^tDsr^
$ O
® J
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA Needs to Increase
Oversight of Leave Bank
Program to Improve Efficiency
and Reduce Risk of Misuse
Report No. 17-P-0374	August 28, 2017
Number of Leave Bank Recipients Compared to Leave Bank Balances
2014
2015
2016

-------
Report Contributors:
Michael D. Davis
Randy Holthaus
Lisa Bergman
Alexandra Zapata-Torres
Abbreviations
CFR
Code of Federal Regulations
DOJ
Department of Justice
EOUSA
Executive Office of the U.S. Attorneys
EPA
U.S. Environmental Protection Agency
FFAS
Farm and Foreign Agricultural Services
FPPS
Federal Personnel Payroll System
LBB
Leave Bank Board
NIH
National Institutes of Health
OARM
Office of Administration and Resources Management
OHR
Office of Human Resources
OIG
Office of Inspector General
OPM
Office of Personnel Management
PPL
PeoplePlus
U.S.C.
United States Code
USD A
U.S. Department of Agriculture
VLBP
Voluntary Leave Bank Program
Cover image: OIG graphic showing the number of leave bank recipients for years 2013-2015
and leave bank starting balances in hours for years 2013-2016.
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
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

-------
x-^tD SW
*. U.S. Environmental Protection Agency	17-P-0374
|	\ Hffirp of Insnprtnr ^pnpral	August 28,2017
.	u.o. CMViiuMiimiiidi nuiei/U
\ Office of Inspector General
% 5322 J
At a Glance
Why We Did This Review
We conducted this audit to
determine whether the
U.S. Environmental Protection
Agency (EPA) had established
and implemented internal
controls for the Voluntary
Leave Bank Program to
prevent and detect fraud, waste
and abuse in the program.
The EPA established its
Voluntary Leave Bank
Program, managed by the
Office of Administration and
Resources Management, in
1988. The leave bank provides
assistance to federal
employees who would be
facing a significant financial
hardship due to a medical
emergency. Participating
employees can receive leave
contributions from the leave
bank when they have
exhausted their accrued leave
hours and are experiencing a
medical emergency. As of
June 30, 2016, the EPA's
voluntary leave bank balance
was 249,789 hours, which we
valued at about $10.8 million.
This report addresses the
following:
• Operating efficiently and
effectively.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
Listing of OIG reports.
EPA Needs to Increase Oversight of Leave Bank Program
to Improve Efficiency and Reduce Risk of Misuse
The stewardship of
leave bank resources is
vulnerable to fraud,
waste and misuse
because the EPA has not
implemented adequate
internal controls.
What We Found
The EPA did not adequately manage the Voluntary
Leave Bank Program to assess the solvency or
efficiency of the program, adequately safeguard
personal employee information, or minimize the
potential for misuse. The EPA did not routinely
monitor the bank balance or the bank's solvency.
Further, the EPA did not periodically assess
whether adjustments were needed to the maximum
number of hours that employees could use, or to the minimum number of hours
an employee was required to contribute annually. Also, the Leave Bank Board
did not routinely assess and verify medical certifications to approve an
application and determine how many hours should be provided. Inaccurate
timekeeping data incorrectly showed that leave bank recipients used more than
the allowed 280 hours per leave year and conflicted with the payroll system.
These conditions occurred because the EPA Office of Administration and
Resources Management did not develop and implement official policies and
procedures to administer the leave bank and govern the actions of the Leave
Bank Board. Also, the timekeeping system did not have working controls to
prevent employees from entering more than the leave bank hours allowed. As a
result, the EPA cannot adequately determine whether the leave bank program is
solvent; determine whether the hours in the bank exceed needs; adequately
protect against fraud, waste and abuse; or provide supervisors with reliable
information to properly verify employees' time.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Administration and
Resources Management develop and implement official policies and procedures
for administering the program, conduct a risk assessment of the program, and
gather and analyze the required Voluntary Leave Bank Program data and provide
the results to leave bank managers for use in decision-making. In addition, we
recommend that the Assistant Administrator for Administration and Resources
Management and the Chief Financial Officer work together to develop and
implement a method for supervisors to view real-time data of employee leave
bank and leave transfer balances, and issue guidance and train supervisors on
the leave bank and leave transfer programs and their roles and responsibilities
for approving timesheets of employees using the leave programs.
The agency concurred with our six recommendations. The agency has completed
corrective actions for three of the recommendations, and we consider the
planned corrective actions for the other three recommendations to be acceptable.

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
August 28, 2017
MEMORANDUM
SUBJECT: EPA Needs to Increase Oversight of Leave Bank Program to Improve Efficiency and
Reduce Risk of Misuse
Report No. 17-P-0374
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY16-0063.
This report contains findings that describe the 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. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, you provided acceptable corrective actions and milestone dates
for all six of our recommendations. Recommendations 2, 4 and 5 are considered completed and closed.
Planned corrective actions for Recommendations 1, 3 and 6 are considered acceptable. As a result, you
are not required to provide a written response to this report. However, if you choose to submit a
response, it will be posted 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 to be released to the public; if your response
contains such data, you should identify the data for redaction or removal along with corresponding
justification.
FROM: Arthur A. Elkins Jr.
TO:
Donna J. Vizian, Acting Assistant Administrator
Office of Administration and Resources Management
David Bloom, Acting Chief Financial Officer
We will post this report to our website at www.epa.gov/oig.

-------
EPA Needs to Increase Oversight of
Leave Bank Program to Improve Efficiency
and Reduce Risk of Misuse
17-P-0374
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		3
Scope and Methodology		3
2	EPA's Leave Bank Not Adequately Managed to Assess Solvency,
Safeguard Sensitive Records, or Minimize Potential Misuse		4
EPA LBB Did Not Monitor Solvency of Leave Bank		4
EPA Did Not Always Adequately Safeguard Sensitive Information		8
EPA LBB Did Not Assess or Verify Medical Certifications		10
Recommendations		11
Agency Response and OIG Evaluation		12
3	Reliable Timekeeping Data Needed to Determine
Leave Bank Hours Used		13
Federal Standards Related to Timekeeping and Reporting		13
VLBP, Voluntary Leave Transfer Program, and
EPA Timekeeping and Payroll Systems		14
Timekeeping Data for Leave Bank Hours Were Inaccurate		14
Conclusion		15
Recommendations		15
Agency Response and OIG Evaluation		16
Status of Recommendations and Potential Monetary Benefits		17
Appendices
A Details on Scope and Methodology		18
B Leave Bank Best Practices of Other Federal Agencies		20
C Agency Response and OIG Evaluation		23
D Distribution		28

