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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
Outdated EPA Leave Manual
arid Control Weaknesses
Caused Irregularities in the
Office of Air and Radiation's
Timekeeping Practices
Report No. 20-P-0063	December 19, 2019
V

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Report Contributors:	John Trefry
Jean Bloom
Angela Bennett
Kevin Collins
David Penman
Abbreviations
CFR
Code of Federal Regulations
EPA
U.S. Environmental Protection Agency
FMLA
Family and Medical Leave Act of 1993
LWOP
Leave Without Pay
OAR
Office of Air and Radiation
OCFO
Office of the Chief Financial Officer
OIG
Office of Inspector General
OMS
Office of Mission Support
OPM
U.S. Office of Personnel Management
RMDS
Resource Management Directives System
TCTO
Travel Compensatory Time Off
U.S.C.
United States Code
Cover Image: Policies provide critical direction and information regarding the requirements,
values and expectations of an organization, as well as the responsibilities of its
employees. (EPA OIG graphic)
Are you aware of fraud, waste or abuse in an
EPA program?
EPA Inspector General Hotline
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Washington, D.C. 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, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
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*. U.S. Environmental Protection Agency	20-P-0063
^ ¦¦ \ Office of Inspector General	December 19,2019
1
I»
At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency's (EPA's)
Office of Inspector General
(OIG) conducted this audit to
address concerns about time
and attendance irregularities
within the Office of Air and
Radiation. These concerns
were identified in a prior OIG
audit. Our objectives for this
audit were to identify and
analyze risks in the Office of Air
and Radiation's timekeeping
practices.
The U.S. Office of Personnel
Management develops and
maintains governmentwide
regulations and policies on
federal agencies' administration
of leave for their employees.
According to the
U.S. Government
Accountability Office, the
primary objectives of internal
controls in a time and
attendance system are to
obtain compliance with
applicable legal requirements,
support the reporting of reliable
financial information, and
operate effectively and
efficiently.
This report addresses the
following:
• Operating efficiently and
effectively.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Outdated EPA Leave Manual and Control
Weaknesses Caused Irregularities in the Office
of Air and Radiation's Timekeeping Practices
The Office of Air and Radiation
needs policies to increase
awareness of and controls to
strengthen timekeeping
practices.
What We Found
Entitlements under the Family and Medical
Leave Act of 1993 are not formalized in the
EPA's Leave Manual. Without a policy that is
updated to reflect current law, staff and
supervisors may not be aware of or fully
understand leave entitlements under the act,
which may result in decisions about leave that are contrary to public law.
Furthermore, our analysis of time and attendance records identified untimely prior
pay period adjustments, which resulted in salary overpayments. We also
identified the improper approval of Travel Compensatory Time Off—time off
earned for time spent in a travel status away from the employee's official duty
station that is not otherwise compensable.
These conditions occurred due to a lack of three things:
•	An up-to-date policy and understanding of leave entitlements under the
Family and Medical Leave Act of 1993.
•	Controls over pay period adjustments.
•	Supervisory enforcement of established time frames for submittal of Travel
Compensatory Time Off.
Without additional internal controls, employees can make after-the-fact
timekeeping adjustments to create salary overpayments and/or improperly
restore leave balances. Employees may also receive Travel Compensatory Time
Off that is not in compliance with the EPA's Pay Administration Manual.
Recommendations and Planned Agency Corrective Actions
We made various recommendations to the agency for improving its timekeeping
practices, including updating the leave policy to reflect current law and
regulations pertaining to the Family and Medical Leave Act of 1993, establishing
time frames and controls for prior pay period adjustments, and enforcing
compliance with the required time frames for the submittal and approval of Travel
Compensatory Time Off. The EPA should also determine whether employees
should forfeit improperly credited Travel Compensatory Time Off hours, as
required by the EPA's Pay Administration Manual, and whether the agency
should recover the value of awarded and used time off as needed. Of the report's
five recommendations, we consider Recommendations 1, 2 and 3 to be
unresolved; Recommendation 4 to be completed; and Recommendation 5 to be
resolved with corrective action pending.

