£
<
33
O
\
^an-%
&
O
¦z
111
CD
X PR0^°
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Spending Taxpayer Dollars
EPA Not Fully Compliant
With Overtime Policies
Report No. 15-P-0293
September 22, 2015
Scan this mobile
code to learn more
about the EPA OIG.

-------
Report Contributors:
Angela Bennett
Safiya Chambers
Abbreviations
CFR
Code of Federal Regulations
EPA
U.S. Environmental Protection Agency
OA
Office of the Administrator
OAR
Office of Air and Radiation
OARM
Office of Administration and Resources Management
OCFO
Office of the Chief Financial Officer
OECA
Office of Enforcement and Compliance Assurance
OEI
Office of Environmental Information
OIG
Office of Inspector General
OTAQ
Office of Transportation and Air Quality
TCTO
Travel Compensatory Time Off
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.gov
More information at www.epa.gov/oiq/hotline.html.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (241OT)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oig
Subscribe to our Email Updates
Follow us on Twitter @EPAoig
Send us your Project Suggestions

-------
^tDsx
* O \
I® *
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
15-P-0293
September 22, 2015
Why We Did This Review
On April 9, 2014, a
U.S. Senator requested the
U.S. Environmental Protection
Agency (EPA) Office of
Inspector General (OIG) to
examine whether the agency:
(a)	properly documents how
overtime is distributed and, if so,
identify the process that is used;
(b)	has a specific breakdown of
activities for employees who
received overtime during the
last 2 fiscal years; and (c) has
an effective means to ensure
employees are not
compensated overtime for
travel. We conducted an audit to
address the Senator's request.
This report addresses the
following EPA goal or
cross-agency strategy:
• Embracing EPA as a high-
performing organization.
EPA Not Fully Compliant With
Overtime Policies
What We Found
The EPA has established policies that identify the
requirements and general process for the
authorization and approval of overtime
compensation. However, based on our limited
sample, the EPA did not always use the EPA
Form 2560-7, Request for Overtime
Authorization, for overtime requests and
authorization as required by EPA Pay
Administration Manual 3155. Even when the EPA
Form 2560-7 was prepared, overtime hours were not always approved in
advance and some overtime hours exceeded the authorized amounts. Also,
the EPA did not always maintain the forms in accordance with EPA records
management requirements. This occurred because management did not
provide sufficient oversight to ensure compliance with EPA policies pertaining
to overtime and records management.
EPA has established specific policies that address overtime during travel.
Employees can only be authorized overtime during travel when officially
ordered and approved, and our analysis did not disclose any instances where
employees requested compensation for overtime during travel.
Recommendation and Planned Corrective Actions
We recommend that the Deputy Administrator ensure management and
employees comply with EPA overtime policies, use EPA Form 2560-7, obtain
advance approval for overtime hours, and follow EPA records management
policies. The agency agreed with our recommendation and provided
acceptable corrective actions with estimated completion dates.
The EPA may have
incurred overtime
charges without
proper authorization
and advance approval,
and did not maintain
overtime request
forms as required.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oia.
The full report is at:
www.epa.gov/oig/reports/2015/
20150922-15-P-0293.pdf

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 23, 2015
MEMORANDUM
SUBJECT: EPA Not Fully Compliant With Overtime Policies
Report No. 15-P-0293
FROM: Arthur A. Elkins Jr.
TO:
A. Stanley Meiburg, Acting Deputy Administrator
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe 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.
The EPA's Office of the Chief Financial Officer is responsible for formulating and providing
time and attendance reporting policies, as well as managing the PeoplePlus payroll and time and
attendance system. The EPA's Office of Human Resources, within the Office of Administration
and Resources Management, is responsible for agency policy and guidance relevant to time and
attendance, including overtime and compensatory time.
Action Required
In response to our discussion document, the agency provided an intended corrective actions plan
that addresses the recommendation and establishes planned completion dates. Therefore, a
response to the final report is not required. The agency should track unimplemented corrective
actions in the Management Audit Tracking System.
We will post this report to our website at http://www.epa.gov/oig.