-------
Chapter 1
Introduction
Purpose
We conducted our audit to determine whether the U.S. Environmental Protection
Agency (EPA) had established and implemented internal controls for the
Voluntary Leave Bank Program (VLBP) to prevent and detect fraud, waste and
abuse of the program. The audit focused on whether the EPA managed the VLBP
in accordance with regulations to accomplish the program's purpose.
Background
Legal Authority and Requirements for VLBP
Title 5 U.S.C. Chapter 63, Subchapter IV, Voluntary Leave Bank Program,
§6362, provides authority to the Office of Personnel Management (OPM) to
establish a VLBP. OPM issued specific requirements for how to manage the
VLBP in the Code of Federal Regulations (CFR), including that each agency
participating "shall. . . [djevelop written policies and procedures for establishing
and administering leave banks and leave bank boards [LBBs]."1
The EPA established its VLBP in 1988. The VLBP provides assistance to federal
employees who would be facing a significant financial hardship due to a medical
emergency. The VLBP accumulates employee contributions of annual leave hours
into its leave bank. Employees participating in the VLBP can receive leave
contributions from the leave bank when they have exhausted their accrued annual
and sick leave hours and are experiencing a medical emergency. As of June 30,
2016, the EPA's voluntary leave bank balance was 249,789 hours, which we
valued at about $10.8 million.2
The VLBP law and regulation require agencies to establish an LBB for
administering and managing the program. The LBB is responsible for performing
the necessary functions relating to the VLBP, such as reviewing and approving
employee applications, monitoring leave bank solvency, and monitoring the status
of each recipient's case. The LBB must be comprised of three people, with at least
one from a labor organization or employee group.
1	Title 5 CFR, Chapter I, Subchapter B, Part 630, Subpart J, Voluntary Leave Bank Program, § 630.1003 (a)(1).
2	The $10.8 million estimate is calculated by using the pay rate per hour of a federal employee in the GS-13 step 1
pay level with a duty station in Washington, D.C., during year 2015 (249,789 hours x $43.52 = $10,870,817).
17-P-0374
1

-------
The EPA VLBP's national program manager is responsible for organizing and
disseminating recipient applications to the LBB. Also, the national program
manager is responsible for communicating with applicants about whether their
applications for leave were approved or denied. In addition, the national program
manager is responsible for maintaining VLBP records, including case files.
A national program coordinator and leave bank coordinators in the regions and
headquarters program offices assist the national program manager and the LBB
with these responsibilities.
The leave bank balance has increased by about 23 percent over the last few years,
from a leave-year starting balance of nearly 206,000 hours in 2013 to over
253,000 hours in 2016. However, while the leave bank balance of hours
increased, the number of leave bank recipients3 dropped by about 15 percent,
from 321 in 2013 to 273 in 2015, as shown in Figure 1.
Figure 1: Number of leave bank recipients (2013-2015) and leave bank
starting balances in hours (2013-2016)
2013
2014
2015
2016
EPA OIG graphic.
3 We calculated the number of leave bank recipients for 2013-2015 from the EPA's LBB recipient application logs
for those years. We completed gathering data before the 2016 leave year ended and, therefore, are not presenting
data for 2016.
17-P-0374
2

-------
Responsible Offices
There are two EPA offices with primary responsibility over the issues discussed
in this report:
•	The Office of Administration and Resources Management (OARM)
provides national leadership, issues policy, and manages many essential
support functions for the EPA, including human resources management.
O ARM's Office of Human Resources (OHR) is responsible for the VLBP
and manages EPA data in its payroll system—the Federal Personnel
Payroll System (FPPS).
•	The Office of the Chief Financial Officer is responsible for managing and
operating the EPA's timekeeping system—PeoplePlus (PPL).
Scope and Methodology
We conducted our performance audit from March 2016 to June 2017 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.
We examined the VLBP's internal controls and other applicable activities for the
period January 1, 2013, to December 31, 2016. Key elements of the program that
we reviewed were:
•	Whether the EPA monitored and maintained solvency of the leave bank.
•	How the EPA approved and denied leave applications.
•	Whether the EPA maintained and used leave bank records.
Appendix A contains a more detailed list of activities we conducted.
17-P-0374
3

-------
Chapter 2
EPA's Leave Bank Not Adequately Managed to
Assess Solvency, Safeguard Sensitive Records,
or Minimize Potential Misuse
The EPA did not adequately manage the VLBP to assess the solvency or
efficiency of the program, adequately safeguard personal employee information,
or minimize potential misuse. In particular, OARM and LLB did not:
•	Routinely monitor the leave bank balance or the leave bank's solvency to
determine whether the amount of leave in the bank was adequate to meet
future obligations or was in excess of needs.
•	Periodically assess the maximum number of leave hours an employee
could use each year to determine when adjustments to the threshold were
necessary.
•	Maintain all required records for managing the program.
•	Adequately safeguard the records it did maintain.
•	Assess or verify medical certifications, used as the primary basis for
deciding whether to approve an application and determine how many
hours should be provided to an employee.
This occurred because OARM did not develop and implement official policies
and procedures to administer the leave bank and govern actions of the LBB. Also,
there have not been any risk assessments or program performance reviews of the
program. Without adequate policies, procedures and controls in place, the EPA
did not have the necessary information to manage the program and determine
whether program goals were being accomplished. Further, the EPA cannot
adequately determine whether the leave bank program is solvent; the hours in the
bank exceed needs; or that the program is adequately protected against fraud,
waste and abuse.
EPA LBB Did Not Monitor Solvency of Leave Bank
Federal Regulations and Standards Provide for VLBP Management
OPM issued 5 CFR, Chapter I, Subchapter B, Part 630, Subpart J, Voluntary
Leave Bank Program, to provide agencies with procedures and requirements to
manage the VLBP. These requirements include that the agency shall develop
17-P-0374
4

-------
written policies and procedures for establishing and administering leave banks
and LBBs.4 In turn, the LBB is to monitor the amount of leave in the bank and the
number of recipient applications submitted, and maintain an adequate amount of
annual leave in the bank.5 According to 5 CFR § 630.1012, the agency is to
maintain records concerning the VLBP administration, to include:
(1)	The number of leave bank members for each leave year;
(2)	The number of applications approved for medical emergencies
affecting the employee, and the number of applications approved
for medical emergencies affecting an employee's family member;
(3)	The grade or pay level of each leave contributor, and the total
amount of annual leave he or she contributed to the bank;
(4)	The grade or pay level and gender of each recipient, and the
total amount of annual leave he or she actually used. ...
The U.S. Government Accountability Office's Standards for Internal Control in
the Federal Government (November 1999 and September 2014) describes the
internal control standards agencies are to use to provide reasonable assurance that
the objectives of the agency are being achieved. Some of these standards include:


Internal control should provide for an assessment of the risks the agency
faces from both external and internal sources.
Pertinent information should be identified, recorded and distributed to
management and others within the entity in a form and time frame that
permits people to perform their duties efficiently and enables them to
carry out their internal control responsibilities.
Activities need to be established to monitor performance measures and
indicators.
Managers need to compare actual performance to planned or expected
results.
4	5 CFR § 630.1003 (a)(1).
5	5 CFR § 630.1003(d).
17-P-0374
5