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^£DSX
s rjQLi \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
|	j?	WASHINGTON, D.C. 20460
%S
*1 PRO"^	OFFICE OF
INSPECTOR GENERAL
December 19, 2019
MEMORANDUM
SUBJECT: Outdated EPA Leave Manual and Control Weaknesses Caused Irregularities
in the Office of Air and Radiation's Timekeeping Practices
Report No. 20-P-0063	/-»
FROM: Charles J. Sheehan, Acting Inspector General
TO:	Donna Vizian, Principal Deputy Assistant Administrator
Office of Mission Support
U I -
David Bloom, Acting Chief Financial Officer
Anne Idsal, Acting Assistant Administrator
Office of Air and Radiation
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-FY17-0090.
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
Of our five recommendations, we consider Recommendations 1, 2 and 3 to be unresolved;
Recommendation 4 to be completed; and Recommendation 5 to be resolved with corrective action
pending. In accordance with EPA Manual 2750, the resolution process for Recommendations 1, 2 and 3
begins immediately with the issuance of the report. We are requesting meetings within 30 days of final
report issuance about Recommendations 1 and 2 between the Assistant Administrator for Mission
Support and the OIG's Assistant Inspector General for Audit and Evaluation and about
Recommendation 3 between the Chief Financial Officer and the OIG's Assistant Inspector General for
Audit and Evaluation. If resolution is still not reached, the agency is required to complete and submit a
dispute resolution request to the appropriate official to continue resolution.
We will post this report to our website at www.epa.gov/oig.

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Outdated EPA Leave Manual and Control
Weaknesses Caused Irregularities in the
Office of Air and Radiation's Timekeeping Practices
20-P-0063
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		2
Prior Audit Report		3
Scope and Methodology		3
2	OAR Unpaid Leave Shows EPA Lacks Formal Policy for FMLA		5
Lack of Policy to Address FMLA Entitlements		5
Recommendations		6
Agency Comments and OIG Evaluation		6
3	OAR Prior Pay Period Adjustments Cause Salary Overpayments		8
Federal and EPA Guidance for Making Prior Pay Period Adjustments		8
Prior Pay Period Adjustments Made Well After Payroll Processed		8
Conclusion		10
Recommendation		10
Agency Comments and OIG Evaluation		10
4	TCTO Requested and Approved Beyond Required Time Frames		12
TCTO Laws and EPA's Pay Administration Manual		12
Significant Delays in TCTO Requests		13
Conclusion		13
Recommendations		14
Agency Comments and OIG Evaluation		14
Status of Recommendations and Potential Monetary Benefits		15
Appendices
A	OMS Response to Draft Report		16
B	OCFO Response to Draft Report		19
C	OAR Response to Draft Report		22
D	Distribution		24

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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency's (EPA's) Office of Inspector
General (OIG) conducted this audit to identify and analyze risks in the Office of
Air and Radiation's (OAR's) timekeeping practices.
Background
The U.S. Office of Personnel Management (OPM) develops and maintains
governmentwide regulations and policies on federal agencies' administration of
leave for their employees, including annual and sick leave; leave under the Family
and Medical Leave Act of 1993 (FMLA); and time off for other circumstances,
such as Travel Compensatory Time Off (TCTO).1 Agencies are responsible for
complying with applicable laws and OPM regulations when administering leave
policies for their employees.
EPA Time and Attendance Policy and Guidance
The EPA's Leave Manual, dated September 1995, and Leave Handbook, undated,
detail the agency's policy and guidance for leave. The Leave Manual provides the
agency's policy for the administration of leave benefits developed within legal
and regulatory requirements. The Leave Handbook is based on applicable federal
law and regulation, as well as the Leave Manual', and provides basic information
about leave for EPA employees and supervisors.
The EPA also has a policy and procedure related to time and attendance reporting.
The EPA's Resource Management Directives System (RMDS) No. 2540-08,
Payroll, dated February 23, 2009, sets forth the policies for payroll payments.
Procedure 1 under the payroll policy—RMDS No. 2540-08-P1, Payroll: Time and
Attendance Reporting, dated September 5, 2014—provides guidance on entering
time and attendance information, approving and correcting timecards, and
reporting labor distribution information.