-------
EPA Not Fully Compliant With Overtime Policies
15-P-0293
Table of C
Purpose		1
Background		1
Responsible Offices		3
Other OIG Audit		4
Scope and Methodology		4
Results of Review		7
Overtime Request Form Not Always Prepared or Retained,
and Hours Were Incurred in Advance of Approval and in
Excess of Authorized Amounts		8
OIG Observation		12
Recommendation		13
Agency Comments and OIG Evaluation		13
Status of Recommendations and Potential Monetary Benefits		14
Appendices
A Fiscal Years 2012 and 2013 Overtime Hours and
Costs Reported by Program Office/Region 	 15
B Agency Response to Discussion Draft 	 16
C Distribution 	 18

-------
Purpose
We conducted this audit to address a congressional request. On April 9, 2014, a
U.S. Senator requested that the Office of Inspector General (OIG) examine
whether the U.S. Environmental Protection Agency (EPA): (a) properly
documents how overtime is distributed and, if so, identify the process that is used;
(b) has a specific breakdown of activities for employees who received overtime
during the last 2 fiscal years; and (c) has an effective means for ensuring
employees are not compensated overtime for travel.
Background
As shown in Table 1, the EPA reported 163,483 hours of overtime at a cost of
$8,058,913 for fiscal years 2012 through 2013.
Table 1: Overtime hours and costs reported
Fiscal
No. of
Overtime
Overtime
year
employees1
hours
costs2
2012
2,219
92,929
$4,569,651
2013
2,014
70,554
3,489,262
Total

163,483
$8,058,913
Source: OIG-generated table.
The overtime hours were reported by employees located in 22 Responsible
Program Implementation Offices—the 10 regions and 12 program offices at
headquarters. Appendix A includes a breakdown of overtime hours and costs
reported by each program office/region.
Requirements for Overtime Authorization and Approval
The EPA must adhere to applicable federal regulations and internal policies
related to the authorization and approval of overtime.
The Code of Federal Regulations (CFR), at 5 CFR § 550. Ill, defines overtime as
work in excess of 8 hours in a day or in excess of 40 hours in an administrative
work week. The regulation also provides that overtime must be officially ordered
or approved only in writing by an officer or employee to whom this authority has
been specifically delegated.
EPA Pay Administration Manual 3155, Chapter 4, "Overtime Pay and Compensatory
Time" (May 17, 1990), Section 5E, provides that overtime must be officially
authorized and approved in writing on EPA Form 2560-7, Request for Overtime
Authorization, before the employee can be compensated for it. Thus, EPA Form
2560-7 is required for the authorization of overtime and compensatory time off in
1	Excludes OIG employees as they were included in a prior report, discussed in "Other OIG Audit" section below.
2	In some instances, while employees incurred overtime hours, due to statutory pay limits, the employee may not
have received payment for or received limited payment for the hours reported.
15-P-0293
1

-------
lieu of payment for overtime. Also, overtime and compensatory time should be
approved in advance; retroactive approval may be permitted when operational
emergencies make it impractical to obtain prior approval. Section 6 provides agency
officials the authorization to approve overtime in accordance with governing laws,
regulations, and EPA rules and procedures. This section also provides that this
authority may be re-delegated to a level that will assure compliance with legal and
regulatory requirements.
EPA Form 2560-7 requires, among other things: a justification or reason for the
overtime request; the employee's name, hours and dates of proposed overtime; and
the signature of the requester and approver. The request form is available in
WebForms—a Web-based application designed to permit EPA staff to
electronically prepare, submit, route and approve selected agency forms. Because
WebForms does not qualify as an electronic recordkeeping system, the record copy
of forms must be printed and filed in the appropriate file or captured in EPA's
electronic recordkeeping system to comply with federal and agency requirements.
Requirements for Overtime During Travel
The EPA has established policies that address compensation for overtime during
travel and other non-overtime-related travel. The EPA policy for overtime during
travel is addressed in the EPA Pay Administration Manual 3155, Chapter 8,
"Premium Pay During Travel and Training." This chapter provides that, to the
maximum extent practicable, managers should plan activities and schedule travel
so that an employee performs necessary travel away from his or her duty station
during his or her regularly scheduled tour of duty. Travel time is not compensable
as overtime unless the travel outside the regularly scheduled duty hours is
officially ordered or approved. Travel scheduled outside the scheduled tour of
duty must be properly authorized on the EPA overtime request form, as provided
in Chapter 4 of the manual, before it can be paid.
The EPA policy that addresses travel time that is not compensable as overtime is
included in the EPA Pay Administration Manual, Chapter 18, "Travel
Compensatory Time Off (TCTO). This policy constitutes the agency's policy on
the administration of TCTO, including requesting, approving, earning, crediting
and tracking TCTO. The policy allows for TCTO to be authorized for covered
employees who perform official travel satisfying all of the following conditions:
•	For officially authorized travel outside of an employee's regularly
scheduled tour of duty—that is, travel for work purposes.
•	For officially authorized travel away from an employee's duty station
(generally outside of a 50-mile radius).
•	For officially authorized travel that is NOT compensable under any other
authority (e.g., overtime pay, regularly scheduled standby duty pay,
administratively uncontrollable overtime pay, and law enforcement
availability pay).
15-P-0293
2