-------
LBB Did Not Monitor Leave Bank Balance and EPA Managers Did Not
Maintain Required Records to Assess Performance or Solvency
The LBB did not routinely monitor the bank balance or the bank's solvency to
determine whether the amount of leave was adequate to meet future obligations.
Although the board informally discussed the bank's balance on an ad hoc basis,
the board did not regularly monitor the balance of leave hours in the bank,
document these bank balance discussions, or perform any measurements or
calculations to assess the solvency or adequacy of the bank balance for future use
and demands.
In addition, the program staff did not maintain the information required by
5 CFR § 630.1012 for the VLBP listed in the previous section. All the required
data elements were available except for the gender of each recipient. However,
the data was accessible in raw form that was not useful for assessing the current
or future needs or the leave bank's solvency. For the required data elements to be
useful, VLBP managers should gather the data elements, summarize and analyze
the results, and present the data to the LBB for consideration.
According to two of the LBB members, the total number of hours allowable to
recipients per year increased over the last several years, from 240 hours to the
current 280 hours. OHR staff provided two OHR Director's memorandums
announcing that the maximum leave bank hours allowed per year were increased.
The first memo, issued in September 2009, announced an increase from 200 to
240. The second memo, issued in May 2011, announced the maximum hours
increase from 240 to 280. However, OARM had no documentation to show why
and how these decisions for change were made.
The EPA's authorized full-time employee levels decreased by nearly 2,000
(11 percent) from 17,359 in 2011 to 15,376 in 2016. Conversely, the leave bank
balance increased about 23 percent from 2013 to 2016,6 even while the maximum
allowable hours provided to recipients increased to 280 hours per recipient. The
leave year starting balance in 2013 was nearly 206,000 hours; in 2016, the
balance had risen to over 253,000. Figure 2 provides details.
6 OARM was unable to provide us with the leave bank starting balances for years 2011 or 2012.
17-P-0374
6

-------
Figure 2: Number of full-time employees (2011-2016) and leave bank starting
balances in hours (2013-2016)
2011
2012
2013
2014
2015
2016
EPA OIG graphic.
In 2016, the EPA had 15,376 authorized full-time positions and about 8,200 leave
bank members. According to the LBB members, the leave bank balance has
increased over recent years and, as of June 30, 2016, contained 249,789 hours of
annual leave valued at about $10.8 million for possible use by leave bank
recipients.
We compared the EPA VLBP practices with practices at similar federal agencies
with a VLBP. According to the U.S. National Institutes of Health (NIH) VLBP
Program Manager, the NIH in 2016 had about 17,500 employees and 6,100 leave
bank members, yet its leave bank balance was around 110,000 hours. While the
two agencies are similar in size, the EPA leave bank balance may have been
disproportionately larger than necessary to support recipient needs. Further, the
NIH allows up to 720 hours from the leave bank per recipient per year—
480 hours for personal medical emergencies and 240 hours for family member
medical emergencies. The NIH LBB also has the authority to make changes to
how many hours a member must contribute to its bank each year, and how many
total hours are provided per year to recipients. While the EPA LBB can
recommend changes to the VLBP, the Assistant Administrator for OARM is the
decision authority. See Appendix B for more information about other federal
agencies' VLBP management best practices.
EPA management did not provide sufficient internal controls for the VLBP.
Although basic informal guidance was posted on the OHR website, OARM did
not develop and implement official policies and procedures to manage the leave
bank and govern the actions of the LBB. Also, OHR managers stated that there
have not been any risk assessments or program performance reviews of the
VLBP.
17-P-0374
7

-------
OHR managers and LBB members identified a lack of staff and high turnover of
staff and managers as challenges to managing the VLBP. The national program
coordinator is the only OHR staff member dedicated to working on the VLBP.
Further, the national program coordinator and the supervisor position (Director of
the OHR Diversity Recruitment & Employee Services Division) have been filled
using temporarily assigned personnel from other OHR or OARM positions. The
national program coordinator position was filled by temporary assignment from
October 2015 through December 2016 and the director position was assigned to
three managers, one permanent and two temporary, in under 2 years. On a
positive note, the director position was filled with a permanently assigned
manager in October 2016. However, since the director served as one of the three
LBB members, the turnover in that position impacted management of the LBB
and the VLBP overall. Also, one LBB member has served for more than
8 consecutive years—6 years longer than the 2-year term identified by EPA
guidance on the leave bank website.
Actions Taken as a Result of Our Audit
During the course of this audit, OHR personnel assessed the adequacy of VLBP
resources and staffing as we proposed in our discussion document. As a result,
OHR designated one additional permanent staff member to serve as a second
VLBP national program manager. This action took effect in January 2017, and
OHR provided support that verified the personnel action.
Conclusion
Without policies and procedures or the data provided by risk assessments,
performance reviews and other monitoring, OHR managers and LBB members do
not have the information to govern the program or determine whether program
goals are accomplished. These internal controls and the data provide management
the tools to properly protect the leave bank assets (i.e., hours) and prevent fraud,
waste or abuse. The LBB did not assess whether the bank balance was appropriate
and adequate for future needs. In addition, the LBB did not consider the historical
balance and use information to determine whether the contributions and allowed
hours per year were appropriate. As a result, the required voluntary contribution
for leave bank members and the maximum hours allowed annually for recipients
may not be appropriate.
EPA Did Not Always Adequately Safeguard Sensitive Information
EPA Records Management for Leave Bank
EPA Records Management Policy, CIO 2155.3 (February 10, 2015), states:
EPA records must be maintained in an appropriate manner,
captured and organized to ensure timely search and retrieval for
17-P-0374
8

-------
internal Agency use as well as for responses to outside inquiries.
Sensitive records ... must be maintained with restricted access in
accordance with statutory and regulatory requirements.7
Also, the policy requires records to be maintained "so they can be accessed [only]
by staff with a need to know the information for appropri ate business reasons."
Records must be secured "to protect the legal and financial rights of the
government and persons affected by government activities." According to the
EPA's General Records Schedule 0565, leave bank records are to be destroyed
1 year after the end of the year in which the file is closed.
Leave Bank Case Files Left Unsecured
According to the EPA's former
VLBP national program manager,
who retired in the fall of 2015,
cabinets in which leave bank case
files were stored were not locked.
During our site visit to the OHR in
April 2016, we observed about 100
recipient case files that were left
outside the file cabinets and on a
desk inside an unoccupied office
cubicle. The case files were left out
at the end of the work day on a
Thursday evening and the national
leave bank coordinator was not due
back to the office until the
following Monday. It appears that
these recipient case files were left out and unlocked over a weekend period. Also,
we observed multiple case files labeled 2013 among those that were out of the
cabinets.
The VLBP staff stated that this instance of case files not being stored in a locked
cabinet was a single occurrence and the records are now always locked up. At the
time of our site visit, the national leave bank coordinator was the only staff
dedicated, full-time, to the VLBP. Processing the recipient applications and
preparing for the LBB meetings were the highest priorities. Regarding the 2013
case files still on hand, the national leave bank coordinator explained that she had
not yet had the time to sort out the older files for di sposal, as she focused on
higher-priority leave bank activities.
OHR cubicle with leave bank case files in EPA
headquarters, April 2016. (EPA OIG photo)
7 Medical information associated with individuals, such as medical conditions and medical certifications, are
sensitive information.
17-P-0374
9