EPA's Time and Attendance Process
The EPA uses PeoplePlus as its time and attendance reporting system. PeoplePlus
integrates human resources, benefits, payroll, and time and attendance reporting
into a single management system. It consists of a time and attendance reporting
1 TCTO is time off earned for time spent in a travel status away from the employee's official duty station that is not
otherwise compensable.
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module to record hours worked, employee absences and labor charges each pay
period.
Within the PeoplePlus system, time and attendance information is entered,
corrected and approved online. Employees are responsible for entering their time
on a biweekly basis by charging hours to time reporting codes in PeoplePlus.
Time reporting codes are used to report the type of time worked (e.g., regular,
overtime or compensatory time) or the type of leave taken (e.g., sick leave, annual
leave, leave bank or leave without pay [LWOP]). Employees attest that the time
entered on their timecards is accurate. After each employee attests to the hours
worked, the employee's approving official reviews and approves those hours.
Approved timecards from PeoplePlus interface with the Federal Personnel Payroll
System, which then processes the employees' time and attendance data for
payment. The Federal Personnel Payroll System is a mainframe-based, portable,
integrated, online and real-time personnel and payroll system. The system
provides personnel and payroll support to numerous agencies and is maintained
by the U.S. Department of the Interior's Interior Business Center.
Standards for Internal Control
The U.S. Government Accountability Office's Standards for Internal Control in
the Federal Government, GAO-14-704G, issued September 2014, discusses the
importance of updating policies over time to reflect changing statutes or
conditions, as well as communicating these updates to staff who implement the
policies. An internal control is a major part of managing an organization.
According to the Government Accountability Office, an internal control
"comprises the plans, methods, policies and procedures used to fulfill the mission,
strategic plan, goals, and objectives of the entity."2 Internal controls also serve as
the first line of defense in safeguarding assets. Furthermore, internal controls
provide reasonable assurance that the objectives of the agency are being achieved
in the following categories:
•	Operations—Effectiveness and efficiency of operations.
•	Reporting—Reliability of reporting for internal and external use.
•	Compliance—Compliance with applicable laws and regulations.
Responsible Offices
The Office of Mission Support (OMS) leads the agency's core mission support
functions to improve efficiency, coordination and the customer experience for
internal customers, stakeholders and the public. The Office of Human Resources
within the OMS is responsible for the management of human resources functions,
including agencywide policy development.
2 Standards for Internal Control in the Federal Government, Section OV1.03.
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The OAR develops national programs, policies and regulations for controlling air
pollution and radiation exposure.
The Office of the Chief Financial Officer (OCFO) is responsible for formulating
and providing time and attendance reporting policies. The OCFO is also
responsible for the PeoplePlus system, including the following actions:
•	Enforcing internal control policies and standards.
•	Monitoring records to confirm that appropriate individuals are entering,
attesting, submitting, verifying and approving time worked.
•	Providing system administration.
•	Coordinating training.
Prior Audit Report
EPA OIG Report No. 15-P-0167. Time and Attendance Fraud Not Identifiedfor
Employees on Extended Absence, But Matters of Concern Brought to EPA 's
Attention, issued June 15, 2015, did not identify any instances of time and
attendance fraud for employees receiving salary payments while absent from their
duty stations for an extended period of time. However, the report identified three
instances when incorrect timecards were prepared for employees who were on
extended leave, resulting in overstatements of the employees' leave balances. We
made one recommendation: that the agency address concerns pertaining to the
accuracy of time charges in PeoplePlus, the use of a personal computer to conduct
official work and the safety of workspace for employees on reasonable
accommodation telework. The agency concurred, corrected the timekeeping
errors, and agreed to update its policies and procedures to address the remaining
matters. The agency reported that corrective actions for the recommendation were
completed as of June 6, 2016.
Scope and Methodology
We conducted this audit from January 2017 through August 2019 in accordance
with generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
To gain an understanding of the EPA's policy and guidance covering leave
benefits and time and attendance, we reviewed the following documents:
•	EPA, Leave Manual, September 1995.
•	EPA, Leave Handbook, undated.
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•	EPA, Pay Administration Manual, Chapter 18, "Travel Compensatory
Time Off," undated.
•	EPA RMDS No. 2540-08, Payroll, February 23, 2009.