-------
Requirements for Timekeeping
The PeoplePlus system is the EPA's official payroll and time and attendance
system. Employees are responsible for entering hours worked on a bi-weekly
basis. PeoplePlus is not an activity-based timekeeping system; rather, it tracks
hours by accounting codes. These codes may be a fixed-account number, based on
the employee's profile and organizational code, or a non-fixed-account number
established for cost recovery purposes pertaining to Superfund sites, oil spills,
and/or information technology project codes. While PeoplePlus can provide a
general idea of an employees' area of work or site-related work by the accounting
codes charged, the system cannot identify specific duties or activities performed.
As a result, we were unable to determine the specific breakdown of activities for
employees who received overtime during the last 2 fiscal years.
Managers are responsible for approving employee information in PeoplePlus—
including employee work schedule changes, overtime and compensatory time—
and ensuring that supporting documentation is retained by timekeepers.
Requirements for Records Management
The EPA is responsible for maintaining all records pertaining to the approval of
overtime in accordance with EPA records management policies. EPA Resource
Management Directive Systems 2540-08-P1, Payroll: Time and Attendance
Reporting, dated September 5, 2014, requires timekeepers to maintain supporting
documentation for approved leave, overtime, compensatory time, and other time
and attendance reports in accordance with EPA records management
requirements. EPA records management requirements applicable to time and
attendance source records are covered in EPA Records Schedule 0300 and 1005.
EPA Records Schedule 0300 (December 31, 2013) provides that the agency's
PeoplePlus time and attendance data may be closed and destroyed after an audit by
the U.S. Government Accountability Office or when the data are 6 years old,
whichever is sooner. EPA Records Schedule 1005 (December 31, 2013) pertains to
financial management records and provides that time and attendance source records
may be closed and destroyed after a U.S. Government Accountability Office audit
or when the records are 6 years old, whichever is sooner.
Responsible Offices
The EPA's Office of the Chief Financial Officer is responsible for formulating
and providing time and attendance reporting policies. In addition, the office is
responsible for the PeoplePlus system, including:
•	Enforcing internal control policies and standards.
•	Monitoring records to confirm that appropriate individuals are entering,
attesting, submitting, verifying and approving time worked.
15-P-0293
3

-------
•	Providing systems administration.
•	Coordinating training.
The EPA's Office of Human Resources, within the Office of Administration and
Resources Management, is responsible for agency policy and guidance relevant to
time and attendance, including overtime and compensatory time.
Other OIG Audit
On February 4, 2015, the OIG issued a report on how the OIG managed overtime.
The report, EPA OIG Not Fully Compliant With Overtime Policies (15-B-0075),
disclosed that the OIG did not always use EPA Form 2560-7 for overtime
requests and authorization as required by EPA Pay Administration Manual 3155.
Also, the OIG did not always comply with its own policy on the use of the
planned timesheet for advance approval of overtime. This occurred because OIG
management did not provide sufficient oversight, and OIG policies were not clear.
We also noted the OIG did not retain EPA request forms supporting overtime
requests. We recommended that the Deputy Inspector General revise OIG policy
as needed and emphasize EPA policy to staff. The Deputy Inspector General
agreed with our recommendations and provided milestones for planned corrective
actions. On June 2, 2015, the OIG Chief of Staff issued guidance to supervisors in
regard to approving and documenting OIG employee overtime work. The
recommendations remain open pending full completion of the corrective actions.
Scope and Methodology
We conducted our audit from May 14, 2014, through June 23, 2015, in
accordance with generally accepted government auditing standards issued by the
Comptroller General of the United States. Those standards require that we plan
and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Based on the request from the Senator, we limited the scope of our audit to
overtime charges3 over a 2-year period (October 2011 through September 2013—
fiscal years 2012 and 2013). We held an entrance conference with the agency on
May 14, 2014, at the EPA's headquarters in Washington, D C. We made return
site visits to headquarters in 2014 to perform fieldwork during the weeks of
June 2, July 7, and August 4.
To determine whether the EPA properly documents how overtime is distributed and
the process used, we reviewed agency overtime policies and discussed controls for
3 Overtime charges included some compensatory time that was converted to paid overtime. Our audit did not include
unconverted compensatory time.
15-P-0293
4