-------
Conclusion
Due to sensitive information not being properly safeguarded, employees who
participate in the leave bank program were at an increased risk of personal and
sensitive medical information being obtained by parties that should not have
access to such information.
EPA LBB Did Not Assess or Verify Medical Certifications
Federal Regulations, Standards and Best Practices for VLBP
Medical Certifications
Title 5 CFR Chapter I, Subpart J, § 630.1006(c)(3), requires recipient applications
to include a certification from one or more physicians, or other appropriate
experts, with respect to the medical emergency, if the LBB so requires. The
EPA's LBB requires this certification.
The U.S. Government Accountability Office's Standards for Internal Control in
the Federal Government states, "Internal control should be designed to provide
reasonable assurance regarding prevention of or prompt detection of unauthorized
acquisition, use, or disposition of an agency's assets." It further states:
Control activities are an integral part of... accountability for
stewardship of government resources and achieving effective
results. Control activities ... include a wide range of diverse
activities such as approvals, ... verifications, reconciliations, ...
and the creation and maintenance of related records. ...
The NIH's VLBP managers have implemented best management practices to
verify the validity and reliability of recipients' medical certifications. This is done
by using an independent medical advisor, relying on medical guidelines resources,
and allowing NIH employees to voluntarily allow NIH VLBP managers to discuss
medical information with certifying doctors. Appendix B provides more
information about other federal agencies' VLBP management best practices.
Guidance and Tools Needed to Help Assess Medical Certifications
The EPA LBB relies on the medical certifications that applicants submit without
assessing or verifying the validity and reliability of the certification. The medical
certifications provide key information to enable the LBB to determine such
matters as the length of time the emergency leave should cover and the required
number of emergency leave hours to provide a recipient. The LBB members
accept the medical certificate information without comparing other sources of
information and do not possess the medical expertise necessary to determine
whether the information is reasonable. Although LBB members stated that they
have discussed unfamiliar medical situations amongst themselves and have in the
17-P-0374
10

-------
past performed some research of specific cases, these evaluations occurred on an
ad hoc basis and were not documented.
The EPA has not developed official policies and procedures to govern the LBB
applicant review and approval process, including verification of medical
certifications. Also, the LBB has not routinely used any mechanisms or tools to
assess or verify the validity and reliability of medical certifications, such as using
reliable medical guidelines resources, using an independent medical advisor, or
developing forms for obtaining an employee's voluntary authorization of medical
disclosure.
Conclusion
The stewardship of about $10.8 million in leave bank resources is at an increased
risk of fraud, waste and abuse because the EPA has not implemented adequate
internal controls to verify the validity and reliability of recipients' medical
certifications. Without proper assessment or verification of certifications, the LBB
could approve an application for leave bank hours that should not be approved.
Recommendations
We recommend that the Assistant Administrator for Administration and
Resources Management:
1. Develop and implement official policies and procedures to administer the
Voluntary Leave Bank Program, to include:
a.	Governing the Leave Bank Board's decision-making, including
documenting those decisions.
b.	Requiring Office of Administration and Resources Management
staff to conduct annual trend analyses of recent years' data to
assess the bank's solvency and identify any appropriate
adjustments to hours allowed to be drawn or minimum required to
be contributed by members.
c.	Rotating the Leave Bank Board members to adequately staff the
board for appropriate amounts of time.
d.	Requiring the Office of Human Resources to prepare and submit
an annual report on program performance and activity.
e.	Establishing adequate controls for assessing and verifying the
validity of medical certifications, to include researching best
practices and tools used by other federal agencies.
17-P-0374
11

-------
f. Requiring leave bank staff to annually assess, identify and dispose
of records that meet disposal criteria.
2.	Conduct a risk assessment of the Voluntary Leave Bank Program to
identify program weaknesses and vulnerabilities, and develop additional
internal controls as needed.
3.	Starting with leave year 2016 and on an annual basis thereafter, gather and
analyze the required Voluntary Leave Bank Program data and provide the
results to the Leave Bank Board and leave bank managers for use in
decision-making.
4.	Train Voluntary Leave Bank Program staff on the records management
policy and the requirements for case files and records retention.
Agency Response and OIG Evaluation
OARM agreed with our recommendations and provided corrective actions and
estimated completion dates that meet the intent of the recommendations. OARM
also provided additional attachments as support for the corrective actions they
have completed.
To address Recommendation 2, OARM conducted a VLBP risk assessment and
finalized its Risk Assessment Plan in June 2017. To address Recommendation 4,
OHR trained the VLBP staff on records management in February 2017, and on
June 7, 2017, issued a memorandum to VLBP managers reminding them to adhere
to the EPA's records management policy for maintaining case files and records
retention. As a result, Recommendations 2 and 4 are considered completed.
To address Recommendation 1, OHR completed VLBP management benchmarking
with other federal agencies, and is using the results to develop and implement
official policies and procedures for administering the EPA's VLBP. OARM
indicated it plans to implement official policies and procedures for non-bargaining
unit employees and notify the national unions regarding proposed policies and
procedures for bargaining unit employees by March 15, 2018. Planned corrective
actions for Recommendation 1 are considered acceptable.
To address Recommendation 3, OHR indicated it plans to gather and analyze the
required data, at least annually, so that OHR VLBP managers and the EPA's LBB
can use the analyses results in decision-making. OHR estimated completing these
corrective actions by December 2017. Planned corrective actions for
Recommendation 3 are considered acceptable.
The agency's detailed response is in Appendix C.
17-P-0374
12

-------
Chapter 3
Reliable Timekeeping Data Needed to Determine
Leave Bank Hours Used
Inaccurate timekeeping data incorrectly showed that leave bank recipients used
more than the allowed 280 hours per leave year,8 and conflicted with data in the
payroll system. Federal internal control standards require that supervisors have
reliable information to perform their duties efficiently. The inaccurate
timekeeping occurred because the timekeeping system did not have working
controls to prevent employees from entering more leave bank hours than allowed.
Supervisors and other EPA staff were unable to properly manage time and
attendance because the system contained conflicting data. As a result, supervisors
cannot properly verify employees' time and prevent fraud.
Federal Standards Related to Timekeeping and Reporting
The U.S. Government Accountability Office's Standards for Internal Control in
the Federal Government states, "Internal control should be designed to provide
reasonable assurance regarding prevention of or prompt detection of unauthorized
acquisition, use, or disposition of an agency's assets." It further states:
Control activities are an integral part of... accountability for
stewardship of government resources and achieving effective
results.
Control activities ... include a wide range of diverse activities such
as approvals, ... verifications, reconciliations, ... and the creation
and maintenance of related records. ...
Information should be recorded and communicated to management
and others within the entity who need it and in a form and within a
time frame that enables them to carry out their internal controls
and other responsibilities.
For an entity to run and control its operations, it must have
relevant, reliable, and timely communications relating to internal
as well as external events. ... Pertinent information should be
8 During the time period covered by our review, OARM used the leave year as the year of measure for the hours
allowed annually. In January 2017, OARM revised the year of measure to the taxable year.
17-P-0374
13