•	EPA RMDS No. 2540-08-P1, Payroll: Time and Attendance Reporting,
September 5, 2014.
To determine whether the EPA's leave policy and guidance comply with
applicable regulations, we compared the Leave Manual to federal regulations. We
obtained the OAR's time and attendance data for fiscal year 2016 and developed a
sampling plan to identify and review time reporting codes for vulnerabilities. To
select our sample, we identified OAR staff who used over 400 hours of LWOP.
We used 400 hours (50 days) to ensure all sample employees had well over 240
hours (or 30 days) which requires documentation in an employee's Official
Personnel Folder. We identified nine staff who used over 400 hours and reviewed
their time and attendance records for anomalies, such as prior pay period
adjustments.
We met with key officials from the OAR, OCFO and Office of Human Resources
to identify the processes and procedures in place for attesting and approving time
and attendance data. We also interviewed staff and their supervisors regarding time
and attendance records, procedures used for submitting and approving time and
attendance data, the Leave Manual, and the Leave Handbook.
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Chapter 2
OAR Unpaid Leave Shows EPA Lacks
Formal Policy for FMLA
Based on our review of unpaid leave in OAR, leave entitlements under the FMLA
are not formalized in the agency's leave policy contained in the Leave Manual.
Rather, they are discussed, albeit incompletely, in the Leave Handbook, which is
the agency's leave guidance document. The lack of formalized FMLA policy
occurred because the agency drafted, but never finalized, updates to the manual.
Without a policy that is updated to reflect current law, staff and supervisors may
not be aware of or fully understand the leave entitlements under the FMLA,
resulting in decisions about leave that are contrary to public law.
Lack of Policy to Address FMLA Entitlements
As discussed in the handbook, the FMLA provides covered employees with an
entitlement of 12 workweeks of unpaid leave (i.e., LWOP) during any 12-month
period for the following reasons:
•	Birth of a child and care of the newborn.
•	Placement of a child with an employee via adoption or foster care.
•	Care of a spouse, child or parent with a serious health condition.
•	Serious health condition that makes an employee unable to perform an
essential duty function.
Under 5 U.S.C. § 6382(a)(1)(E), covered employees are also entitled to unpaid
leave under the FMLA:
Because of any qualifying exigency arising out of the fact
that the spouse, or a son, daughter, or parent of the employee
is on covered active duty (or has been notified of an impending
call or order to covered active duty) in the Armed Forces.
However, this FMLA entitlement for the Armed Forces is not addressed in the
Leave Handbook.
Although the agency last updated the Leave Manual in 1995, it did not include the
FMLA entitlements that were enacted in 1993. According to staff in the OMS'
Office of Human Resources, revisions to the manual had been sent to
management several times since the 1995 update, but the revisions were never
approved and finalized. Office of Human Resources staff said that, as of
August 2017, they were in the process of updating the manual but that the process
was difficult. In September 2017, the agency provided the OIG with a copy of an
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incomplete "draft" version of the manual. The "draft" version included a chapter
pertaining to the FMLA, but it has not been finalized.
Recommendations
We recommend that the Assistant Administrator for Mission Support:
1.	Update the Leave Manual and Leave Handbook to reflect laws and
regulations implemented since 1995 for leave taken under the Family and
Medical Leave Act of 1993.
2.	Develop a process and establish time frames to regularly review and
update the Leave Manual and Leave Handbook to incorporate new laws
and regulations.
Agency Comments and OIG Evaluation
The OMS agreed with Recommendation 1 and is updating thq Leave Manual to
reflect current laws and regulations. The new policy, once approved, will
supersede the out-of-date Leave Manual and Leave Handbook. The OMS stated
that it would enter the revised Leave Manual into directive clearance review by
June 30, 2021. The agency said that the Leave Handbook was initially developed
as a supplemental document until the Leave Manual could be updated. Per the
agency, the issuance of a new policy will render the Leave Handbook inapplicable
and unnecessary.
