unions' right to bargain and enter into agreements covering their members. The agency has tried its best to ensure that agreements and the NBU policy are aligned. 18-P-0024 10 ------- Employee telework training already covers expectations for teleworkers. If employees are not able to effectively telework, the NBU policy and all agreements allow for telework to be revoked. The agency's telework training modules for supervisors and employees are always available through the agency's eLearning site. Refresher training or reminders about telework expectations can be provided as needed by the supervisor, local telework coordinator or OARM. The agency is currently in negotiations with AFGE. The progress of negotiations is currently stalled given litigation issues regarding the negotiations; once the litigation issues are resolved, the agency will resume negotiations with AFGE. As previously communicated, the agency can take no action that would violate the Telework Enhancement Act which requires teleworkers and non-teleworkers to be treated the same for purposes including, but not limited to, performance management. Regarding outcome-based management, tracking deliverables and measuring outcomes of an employee's work is a supervisory responsibility that is applicable to all employees and not just those who telework. Similarly, teleworkers would be subject to different treatment if their supervisors were authorized to employ metrics in addition to those contained in the employee's performance plan as noted in the "more flexibility for managers" recommendation. However, through training on the agency's performance management and recognition program, supervisors can receive information on methods for consistently tracking deliverables and measuring outcomes for all employees. I hope this information provides the clarity you requested in regards to OARM's July 14, 2017, response. If you have any questions or concerns about this matter, please contact: Debbi Hart, division director, Policy, Planning and Training Division, at hart. debbi@,epa. gov or (202) 564- 2011; or Krysti Corbett, division director, Labor and Employee Relations Division, at corbett. krysti@epa. gov or (202) 564-6295. cc: Wesley Carpenter Debbi Hart Krysti Corbett Cheri Hembrey 18-P-0024 11 ------- Appendix C Distribution The Administrator Chief of Staff Chief of Staff for Operations Deputy Chief of Staff for Operations Assistant Administrator for Administration and Resources Management Agency Follow-Up Official (the CFO) Agency Follow-Up Coordinator General Counsel Associate Administrator for Congressional and Intergovernmental Relations Associate Administrator for Public Affairs Deputy Assistant Administrator for Administration and Resources Management Director, Office of Resources, Operations and Management, Office of Administration and Resources Management Deputy Director, Office of Resources, Operations and Management, Office of Administration and Resources Management Audit Follow-Up Coordinator, Office of the Administrator Audit Follow-Up Coordinator, Office of Administration and Resources Management 18-P-0024 12 ------- |