-------
overtime authorization and approval with agency officials. Based on our review and
discussion, we determined that controls for overtime authorization and approval
vary depending on the approver. The approvers are usually at the supervisor or
manager level and have at least one alternate approver and a timekeeper. The EPA
estimated that it has more than 3,300 supervisors, managers and timekeepers.
Because of the large number of control points and lack of consistency among
overtime approvers, testing of individual control points would be cost prohibitive
and ineffective for projecting results. As a result, we looked at overtime usage and
not controls over the payment of overtime through the agency's timekeeping and
payroll system. We based our conclusions on substantive testing rather than trying
to test the varying internal controls; we designed a substantive test to cover the
maximum assumed control risk. We shared our methodology with the agency. The
agency expressed no concerns and stated that our approach sounded reasonable.
For our testing, we obtained overtime data from the Compass Data Warehouse—
EPA's accounting system—for the period October 2011 through September 2013.
The first step in our sample selection process included the removal of employees
with 24 hours or less of overtime, which we considered to be insignificant for
review purposes. As shown in Table 2, employees with 24 or less hours
represented 13 percent of the total overtime hours reported. Later in this report,
Table 5 includes a further breakdown by the range of hours.
Table 2: Employees with 24 or less overtime hours
Fiscal year
No. of employees
Overtime hours
Overtime costs
2012
1,439
11,133
$607,754
2013
1,384
10,121
535,879
Total

21,254
$1,143,633
% of Total

13%
14%
Source: OIG-generated table.
For the hours greater than 24, we analyzed the data using a multistep process to
select a judgmental sample of employees for testing. The process considered
various attributes, including: office, position, grade, hours reported and pattern of
overtime. The resulting sample represents eight of 22, or 36 percent, of the
program offices/regions that reported overtime. The sample includes employees
located in the following program offices/regions:
•	Office of the Administrator (OA)
•	Office of Administration and Resources Management (OARM)
•	Office of the Chief Financial Officer (OCFO)
•	Office of Environmental Information (OEI)
•	Office of Air and Radiation (OAR)
•	Office of Enforcement and Compliance Assurance (OECA)
•	Region 2
•	Region 3
15-P-0293
5

-------
Table 3 shows the number of employees reviewed in our sample by program
office/region, the associated overtime hours, and costs reported. The sample hours
and related costs represent 17 percent of the total overtime hours and costs
reported from fiscal years 2012 through 2013 (as noted in Table 1).
Table 3: Overtime hours and costs reported
EPA
office
No. of
employees
Overtime hours
reported
Overtime costs
reported
OA
5
947
$43,912
OARM
1
124
5,715
OCFO
6
1,664
72,397
OEI
2
528
37,141
OAR
22
6,782
316,805
OECA
8
5,384
236,781
Region 2
15
9,090
458,911
Region 3
12
4,271
216,745
Total
71
28,791
$1,388,407
Source: OIG-generated table.
We met with approving officials from each office in our sample to gain an
understanding of the process used to authorize and approve overtime. For each
employee, we obtained and reviewed PeoplePlus timesheets and the EPA's
overtime request forms to determine whether overtime was authorized and
approved in advance, and included a justification or reason for the overtime. In
some instances, offices provided email and other correspondence in lieu of the
overtime request forms to support approval of overtime; we did not evaluate the
emails or correspondence to determine whether the overtime had been authorized
and approved. Our analysis focused on compliance with the requirements for the
use of the overtime request form as set forth in EPA Manual 3155.
To determine whether the EPA has an effective means for ensuring employees are
not compensated overtime for travel, we reviewed agency policy on overtime
compensation during travel and TCTO. We met with agency officials to discuss
internal controls for overtime during travel and TCTO. Based on these
discussions, we learned that, similar to overtime compensation, the authorization
and approval for travel-related compensation may vary by office or approver.
Based on the EPA policy, in some instances overtime compensation for travel is
considered "overtime" and, as such, should follow the requirements for overtime
authorization and approval. TCTO is different from regular compensatory time in
that it is not converted to overtime if not used within the applicable period. TCTO
is forfeited if not used within 26 pay periods after the pay period in which it is
credited. Forfeited TCTO has no cash conversion; therefore, under no
circumstances may an employee be paid cash for unused TCTO.
Because our overtime data obtained from the Compass Data Warehouse did not
distinguish between overtime for travel and regular overtime, we could not
15-P-0293
6