We agree with the proposed action to update the Leave Manual and to enter the
revised manual into the review process. However, a delay until June 30, 2021, is
unacceptable and excessive; it has already been more than 25 years since the
FMLA became law. Also, the EPA has not committed to a deadline to issue the
manual to EPA employees. In the interim, the OMS should issue a human
resources bulletin or other guidance (as it suggested in response to
Recommendation 2) to expeditiously and completely address all the entitlements
of the FMLA statute. We consider Recommendation 1 unresolved with resolution
efforts in progress.
The OMS disagreed with Recommendation 2 and said that it has an established
process in place to identify future policy priorities and updates. The OMS stated
that priorities are established based on a variety of factors, including senior
management decisions, OPM guidance, changes in regulations or laws,
presidential executive orders, EPA deadlines to address audit findings, and agency
customer requests. Further, the OMS tracks the progress of these policies in the
Office of Human Resources' policy tracker.
In lieu of Recommendation 2, the OMS proposed that updates to the new Leave
Manual (once issued) be made as soon as possible to reflect changes to the law or
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regulations. The OMS added that to effect a change quickly, it may issue a human
resources bulletin or guidance to ensure the agency has a policy in place. In its
response to the OIG's draft report, the OMS identified its corrective action as
"completed" as of the September 4, 2019, update to the Office of Human
Resources' policy tracker.
We disagree with the OMS' assessment that the corrective action is complete. The
OIG acknowledges that the OMS has a policy tracker to track updated policies
while they are in the review process; however, the OMS did not provide details of
its established process for how updates are identified or how priorities are
established before a policy is entered into the policy tracker. Tracking policy
updates does not provide direction or policy guidance to EPA personnel. We
therefore consider Recommendation 2 unresolved with resolution efforts in
progress.
The full response provided by the OMS is in Appendix A.
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Chapter 3
OAR Prior Pay Period Adjustments Cause
Salary Overpayments
Our analysis of time and attendance records for nine OAR staff in fiscal year 2016
showed that two employees made 16 prior pay period adjustments that resulted in
salary overpayments. Some of these adjustments were made up to 330 days after
the original workdays, and some resulted in debt notices being issued to the
employees. These adjustments occurred because the EPA has limited controls in
place to preclude employees from modifying previously attested and approved time
and attendance records. Although the EPA's RMDS No. 2540-08-P1, Payroll:
Time and Attendance Reporting, states that corrections are to be made in a timely
manner, the process for prior pay period adjustments lacks specificity in terms of
time frames. Without additional controls, employees can manipulate time reporting
codes to create salary overpayments and/or restore leave balances.
Federal and EPA Guidance for Making Prior Pay Period Adjustments
The EPA's RMDS No. 2540-08-P1, Section III, Part G, addresses prior pay
period adjustments and corrections. It outlines employees' responsibilities for
timely identification of prior pay period corrections, which include adjustments to
hours charged to a time reporting code and adjustments to hours allocated to
account/project codes. All adjustments must be either attested to by the employee
or entered and verified on behalf of the employee. The adjustments must then be
approved by the appropriate supervisor. The procedure does not include time
frames for making adjustments.
Part I of the Government Accountability Office's Maintaining Effective Control
over Employee Time and Attendance Reporting, GAO-03-352G, issued
January 2003, states that time and attendance adjustments or corrections required
because of changes after approval should be processed promptly and be traceable
to the pay period for which the correction applies. The document highlights the
importance of implementing and maintaining well-defined internal control
activities.
Prior Pay Period Adjustments Made Well After Payroll Processed
Our analysis of the nine employees' time and attendance records for the period
identified two employees who made a combined total of 16 prior pay period
adjustments. Adjustments for the two employees included changing the
employees' original duty status from an official work status to LWOP or annual
leave. The adjustments to LWOP resulted in salary overpayments and the
subsequent issuance of debt memorandums to the employees. In addition, we
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found that 14 of the 16 adjustments were made more than 60 days after the
original workdays. In some cases, the adjustments were made well over 100 days
after the original workdays.
Tables 1 and 2 summarize the prior pay period adjustments for the two employees
who made the 16 prior pay period adjustments in fiscal year 2016. The tables show
how many days elapsed between the original work date and the date on which
adjusted time was approved.