-------
identified, captured, and distributed in a form and time frame that
permits people to perform their duties efficiently.
VLBP, Voluntary Leave Transfer Program, and EPA Timekeeping and
Payroll Systems
The EPA VLBP website guidance allowed an employee to use up to 280 leave
bank hours per leave year for qualified periods of medical emergency. Once
approved by the LBB, the national program coordinator enters the approved leave
bank hours into the timekeeping system and the payroll system to make the hours
available to the leave bank recipient.
The EPA also has a Voluntary Leave Transfer Program that provides the
opportunity for an employee who has exhausted his/her paid leave due to a
medical emergency to receive annual leave donated by other federal employees.
The leave transfer program is separate from, but similar to, the VLBP, as it was
designed to assist employees who are or will be facing a significant financial
hardship due to a medical emergency. The main differences in these separate
programs are that the VLBP requires membership and provides "banked" hours,
while the leave transfer program does not require membership and leave donated
from employees goes directly to a specific leave recipient. VLBP members may
receive leave from the leave transfer program or simultaneously with VLBP
hours. We did not audit the leave transfer program, but learned about how the two
programs may overlap when the VLBP recipient uses both.
PPL is the EPA timekeeping system, and the FPPS is the EPA payroll system of
record. The U.S. Department of the Interior's Interior Business Center hosts FPPS
and allows the EPA and other federal agencies to use it to generate payroll; the
system interfaces with PPL. EPA employees enter their time and attendance
data—and timekeepers review and supervisors review and approve data—in PPL.
The PPL data is transmitted to FPPS, and that system generates the payroll. PPL
has time reporting codes for the various types of leave that employees may use.
PPL sums the types of leave hours used by these codes. OHR managers reported
that when an employee receives leave from both the VLBP and the leave transfer
program during the same pay periods, the FPPS will apply donated leave hours
first until exhausted. Then FPPS applies the VLBP hours that are available. This
occurs regardless of how the PPL time reporting codes are entered.
Timekeeping Data for Leave Bank Hours Were Inaccurate
The PPL data for 75 VLBP recipients during 2014 and 2015 (three recipients had
over 280 hours in both years, for a total of 78 over-hour cases) showed that these
recipients used more than the 280 hours allowed per leave year. In one case, the
PPL data for a recipient showed 791.5 total hours (511.5 hours above the
maximum limit). About 23 percent of the 78 leave bank over-hours cases showed
17-P-0374
14

-------
400 or more leave bank hours used (i.e., 120 or more hours above the 280-hour
limit) in a single leave year.
OHR managers stated the PPL data was incorrect and that FPPS controls prevent
employees from receiving more than the allowed 280 hours per year. They
pointed out that when a leave bank recipient also has received donated leave
through the leave transfer program, the FPPS system draws first from the donated
leave balance before using any leave bank hours. Once the donated leave is
exhausted, FPPS then applies the leave bank hours up to 280 but no more. OHR
further explained that manual time card corrections in PPL may result in
additional differences between the two systems' data. We analyzed FPPS data for
a sample of the 75 employees and confirmed that none received more than 280
leave bank hours in a leave year. OHR reinforced that FPPS is the official system
of record and that system's data is to be relied upon. OHR personnel noted,
however, that they cannot make improvements to PPL because the Office of the
Chief Financial Officer manages that system.
Leave bank recipients' supervisors relied on PPL system controls to limit leave
bank hours and could not easily track the hours that recipients input to verify that
employees were not using more than the 280-hour limit. Supervisors said they
could not view the number of leave bank hours or leave transfer hours an
employee used. They also seemed not to know how the leave bank program
works. Supervisors need training on the VLBP and leave transfer programs, and
tools for how to manage or monitor the hours.
Conclusion
The PPL system did not have working controls that limit the number of leave
bank hours a recipient can input or enter to the 280 hours allowed. The conflicting
timekeeping and payroll data did not provide employees, their supervisors and
other applicable EPA staff with accurate data to properly manage time and
attendance, leave bank hours, or leave transfer hours. As a result, the supervisors
cannot properly verify employees' time and prevent fraud.
Recommendations
We recommend that the Assistant Administrator for Administration and
Resources Management and the Chief Financial Officer work together to:
5.	Develop and implement a method for supervisors to view real-time data of
employee leave bank and leave transfer balances in PeoplePlus and the
Federal Personnel Payroll System.
6.	Issue guidance to, and train, supervisors on the leave bank and leave
transfer programs and their roles and responsibilities for approving and
attesting timesheets of employees using the leave programs.
17-P-0374
15

-------
Agency Response and OIG Evaluation
OARM and the Office of the Chief Financial Officer agreed with our
recommendations and provided corrective actions and estimated completion dates
that meet the intent of the recommendations.
To address Recommendation 5, the Office of the Chief Financial Officer made
changes in the PPL system, and OHR changed VLBP (and leave transfer) input
processes that result in the leave bank data feeding from FPPS into PPL (occurs
nightly). The agency response also identified that while leave information is in
PPL, supervisors and PPL coordinators may gain access to the most recent official
leave balance information for their employees by requesting access to the Interior
Business Center's Datamart (from OARM) to run a leave balance report. As a
result of actions taken, Recommendation 5 is considered completed.
To address Recommendation 6, OARM and Office of the Chief Financial Officer
indicated that they are collaborating to issue guidance and create and provide
supervisory training on the leave bank and leave transfer programs, as well as
roles and responsibilities for approving and attesting employees' timesheets.
Completion is expected by December 2017. Planned corrective actions for
Recommendation 6 are considered acceptable.
The agency's detailed response is in Appendix C.
17-P-0374
16

-------
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Potential
Planned	Monetary
Rec. Page	Completion	Benefits
No. No.	Subject	Status1 Action Official	Date	(In $000s)
R Assistant Administrator for 3/15/18
Administration and
Resources Management
b.	Requiring Office of Administration and Resources
Management staff to conduct annual trend analyses of
recent years' data to assess the bank's solvency and
identify any appropriate adjustments to hours allowed to
be drawn or minimum to be contributed by members.
c.	Rotating the Leave Bank Board members to adequately
staff the board for appropriate amounts of time.
d.	Requiring the Office of Human Resources to prepare and
submit an annual report on program performance and
activity.
e.	Establishing adequate controls for assessing and verifying
the validity of medical certifications, to include researching
best practices and tools used by other federal agencies.
f.	Requiring leave bank staff to annually assess, identify and
dispose of records that meet disposal criteria.
1 11 Develop and implement official policies and procedures to
administer the Voluntary Leave Bank Program, to include:
a. Governing the Leave Bank Board's decision-making,
including documenting those decisions.
12 Conduct a risk assessment of the Voluntary Leave Bank
Program to identify program weaknesses and vulnerabilities, and
develop additional internal controls as needed.
12 Starting with leave year 2016 and on an annual basis thereafter,
gather and analyze the required Voluntary Leave Bank Program
data and provide the results to the Leave Bank Board and leave
bank managers for use in decision-making.
12 Train Voluntary Leave Bank Program staff on the records
management policy and the requirements for case files and
records retention.
15 Develop and implement a method for supervisors to view real-
time data of employee leave bank and leave transfer balances in
PeoplePlus and the Federal Personnel Payroll System.
Assistant Administrator for 6/26/17
Administration and
Resources Management
Assistant Administrator for 12/29/17
Administration and
Resources Management
Assistant Administrator for 6/7/17
Administration and
Resources Management
Assistant Administrator for 6/18/17
Administration and
Resources Management
and Chief Financial Officer
15 Issue guidance to, and train, supervisors on the leave bank and
leave transfer programs and their roles and responsibilities for
approving and attesting timesheets of employees using the leave
programs.
Assistant Administrator for
Administration and
Resources Management
and Chief Financial Officer
12/29/17
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
17-P-0374
17