-------
identify the extent to which overtime for travel occurred. However, since
approved overtime for travel would follow the same authorization/approval
process as regular overtime, the potential existed that overtime for travel could
show up in our sample for testing. We did not conduct any substantive testing for
TCTO since the focus of the audit was paid overtime compensation.
Results of Review
The EPA has established policies that identify the requirements and general
process for the authorization and approval of overtime compensation. However,
based on our limited sample, the EPA did not always follow the policy in EPA
Manual 3155 requiring the advance authorization and approval of overtime
through EPA Form 2560-7. While all offices in our sample acknowledged the
overtime request form, it was not consistently used. In many instances, the offices
used verbal or other written methods for the advance approval of overtime.
Further, when offices did use the request form, officials did not always approve
the request form in advance. In addition, employees recorded hours in excess of
the authorized amounts, and responsible staff did not always retain the request
forms as required by records management policies.
This occurred because management did not provide oversight to ensure
compliance with EPA policies pertaining to overtime and records management.
As a result of the issues noted, the EPA may have incurred overtime charges
without proper authorization, may have made after-the-fact approvals that did not
relate to an operational emergency, and did not comply with records management
requirements. Without adequate controls and oversight, there is limited assurance
that overtime charges are properly authorized or approved in advance or that
supporting records are appropriately retained.
The EPA had established specific policies that address overtime during travel.
Employees can only be compensated for overtime during travel when officially
ordered and approved. For other circumstances, employees are entitled to receive
TCTO. Our analysis of the justifications or reasons for overtime on overtime
request forms provided by the various EPA offices did not identify any instances
of overtime requested during travel.
Overtime Request Form Not Always Prepared or Retained,
and Hours Were Incurred in Advance of Approval and in
Excess of Authorized Amounts
EPA policy requires the completion of EPA Form 2560-7 for overtime requests
and authorization. EPA Resource Management Directive System 2540-08-P1,
Payroll: Time and Attendance Reporting, requires timekeepers to maintain
supporting documentation for approved leave, overtime, compensatory time, and
other time and attendance reports in accordance with EPA records management
requirements. As shown in Table 4, our sample identified that EPA:
15-P-0293
7

-------
•	Did not provide overtime request forms to support 14,4944 of the 27,817
overtime hours recorded in PeoplePlus.
•	Did not authorize and approve in advance 3,193 of the 13,324 hours
included on the overtime request forms provided to the OIG.
Table 4: Results of analysis of sampled overtime hours recorded in PeoplePlus
EPA office/
region
Hours
recorded in
PeoplePlus
Hours not
supported by
request form
Hours
supported
by request
form
Hours supported by
request form that
were not approved
in advance
OA
905
905
0
NA
OARM
124
0
124
30
OCFO
1,875
1,117
758
285
OEI
450
310
140
123
OECA
5,250
1,838
3,412
280
OAR
6,355
5,147
1,209
469
Region 2
8,016
3,772
4,244
1,167
Region 3
4,842
1,405
3,437
839
Total
27,8175
14,494
13,324
3,193
Source: OIG-generated table.
Based on our interviews with management officials, most offices acknowledged
the requirement to use the request form. However, as discussed in the results by
program offices and regions below, not all offices/regions consistently used the
request form, for various reasons.
OA Results
The OA sample included four employees in administrative positions and one
driver within the executive office. OA officials informed the OIG that it
completes the request form via WebForms and in hardcopy, and that the OA
timekeeper retains the request forms. However, the timekeeper could not
locate the request forms to support any of the 905 overtime hours recorded in
PeoplePlus. OA management said that while they were unable to locate the
request forms, they do believe the employees had permission and the work
was performed as indicated on the timecards. Because OA did not provide the
request forms, we could not identify a justification or reason for the overtime
charges.
4	This amount includes hours with no supporting forms due to compensatory time converted to overtime and hours
in excess of hours approved on the forms.
5	Overtime hours were obtained from PeoplePlus time sheets and may include various forms of overtime (such as
overtime, overtime in schedule, holiday work or compensatory time earned). Hours do not include differential pay.
Hours recorded in PeoplePlus did not always equal the hours reported in the Compass Data Warehouse due to
payment of unused compensatory time and differential pay.
15-P-0293
8