Table 1: Employee A prior pay period adjustments in fiscal year 2016
Transaction
Original time recorded
Adjusted time approved
Days lapsed
1
8 hours regular time
8 hours LWOP
70
2
8 hours regular time
8 hours LWOP
104
3
8 hours regular time
8 hours LWOP
81
4
8 hours regular time
8 hours LWOP
39
Source: OIG analysis of EPA time and attendance data.
Table 2: Employee B prior pay period adjustments in fiscal year 2016
Transaction
Original time recorded
Adjusted time approved
Days lapsed
1
9 hours annual leave
9 hours LWOP
330
2
9 hours annual leave
9 hours LWOP
329
3
9 hours regular time
1 hour LWOP
8 hours annual leave
265
4
9 hours regular time
9 hours LWOP
223
5
3 hours regular time
3 hours annual leave
195
6
9 hours regular time
9 hours LWOP
183
7
8 hours regular time
8 hours LWOP
182
8
9 hours regular time
9 hours LWOP
181
9
9 hours telework
9 hours LWOP
110
10
9 hours regular time
6 hours annual leave
3 hours LWOP
69
11
9 hours regular time
9 hours LWOP
68
12
9 hours telework
9 hours LWOP
13
Source: OIG analysis of EPA time and attendance data.
During interviews with the OIG:
•	Employee A said that timecard adjustments were needed because the
original work status recorded was approved and processed in advance of
an upcoming workday. The employee subsequently did not report to duty
and forgot to adjust the timecard after returning to work to reflect the
appropriate nonworking status.
•	Employee B could not recall the exact circumstances surrounding the
timecard adjustments made; however, of the 12 adjustments made,
10 changed the employee's status from an official work status to LWOP or
annual leave.
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Untimely adjustments force supervisors to recall an employee's work status
months after the original timecard was processed, which can be a difficult task.
Conclusion
While the EPA's RMDS No. 2540-08-P1 outlines the responsibilities for the
submission and approval of adjustments and corrections, the procedure does not
include time frames for these adjustments and corrections. By setting time frames
and establishing system controls to prevent adjustments from being processed
months after the original timecards are approved, the EPA could minimize the
potential for unwarranted or improper adjustments. Without additional controls,
employees could manipulate time reporting codes to create salary overpayments
and restore leave balances.
Recommendation
We recommend that the Chief Financial Officer:
3. Implement a policy that defines time frames for time and attendance
adjustments, and implement controls in PeoplePlus to prevent adjustments,
without prior approval, after the established time frames.
Agency Comments and OIG Evaluation
The OCFO disagreed with Recommendation 3 and said that adequate policies and
procedures are in place to address prior period pay adjustments. The OCFO said
that the agency's current payroll provider allows prior pay period adjustments up
to 52 pay periods (or 2 years) after the original entry and believes that limiting
time frames to make prior pay period adjustments may be burdensome and may
negatively impact the EPA's programs. Also, the OCFO said that the PeoplePlus
system, a commercial off-the-shelf product, does not impose time limitations and
cannot monitor prior pay period timecard adjustments against set time frames.
The OCFO said that it recognizes the need to continuously review and strengthen
controls over its processes, and it issued timecard reconciliation instructions to the
agency's PeoplePlus Coordinators on August 22, 2019. In addition, the OCFO
will provide a program/region-specific timecard reconciliation report to the
agency PeoplePlus Coordinators. This report will help the coordinators identify
discrepancies between employee leave requests and timecards. Effective
immediately, the OCFO said it would institute a process to regularly remind
supervisors and PeoplePlus Coordinators to run the reconciliation report as part of
their biweekly time and attendance duties.
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We acknowledge the limitations with the PeoplePlus system and that the agency
has policy and procedures in place that address prior pay period adjustments,
including a statement that employees are responsible for the "timely"
identification of prior period adjustments/corrections. However, the policy does
not define "timely." In addition, the allowed time frame of 52 pay periods for
adjustments seems contrary to the intent of "timely." The agency should establish
a reasonable time frame for making adjustments that meets the intent of "timely"
and fits the needs of its program offices.
We consider Recommendation 3 unresolved with resolution efforts in progress.
The full response provided by the OCFO is in Appendix B.