-------
Appendix A
Details on Scope and Methodology
To obtain an understanding of the internal controls for leave bank processes, we reviewed the
following criteria documents:
•	Federal Employees Leave Sharing Act of 1988, Subchapter IV, Voluntary Leave Bank
Program, § 6361-6373.
•	Title 5 CFR, Chapter I, Subchapter B, Part 630, Subpart J, Voluntary Leave Bank
Program.
•	Presidential Memorandum of January 15, 2015, Modernizing Federal Leave Policies for
Childbirth, Adoption, and Foster Care To Recruit and Retain Talent and Improve
Productivity.
•	U.S. Office of Personnel Management Guidance:
o Fact Sheet: Voluntary Leave Bank Program.
o Handbook on Leave and Workplace Flexibilities for Childbirth, Adoption, and
Foster Care.
•	U.S. Government Accountability Office's Standards for Internal Control in the Federal
Government, November 1999 (applicable to fiscal years 2000 through 2015) and
September 2014 (applicable to fiscal year 2016 and forward).
•	Office of Management and Budget Circular A-123, Management's Responsibility for
Internal Control, December 21, 2004.
•	Memorandum of Understanding, EPA Leave Bank Program.
•	44 U. S. C. Chapter 31, Records Management by Federal Agencies, 2011.
•	44 U.S.C. Chapter 33, Disposal of Records, 2008.
•	EPA's Records Management Policy, February 10, 2015.
•	EPA Records Schedule 0565, Donated Leave Program Case Files, December 31, 2013.
•	EPA's Voluntary Leave Bank Program Guidance.
To determine whether the EPA managed the VLBP in accordance with applicable laws,
regulations and guidance, we performed the following tasks:
•	Identified, gathered and analyzed applicable criteria related to requirements for the
VLBP.
•	Used the criteria to evaluate the VLBP's internal and management controls for preventing
and detecting fraud, waste and abuse.
•	Performed a literature search to review and summarize previous audits, evaluations, other
reports and articles that were relevant to this audit.
•	Obtained and assessed leave bank data from the EPA time and attendance PPL and
payroll FPPS systems for employees participating in the VLBP.
•	Conducted a site visit to OHR offices in Washington, D.C., where we interviewed VLBP
managers, staff and LBB members; performed reviews of case files for a judgmental
sample of 28 leave bank recipients (based on EPA offices with a high number of leave
17-P-0374
18

-------
bank recipients and the recipients with the most leave bank hours received); obtained
PPL and FPPS walk-throughs; and observed the VLBP case files and storage location.
•	Analyzed recipient data from PPL and FPPS to identify those employees who may have
received leave bank hours over the maximum 280 hours allowed per leave year.
•	Obtained PPL time card data for a judgmental sample of eight VLBP recipients with over
280 hours (based on high leave bank hours received) to assess leave used by pay period
in 2014 and 2015 and determine the applicable supervisors/approving officials.
•	Interviewed five VLBP recipients' supervisors for information on their roles, and the
processes they use related to time card reporting.
•	Reviewed VLBP records, including internal performance reports for the program, such as
data on leave bank balances, leave bank members, and leave bank withdrawals.
•	Reviewed individual VLBP recipient case files, including applications, medical
certifications, leave balances, and LBB decisions. In reviewing medical certifications, we
searched online for the medical practitioners' names, addresses and current licensing.
•	Examined the approval process for leave bank applicants.
•	Interviewed VLBP staff, including LBB members, the VLBP national program manager,
and two regional coordinators, to obtain information on the processes the EPA used to
manage the VLBP and safeguard resources.
To obtain information about best practices used by other federal agencies for managing VLBPs,
we interviewed personnel and reviewed documentation from three other federal agencies:
•	U.S. National Institutes of Health.
•	U.S. Department of Justice.
•	U.S. Department of Agriculture's Farm Service Agency.
17-P-0374
19

-------
Appendix B
Leave Bank Best Practices of Other Federal Agencies
We contacted three other federal agencies operating VLBPs and gathered information from the
managing personnel about practices and tools used to achieve efficiency and effectiveness of
their respective programs. The three agencies we contacted were the:
•	U.S. National Institutes of Health (NIH).
•	U.S. Department of Justice's (DOJ's) Executive Office of the U.S. Attorneys (EOUSA).
•	U.S. Department of Agriculture's (USDA's) Farm and Foreign Agricultural Services
(FFAS).
The NIH and DOJ's EOUSA had relatively comparable numbers of employees in 2016, with
about 17,500 and 16,000, respectively; the EPA had about 15,300 employees in 2016. The
USDA's FFAS was much smaller, with about 1,700 employees in 2016. Although NIH seemed
to have the most robust and proactive management practices, each of the three agencies used
practices to manage their VLBP that EPA did not. We compared the practices of the three
agencies to those the EPA uses to identify best practices at other agencies that the EPA could
implement to improve how it manages its leave bank.
National Institutes of Health
The VLBP program manager provided details on how the NIH leave bank is managed. In May
2016, the NIH had about 17,500 employees, 6,100 leave bank members, and 110,000 leave hours
in the bank. The NIH allows each leave bank recipient to receive up to 720 hours per year—
480 hours for personal medical emergencies and 240 hours for family member medical
emergencies. Below are NIH best practices regarding the program management structure and
controls to process and review recipient applications and medical certifications.
•	The NIH VLBP Management Structure:
•S The program has a detailed set of written procedures for managing its program.
¦S The LBB consists of three permanent members and three alternate members. The
LBB has the authority to determine the number of hours allowed to recipients
each year, the number of hours that members must contribute, and the number of
hours that can be donated.
•S The LBB delegated the daily VLBP operations, such as the review and approval
of leave bank recipient applications, to the VLBP staff.
•S VLBP staff include a full-time program manager and two contractor case
managers. Leave bank staff review applications daily instead of every 2 weeks as
the EPA does.
•S VLBP staff use a share point site to track all recipient cases. The LBB has access
to the data in the share point and can see the status of recipients at any given time.
The LBB can directly pull reports from the share point, as needed or desired.
17-P-0374
20