-------
OA management also discussed and provided a copy of an internal
memorandum issued to the immediate office employees and staff office
directors on March 13, 2014. The memorandum emphasized that requests for
overtime/compensatory time authorization (EPA Form 2560-7) must be
approved by a supervisor prior to working extra hours. It also stated that
overtime or compensatory time would not be approved in PeoplePlus if the
timekeepers did not have a supervisor-approved form.
OARM Results
The OARM sample included one employee—a security specialist. OARM
officials informed the OIG that the office completes the request form via
WebForms. Our analysis of the 124 hours of overtime recorded in PeoplePlus
showed that OARM completed the request form for all of the hours, but only
94 of the 124 hours were approved in advance. We could not determine from
the request forms why the remaining 30 hours were not approved in advance.
OARM cited some of the after-the-fact approvals as due to emergency call-in
situations, which is allowable per EPA policy. The hours recorded exceeded
the authorized hours on the request form by four. All request forms included a
justification or reason, including: public address system testing, addressing
emergency system issues, and serving as duty officer during Hurricane Sandy.
OCFO Results
The OCFO sample included six program analysts (lead and supervisory).
OCFO officials informed the OIG that the office completes the request form
via WebForms, may utilize email, or obtain verbal approval for the
authorization and approval of overtime hours. Our analysis of the 1,875
overtime hours recorded in PeoplePlus showed that OCFO completed the
request form for 758, or 40 percent, of the total hours. Of those 758 hours,
only 473 were authorized in advance. We could not determine from the
request form why 285 hours were not approved in advance. Also, the hours
recorded exceeded the hours authorized on the request form by 179. The
request forms included a justification or reason for the hours that pertained to
budget and operation planning and analysis.
OEI Results
The OEI sample included two information technology specialists. OEI
officials informed the OIG that the office completes the request form via
WebForms. The request forms are routed to the supervisor for approval and a
copy is sent to the timekeeper. OEI indicated that, due to the nature of its
work, there were times when verbal or after-the-fact approval was given. Our
analysis of the 450 overtime hours recorded in PeoplePlus showed that OEI
completed the request form for 140, or 31 percent, of the hours. Of those 140
hours, only 17 were approved in advance. We could not determine from the
15-P-0293
9

-------
request forms why the remaining 123 hours were not approved in advance.
However, given the nature of the work performed, the potential existed that
the hours were incurred due to an operational emergency, which is allowable
per EPA policy. The hours recorded did not exceed the authorized hours. A
justification or reason for the hours primarily pertained to addressing EPA
computer center and network issues.
OECA Results
The OECA sample included seven criminal investigators and one operations
support specialist within OECA's Office of Criminal Enforcement, Forensics
and Training. OECA officials informed the OIG that overtime is approved in
advance based on the protection service detail schedule. The special agent in
charge completes and approves the request form for employees with
scheduled overtime, and the form is forwarded to the Office of Criminal
Enforcement, Forensics and Training program analyst to retain. Our analysis
of the 5,250 overtime hours recorded in PeoplePlus showed that OECA
completed the request form for 3,412, or 65 percent, of the hours. However,
only 3,132 hours were approved in advance. We could not determine from the
request form why the remaining 280 hours were not approved in advance. The
hours recorded exceeded the authorized hours by 212. Most of the request
forms included a justification or reason for the hours that pertained to a detail
for the protection of the EPA Administrator.
OAR Results
The OAR sample included 13 engineers and specialists within the Office of
Transportation and Air Quality (OTAQ), at the Ann Arbor Laboratory. OTAQ
officials informed the OIG that, prior to March 2013, each of the four divisions
within OTAQ followed different processes for authorization and approval of
overtime. These processes included email, verbal communications, and in some
instances use of the request form. OTAQ officials said they did not universally
use or mandate the use of the request form/process in WebForms. Rather, each
division and their sub-units established their own protocols and processes for
tracking and documenting the use of overtime.
Beginning in March 2013, OTAQ officials said that their immediate office
used an additional authorization level that requires each division to obtain
approval from the immediate office to assign and authorize overtime to any
employee. Officials stated that the approvals are typically made via email or
verbally. Each division then uses the email, conversation or request form, and
reconciles/documents the approval by approving the employee's PeoplePlus
timesheet. Officials stated that PeoplePlus is the official record of the
authorization/approval of the hours worked.
15-P-0293
10

-------
Our analysis of the 6,355 overtime hours recorded in PeoplePlus showed that
OTAQ completed the request form for 1,209, or 19 percent, of the overtime
hours. Only 739 of those hours were approved in advance. We could not
determine from the request forms why the remaining 469 hours were not
approved in advance. The hours recorded exceeded the authorized hours by
65. A justification or reason for the hours was included on most of the request
forms. The hours primarily pertained to work in the metrology laboratory and
with the central gas system.
Region 2 Results
The Region 2 sample included 15 on-scene coordinators within the
Emergency and Remedial Response Division. Division officials informed the
OIG that due to the nature of the work in emergency and disaster responses,
the first-line supervisor notifies the Branch Chief of employees' overtime
needs verbally or via email. Once the Branch Chief has agreed with the
request, the information is sent to administrative staff, who prepare the request
form. The request form is submitted to the Division Director for approval.
Approved forms are forwarded to the administrative staff to retain.
Our analysis of the 8,016 overtime hours recorded in PeoplePlus showed that
the Emergency and Remedial Response Division completed the request form
for 4,033, or 50 percent, of the hours. However, only 3,076 of the hours were
approved in advance. We could not determine from the request forms why the
remaining 1,167 hours were not approved in advance. However, given the
nature of the work performed by the division, the hours could potentially
relate to operational emergency situations, which is allowed per EPA policy.
The hours recorded exceeded the authorized hours by 1,594. All forms
included a justification or reason for the requested hours. The hours primarily
pertained to work with natural disasters, including Hurricane Sandy.
Region 3 Results
The Region 3 sample included 12 on-scene coordinators and financial
specialists within the Hazardous Site Cleanup Division. Division officials
informed the OIG that the employees complete the request form for the
authorization and approval of overtime hours. In the event the employee is
unable to complete the request form, the administrative assistant or first-line
supervisor will submit the request on their behalf. The request form is
submitted to the first-line supervisor, second-line supervisor, and Division
Director for signature. Approved request forms are forwarded to the
timekeeper to retain.
Our analysis of 4,842 overtime hours showed that the Hazardous Site Cleanup
Division completed the request form for 3,437, or 71 percent, of the hours
recorded in PeoplePlus. However, only 2,598 of the hours were approved in
15-P-0293
11