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Chapter 4
TCTO Requested and Approved Beyond
Required Time Frames
We identified two OAR employees who received unallowable TCTO in fiscal
year 2016. The TCTO requests were not submitted and approved within the
required time frames established in the EPA's Pay Administration Manual.
However, the employees received TCTO because the approving officials did not
enforce the established time frames for the submittal of TCTO. As a result, staff
received TCTO contrary to the EP A's Pay Administration Manual.
TCTO Laws and EPA's Pay Administration Manual
Compensatory time off for travel is authorized in Section 203 of the Federal
Workforce Flexibility Act of 2004 (Public Law 108-411), which is codified at
5 U.S.C. § 5550b. Section 5550b provides for the following:
[E]ach hour spent by an employee in travel status away from the
official duty station of the employee, that is not otherwise
compensable, shall be treated as an hour of work or employment
for purposes of calculating compensatory time off.
The OPM promulgated regulations implementing 5 U.S.C. § 5550b at 5 CFR
Part 550, Subpart N. Among these regulations, 5 CFR § 550.1405(b) includes the
following requirement:
An employee must comply with his or her agency's procedures for
requesting credit of compensatory time off under this section.
Employees must file such requests within the time period required
by the agency. An employee's request for credit of compensatory
time off for travel may be denied if the request is not filed within
the time period required by the agency.
The EPA's Pay Administration Manual contains basic legal requirements, as well
as agency policy and procedures, regarding pay administration for EPA
employees. Chapter 18, "Travel Compensatory Time Off," constitutes the
agency's policy on the administration of TCTO, including requesting, approving,
earning, crediting, tracking and forfeiting expired TCTO. In accordance with
Section VII(b)(l) of this policy, employees must submit, and supervisors must
approve, a preliminary request for projected TCTO earnings per trip.
Section VII(d) requires that after an employee completes official travel and
submits the subsequent travel voucher, any employee who wishes to claim credit
for TCTO must submit a final request within 30 calendar days of completing
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travel. Section VII(e) also includes the following requirements regarding
extensions to that 30-day time frame:
In cases in which there are issues requiring resolution or an
employee needs additional time to obtain materials to corroborate
the employee's final request, the employee may request an
extension of the final submission deadline from the supervisor. In
the latter case, the employee must explain to his or her supervisor
the reasons that more time is needed. It is a matter of supervisory
discretion whether or not to grant additional time to the employee
beyond the 30-calendar-day deadline.
Failure to submit a final TCTO request within 60 days after travel
completion will result in forfeiture of all potential TCTO credit for
the period of travel.
Significant Delays in TCTO Requests
To test compliance with the agency's TCTO policy, we selected a judgmental sample
of fiscal year 2016 travel records for three OAR employees. One of the three
employees requested TCTO within the required time frame. However, as shown in
Table 3, two of these employees submitted a total of five requests anywhere from
60 to 167 days after travel was completed, for a total of 107 TCTO hours.
Table 3: Total hours requested and number of days to submittal
Employee
Request
TCTO
hours
Days after travel completion that
TCTO request was submitted
Employee A
1
31.50
103

2
25.50
60
Employee B
1
16.00
167

2
19.25
157

3
14.75
125
Total
5
107.00

Source: OIG analysis of EPA travel records.
Except for the one 60-day request submitted by Employee A, the remaining four
requests exceeded the 60-day maximum submittal period specified in the TCTO
policy. In addition, we found no evidence in the travel records indicating that the
employees requested additional time to submit the requests.
Conclusion
The EPA's lack of enforcement of the TCTO policy enabled employees to receive
TCTO that otherwise should have been forfeited. In addition, the requests for
some TCTO credit violated EPA policy. Without enforcement, there is potential
for future violations.
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Recommendations
We recommend that the Assistant Administrator for Air and Radiation:
4.	Implement controls to enforce compliance with the requirements
associated with requesting and approving Travel Compensatory
Time Off, including established time frames.
We recommend that the Assistant Administrator for Mission Support:
5.	Evaluate and determine whether the improperly credited Travel
Compensatory Time Off should have been forfeited as required by the
EPA's Pay Administration Manual and, if so, whether the time off or
value of any time off used should be recovered.