-------
~
~
~
VLBP staff evaluate program effectiveness by surveying leave bank members,
tracking the timeliness of recipient application processing, and developing
statistical reports about the number of members and recipients over time. (See
Figure 3 for the 2015 At A Glance slide used in February 2016 by the N1H VLBP
program manager as part of a larger presentation on leave bank data and program
performance information to the NIH LBB.)
VLBP staff use the data to prepare program reports presented and discussed
during quarterly meetings with the LBB.
Although assessing the leave bank balance and solvency is not included in the
detailed written procedures, VLBP staff and the LBB discuss the balance each
year and consider past trends, such as the hours deposited in the bank and hours
allocated to recipients. The LBB makes decisions based on those historical trends.
Figure 3: The 2015 At A Glance slide
2015 At A Glance
r 1
New Employee
Enrollment:
47%
l. J
1
r 1
Cases Processed:
440
2014: 342
L


Individual
Recipients:
282
2014: 224

r ^
Hours Distributed:
25,616
2014: 41,039
Ave. Hours
Distributed Per
Recipient: 91
2014: 183
LB Balance at End
of Year:
82,180 Hours
2014: 45,393


~ National Institutes of Health
Crttc of Mfinaoemau
Offtos of Human Resources
NIH graphic, used at the NIH LBB meeting held in February 2016.
The NIH Leave Bank Controls to Verify Medical Certifications:
S VLBP staff contact doctors referenced in medical certification forms to verify that
they indeed completed the form and signed it.
S VLBP staff use an MD Guidelines database to determine whether the information
presented on the medical certification form is reasonable.
S VLBP staff have an authorization for disclosure form that employees may sign
that authorizes the NIL! VLBP staff to discuss the content of the medical
certification with doctors.
S When necessary, VLBP staff use an outside Federal Occupational Health (part of
the U.S. Department of Health and Human Services) consultant to gather an
expert medical opinion of the medical emergency. This consultant can also
contact doctors to discuss medical certifications.
17-P-0374
21

-------
Department of Justice/Executive Office of the U.S. Attorneys
The DOJ/EOUSA's VLBP coordinator provided details on how that leave bank is managed, and
on operating procedures and guidance. In 2016, the EOUSA had about 16,000 employees, the
leave bank members numbered about 2,300, and leave hours fluctuated from 5,000 to 7,000. The
EOUSA allows up to 160 hours from the leave bank per recipient per year for personal or family
member medical emergencies. Below are DOJ best practices regarding the program management
structure and controls to process and review recipient applications and medical certifications.
•	DOJ procedures establish that its LBB will consist of three members, and they can
designate alternate board members, when available.
•	The LBB has the authority to set the maximum number of leave hours allowed to
recipients per year and to adjust the maximum hours allowed when needed.
•	The LBB delegated daily operations to the VLBP administrator. These routine operations
included processing and approving membership applications, reviewing and approving
recipient applications when all the leave bank criteria are met, and denying recipient
applications when criteria are not met.
•	The LBB delegated approval authority to the VLBP administrator for recipients of
routine, non-elective medical emergencies such as childbirth or routine surgical
procedures having a standard recuperation period, and extensions on previously-approved
cases with proper medical documentation.
•	VLBP staff use online resources, such as webMD and the Mayo Clinic website, and
perform internet searches to gain an understanding of medications and medical procedures.
•	DOJ VLBP staff work with their General Counsel, as needed, on cases with potentially
sensitive issues, to prevent discrimination complaints.
U.S. Department of Agriculture/Farm and Foreign Agricultural Services
The USDA's FFAS VLBP manager provided details on how the FFAS leave bank is managed,
and on operating procedures and guidance. FFAS consists of three smaller agencies, each having
a separate balance of hours within the one leave bank. The VLBP manager has the authority to
move the leave hours between the three agency banks as needed. The FFAS component is very
small in comparison to the EPA. In June 2016, the VLBP manager estimated the total employees
at about 1,700. The leave bank for one of the three component agencies had only 14 members
and a starting balance of about 2,850 leave hours. The FFAS allows up to 160 hours from the
leave bank per recipient per year for personal or family member medical emergencies. Below are
FFAS best practices regarding the program management structure and controls to process and
review recipient applications and medical certifications.
•	The FFAS VLBP offers a new member summer enrollment period.
•	The LBB has the authority to grant exceptions to donor limitations.
•	The LBB may request a second opinion from a medical expert or physician. If they do,
the medical charges are paid by the agency.
•	The VLBP Frequently Asked Questions document contains an official "Notice" that
states that falsifying or altering any government or medical document(s) can lead to
disciplinary action, including suspension from work or termination of employment.
17-P-0374
22

-------
Appendix C
Agency Response and OIG Evaluation
[June 30, 2017]
MEMORANDUM
SUBJECT: Management Response to Office of Inspector General Draft Report, "EPA Needs
to Increase Oversight of Leave Bank Program to Improve Efficiency and Reduce
Risk of Misuse" (Project OA-FY16-0063)
FROM: Donna J. Vizian, Acting Assistant Administrator//signed//
Office of Administration and Resources Management
David A. Bloom, Acting Chief Financial Officer//signed//
Office of the Chief Financial Officer
TO:	Arthur A. Elkins, Jr., Inspector General
Thank you for the opportunity to review and comment on the findings and recommendations in
the draft report for the subject audit. The U.S. Environmental Protection Agency's Office of
Inspector General conducted this audit to determine if the EPA had established and implemented
internal controls for the Voluntary Leave Bank Program to prevent and detect fraud, waste and
abuse of the program.
The agency concurs with all six recommendations. Attachment 1 is our response to each
recommendation, including the intended corrective action and estimated completion date for
each recommendation. Also attached are the agency's Voluntary Leave Bank Program
Benchmark Report (Attachment 2), a Risk Management Plan (Attachment 3), OHR's June 7,
2017, memorandum regarding EPAs records management policy for the VLBP (Attachment 4),
and draft Risk Assessment Worksheet Instructions (Attachment 5).
The Office of Administration and Resources Management, which manages the VLBP, requests
closure of recommendations 2, 4 and 5. OARM VLBP staff were trained on records management
in February 2017, OARM completed a risk assessment of the VLBP, and the Office of the Chief
Financial Officer implemented changes to PeoplePlus to improve the leave bank process in June
2017.
The EPA appreciates the work of the OIG in planning and conducting this audit. If you have
questions regarding this response, please contact Ms. Linda Gray, Director, Office of Human
Resources, at (202) 564-4606 or Grav.Linda@epa.gov.
17-P-0374
23

-------
Attachments
1.	EPA Response to OIG Report
2.	EPA Voluntary Leave Bank Program Benchmark Report
3.	Risk Management Plan
4.	OHR Memorandum to VLBP Managers, dated June 7, 2017
5.	Draft Risk Assessment Worksheet Instructions
cc: John Showman
Howard Osborne
Linda Gray
Quentin Jones
Wesley Carpenter
Lynnann Hitchens
Marian Cooper
Matthew Bell
Lauren Lemley
Bobbie Trent
Benita Deane
Bisa Cunningham
Debbi Hart
Krysti Corbett
Cheri Hembrey
17-P-0374
24