-------
advance. We could not determine why the remaining 839 hours were not
approved in advance. Given the nature of the work performed by the division,
the hours could potentially relate to operational emergency situations, which
is allowed per EPA policy. The hours recorded exceeded the authorized hours
by 316. All of the request forms included a justification or reason for the
overtime request. The request forms showed that the hours primarily pertained
to removal activities at hazardous sites.
OIG Observation
As shown above in Table 1, data from EPA's Compass Data Warehouse showed
163,483 overtime hours at a cost of $8,058,913 for FYs 2012 and 2013.
Individual employee overtime charges ranged from 0.01 (1 minute) to 2,398
hours, with costs ranging from $0.1 to $40,167.6 The OIG's analysis of this data
showed a significant number of instances where employees reported less than 24
hours of overtime, as shown in Table 5.
Table 5: Employees with 24 or less overtime hours for fiscal years 2012 and 2013
Fiscal Year 2012
Range of hours
No. of
employees
Overtime
hours
Overtime
costs
.01 to .99
164
53
$3,832
>1 to 4
384
955
53,048
> 4 to 8
353
2,300
125,394
> 8 to 16
351
4,084
215,462
> 16 to 24
186
3,741
210,017
Total

11,133
$607,753
Fiscal Year 2013
Range of hours
No. of
employees
Overtime
hours
Overtime
costs
.01 to .99
192
64
$3,858
> 1 to 4
375
896
47,139
>4 to 8
330
2,110
116,352
>8 to 16
316
3,678
192,089
>16 to 24
170
3,374
176,441
Total

10,122
$535,879
Total FY 2012 & 2013

21,253
$1,143,632
Source: OIG-generated table.
In comparison, employees7 over the 2-year period accumulating less than
24 hours a year represent over two-thirds, or 67 percent, of all employees earning
overtime. However, overtime charges for these employees represented only
13 percent of the total hours and only 14 percent of the total costs.
6	There is not necessarily a correlation between the overtime hours reported and the overtime costs incurred due to
statutory pay limitations. As demonstrated by the overtime data, one employee who charged 2,398 overtime hours
received only $28,719, whereas, another employee who charged 784 overtime hours received $32,011.
7	In many instances, employees earned overtime in both fiscal years.
15-P-0293
12

-------
When broken down further, employees accumulating less than 8 hours of
overtime charges a year represent 42 percent of the total overtime charges for the
2 years, but only 4 percent of the total hours and costs. An inordinate amount of
administrative cost is being incurred for a small percentage of total hours and total
overtime charges. While some instances may have been unavoidable, better time
management could eliminate numerous other instances, reducing not only the
overtime costs but the administrative costs associated with the approval,
management and documentation of overtime.
Recommendation
We recommend that the Deputy Administrator:
1. Ensure management and employees comply with EPA overtime policies,
including the requirement to use EPA Form 2560-7 to document overtime
authorization; obtain advance approval for overtime hours; and follow
EPA records management policies.
Agency Comments and OIG Evaluation
A discussion document was provided to the agency for comment on June 23, 2015.
The agency provided us its formal response on July 17, 2015, and we held a final
exit conference with agency officials on August 4, 2015.
The agency concurred with our recommendation and the acting Deputy
Administrator issued a mass mailer on June 24, 2015, to all EPA employees
reminding them to comply with EPA overtime policies, use EPA Form 2560-7,
obtain advance approval for overtime hours, and follow EPA records management
policies to correct the timekeeping errors identified. The agency plans to send an
email to supervisors by the end of fourth quarter 2015 reminding them that
overtime approval authority resides at the Division Director level unless
re-delegated.
The agency's full response to our discussion draft is in Appendix B of this report.
15-P-0293
13

-------
Status of Recommendations and
Potential Monetary Benefits
POTENTIAL MONETARY
BENEFITS (In $000s)
Claimed Agreed-To
Amount Amount
EPA overtime policies, including the requirement to
use EPA Form 2560-7 to document overtime
authorization; obtain advance approval for overtime
hours; and follow EPA records management
policies.
RECOMMENDATIONS
Planned
Rec. Page	Completion
No. No.	Subject	Status1 Action Official	Date
1 13 Ensure management and employees comply with 0 Deputy Administrator 9/30/15
1 0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
15-P-0293
14

-------
Appendix A
Fiscal Years 2012 and 2013 Overtime Hours and
Costs Reported by Program Office/Region
Responsible
program
office
Description of program office/region
Overtime
hours
Overtime
costs
1
Region 1
6,540
$344,958
2
Region 2
33,006
1,698,040
3
Region 3
11,130
463,549
4
Region 4
10,459
499,473
5
Region 5
16,072
772,780
6
Region 6
6,727
333,271
7
Region 7
3,893
189,205
8
Region 8
5,804
306,124
9
Region 9
3,874
237,953
10
Region 10
2,563
142,979
11
Office of the Administrator
3,154
152,565
13
Office of International and Tribal Affairs
102
6,362
16
Office of Administration and Resources Management
3,865
164,190
17
Office of the Chief Financial Officer
16,536
689,417
18
Office of Environmental Information
1,442
94,760
20
Office of Chemical Safety and Pollution Prevention
425
23,198
26
Office of Research and Development
6,949
319,935
27
Office of Air and Radiation
15,255
778,426
30
Office of Water
1,287
76,769
39
Office of General Counsel
272
17,708
75
Office of Solid Waste and Emergency Response
6,036
287,959
77
Office of Enforcement and Compliance Assurance
8,092
459,292

Total
163,483
$8,058,913
Source: OIG-generated table.
15-P-0293
15

-------
Appendix B
Agency Response to Discussion Draft
MEMORANDUM
SUBJECT: EPA Comments on Discussion Document, EPA Not Fully Compliant with
Overtime Policies, Project No. OA-FY14-0245, dated June 23, 2015
FROM: Karl Brooks, Acting Assistant Administrator
TO:	Robert Adachi, Director
Forensics Audits
Thank you for the opportunity to review the discussion document. Below is the agency's
response to the report recommendation.
Background:
On April 9, 2014, a U.S. Senator requested that the EPA Office of Inspector General review the
process the agency uses to determine and track overtime compensation for EPA employees. The
OIG examined whether the agency: (a) properly documented how overtime hours were
distributed across the agency and identified the process used for overtime authorization and
approvals, (b) had a breakdown of activities for employees who received overtime during the last
two fiscal years, and (c) had an effective means for ensuring that employees are not compensated
overtime for travel.
Agency Response to Recommendation:
The agency concurs with the discussion document recommendation and provides the following
corrective actions and estimated completion dates.
No.
Recommendation
High-Level Intended
Corrective Action(s)
Estimated Completion
by Quarter and FY
1
We recommend that the [Acting]
Deputy Administrator ensure
management and employees
comply with EPA overtime
policies including the
requirement to use EPA Form
2560-7 to document overtime
authorization; obtain advance
approval for overtime hours; and
follow EPA records
management policies.
The Acting Deputy
Administrator issued a
mass mailer to all EPA
employees reminding them
to comply with EPA
overtime policies, use EPA
Form 2560-7, obtain
advance approval for
overtime hours, and follow
EPA records management
policies.
Completed,
June 24, 2015.
15-P-0293
16

-------
The Office of Human
Resources Director will
send an email to
supervisors/managers
reminding them that
overtime approval
authority resides at the
division director level
unless redelegated.
Questions regarding
overtime approval
authority can be directed to
each organization's HR
officer.
Q4, FY15.
OARM believes the agency has met the intent of the OIG recommendation and no additional
follow-up actions are required.
Please contact Susan Kantrowitz, director, Office of Human Resources, should you have any
questions regarding this response. She can be reached at (202) 564-4606.
cc: Donna Vizian
Marian Cooper
Susan Kantrowitz
Angela Freeman
John Showman
Brandon McDowell
Debbi Hart
15-P-0293
17

-------
Appendix C
Distribution
Office of the Administrator
Deputy Administrator
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Assistant Administrator for Administration and Resources Management
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
15-P-0293
18

-------