-------
Attachment 1, EPA Response to OIG Report
EPA Response to the OIG's Draft Report No. OA-FY16-0063 "EPA Needs to Increase Oversight
of Leave Bank Program to Improve Efficiency and Reduce Risk of Misuse"
No.
OIG Recommendations
Planned Corrective Action
Estimated
Completion
1
Develop and implement official
policies and procedures to
administer the Voluntary Leave
Bank Program, to include:
a.	Governing the Leave Bank
Board's decision making,
including documenting those
decisions.
b.	Requiring Office of
Administration and Resources
Management staff to conduct
annual trend analysis of recent
years' data to assess the bank's
solvency and identity any
appropriate adjustments to hours
allowed to be drawn or required to
be contributed by members.
c.	Rotating the Leave Bank Board
members to adequately staff the
board for appropriate amounts of
time.
d.	Requiring the Office of Human
Resources to prepare and submit
an annual report on program
performance and activity.
e.	Establishing adequate controls
for assessing and verifying the
validity of medical certifications,
to include researching best
practices and tools used by other
federal agencies.
f.	Requiring VLBP staff to
annually assess, identity and
dispose of records that meet
disposal criteria.
Concur. By March 15, 2018, OARM will
implement official policies and procedures for non-
bargaining unit employees and notify the national
unions regarding proposed policies and procedures
for bargaining unit employees. Unfortunately, we
cannot put a timeframe on completion of union
negotiations/implementation.
In May 2017, the Office of Human Resources
completed benchmarking with other federal
agencies, including reviewing the policies and
procedures for the voluntary leave bank programs
of those agencies. OHR is utilizing the results of
the benchmarking to develop and implement
official policies and procedures for administering
the U.S. Environmental Protection Agency's
VLBP. The policies and procedures will: a) govern
the LBB's decision making, including documenting
those decisions; b) require VLBP staff to conduct
annual trend analysis of VLBP data to assess the
bank's solvency and to identify any appropriate
adjustment to hours to be withdrawn or
contributed; c) rotate the LBB; d) require VLBP
staff to prepare and submit an annual report on
program performance and activity; e) establish
adequate controls for assessing and verifying the
validity of medical certifications; and f) require
VLBP staff to annually assess, identify and dispose
of records that meet disposal criteria.
Attachment 2 is a summary of OHR's
benchmarking for the OIG's information.
March 15,
2018
2
Conduct a risk assessment of the
VLBP to identity program
weaknesses and vulnerabilities,
and develop additional internal
controls as needed.
Concur. In June 2017, OHR finalized a risk
assessment of the VLBP. The risk assessment
involved the identification and analysis of relevant
risks, assessment of the likelihood of occurrence,
and determination of what actions the VLBP has
taken or will take to manage the risks to ensure the
Completed
17-P-0374
25

-------


effectiveness of program internal controls in
addressing program risks. Attachment 3 is a copy
of the completed Risk Assessment Plan.

3
Starting with leave year 2016 and
on an annual basis thereafter,
gather and analyze the VLBP data
and provide the results to the LBB
and VLBP managers for use in
decision making.
Concur. At least annually, OHR will gather and
analyze the following data required by Title 5 of
the Code of Federal Regulations, Section 630,
Subpart J: (1) the number of leave bank members
for each leave year; (2) the number of applications
approved for medical emergencies affecting the
employee and the number of applications approved
for medical emergencies affecting an employee's
family member; (3) the grade of each leave
contributor and the total amount of annual leave the
employee contributed to the bank; and (4) the grade
and gender of each leave recipient and the total
amount of annual leave employee actually used.
OHR VLBP managers and the EPA's LBB will use
the results of the analysis in decision making as
outlined in the VLBP policies and procedures.
December 29,
2017
4
Train VLBP staff on the records
management policy and the
requirements for case file and
records retention.
Concur. The VLBP staff received records
management training on February 22, 2017.
Additionally, on June 7, 2017, OHR issued a
memorandum to VLBP managers reminding them
to adhere to the EPA's records management policy
for maintaining case files and records retention.
The memorandum also includes a requirement for
the VLBP managers to retain VLBP case files in a
confidential manner, identifies the time frame for
retaining and destroying files, and requires that all
files currently retained beyond the minimum
retention period be immediately destroyed after
they are no longer in use.
Attachment 4 is a copy of OHR's memorandum.
Completed
5
Develop and implement a method
for supervisors to view real-time
data of employee leave bank and
leave transfer balances in
PeoplePlus and the Federal
Personnel and Payroll System.
Concur. Effective June 18, 2017, The Office of the
Chief Financial Officer implemented changes to
PeoplePlus, the agency's time and attendance
system, to improve the leave bank process. The
implemented changes eliminated OHR's usage of
the PeoplePlus HR module and the accrual pages.
Once a leave bank member's application is
approved and the hours are awarded, the leave
bank coordinator enrolls the leave bank recipient in
a leave bank or leave share emergency/occurrence
in FPPS. The leave bank coordinator inputs the
employee's name, employee ID, emergency
type/occurrence (IBC field), emergency start date,
and leave bank hour awards. With the new process,
the employee's name, employee ID, emergency
start date and emergency type/occurrence is
transferred to PeoplePlus on a nightly basis. The
transfer information is populated into PeoplePlus
and grants the leave bank recipient access to all
leave bank/leave share time reporting codes. The
VLBP's staff provides the leave bank recipient with
detailed instructions regarding which codes to use
Completed
17-P-0374
26

-------


for each emergency occurrence. Once the VLBP's
staff is informed that the medical emergency is
over, they input the end date into FPPS to close the
leave bank occurrence. When the end date is
inputted into FPPS, the nightly transfer will update
the data and populate the same information to
PeoplePlus after which all leave bank codes are
deactivated for the leave bank/leave share
recipient.
FPPS is the official repository for all leave.
Employees have access to their Leave and Earning
Statements via Employee Express. While leave
information is available in PeoplePlus, supervisors
and PeoplePlus coordinators may gain access to the
most recent official leave balance information for
their employees by requesting access to the IBC
Datamart (from OARM) to run a leave balance
report.

6
Issue guidance to, and train,
supervisors on the leave bank and
leave transfer programs and their
roles and responsibilities for
approving and attesting timesheets
of employees using the leave
programs.
Concur. OARM and OCFO are collaborating to
issue guidance. Create and provide supervisory
training to on the leave bank and leave transfer
programs and their roles and responsibilities for
approving and attesting employees' timesheets.
December 29,
2017
17-P-0374
27

-------
Appendix D
Distribution
The Administrator
Chief of Staff
Chief of Staff for Operations
Deputy Chief of Staff for Operations
Assistant Administrator for Administration and Resources Management
Chief Financial Officer
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Chief Financial Officer
Deputy Assistant Administrator for Administration and Resources Management
Director, Office of Human Resources, Office of Administration and Resources Management
Deputy Director, Office of Human Resources, Office of Administration and
Resources Management
Director, Office of Technology Solutions, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of the Administrator
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 Human Resources, Office of Administration and
Resources Management
17-P-0374
28

-------