Agency Comments and OIG Evaluation
The OAR agreed with Recommendation 4. On August 21, 2019, the OAR issued
a memorandum to its Directors explaining the requirements and associated time
frames for requesting and approving TCTO. In addition, the OAR will include
TCTO within annual management reviews of each office conducted by the
Deputy Assistant Administrator. For these reviews, Deputy Assistant
Administrator staff will prepare an analysis of the TCTO earned and used and
then will review that analysis against supporting documentation to verify
compliance. We agree with the OAR's corrective actions and consider
Recommendation 4 to be complete. The OAR's full response is in Appendix C.
The OMS agreed with Recommendation 5, will review the cited TCTO cases and
will issue a determination on the findings. If recovery of the time off or the value
of the time off is warranted, the OMS will notify the OAR and the OCFO so that
the recovery process may be initiated. We accept the agency's corrective action
and the proposed completion date. We consider Recommendation 5 to be resolved
with corrective actions pending. The OMS' full response is in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page No.
Subject
Status1
Action Official
10
14
14
Update the Leave Manual and Leave Handbook to reflect U
laws and regulations implemented since 1995 for leave
taken under the Family and Medical Leave Act of 1993.
Develop a process and establish time frames to regularly U
review and update the Leave Manual and Leave Handbook
to incorporate new laws and regulations.
Implement a policy that defines time frames for time and
attendance adjustments, and implement controls in
PeoplePlus to prevent adjustments, without prior approval,
after the established time frames.
Implement controls to enforce compliance with the
requirements associated with requesting and approving
Travel Compensatory Time Off, including established time
frames.
Evaluate and determine whether the improperly credited
Travel Compensatory Time Off should have been forfeited
as required by the EPA's Pay Administration Manual and, if
so, whether the time off or value of any time off used
should be recovered.
U
Assistant Administrator for
Mission Support
Assistant Administrator for
Mission Support
Chief Financial Officer
Assistant Administrator for
Air and Radiation
Assistant Administrator for
Mission Support
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
8/21/19
1/31/21
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
OMS Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OA-FY17-0090 "Outdated
EPA Leave Manual and Control Weaknesses Caused Irregularities in Office of Air and
Radiation's Timekeeping Practices," dated August 7, 2019
FROM: /^JDonna J. Vizian, Principal Deputy Assistant Administrator
TO:	Charles J. Sheehan, Acting Inspector General
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. The Office of the Chief Financial Officer provided its response to the audit report on
September 5, 2019, addressing recommendation three. The Office of Air and Radiation will be
addressing recommendation four. The following is a summary of the Office of Mission Support's
overall position, along with its response to recommendations one, two and five.
AGENCY'S OVERALL POSITION
OMS concurs with recommendations one and five and has provided corrective actions as well as
estimated completion dates for both; however, we disagree with recommendation two and
proposed an alternative recommendation.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended Correction Action(s)
Estimated Completion
1.
Update the Leave
Manual to reflect
laws and regulations
implemented since
1995 pertaining to
leave taken under the
Family and Medical
OMS is updating the Leave Manual to
reflect current laws and regulations. The
new policy, once approved, will supersede
the out-of-date Leave Manual and Leave
Handbook. The Leave Handbook was
originally developed as a supplemental
document until the Leave Manual could
OMS will enter the revised
Leave Manual into
directives clearance review
by June 30, 2021.
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Leave Act and update	be updated. With the issuance of the new
the Leave Handbook	policy, the Leave Handbook will no
to be consistent with	longer be applicable or necessary,
the manual.
No.
Recommendation
High-Level Intended Correction Action(s)
Estimated Completion
5.
Evaluate and
determine whether the
improperly credited
Travel Compensatory
Time Off should have
been forfeited as
required by the EPA's
Pay Administration
Manual and, if so,
whether the time off
or value of any time
off used should be
recovered.
OMS will review the travel compensatory
time off cases and issue a determination
on the findings. If recovery is warranted,
OMS will notify the Office of Air and
Radiation and the Office of the Chief
Financial Officer so the process may be
initiated.
January 31, 2021
Disagreement
No.
Recommendation
Agency Explanation/Response
Proposed Alternative
Estimated
Completion
2.
Develop a process
and establish time
frames to review
and update the
Leave Manual and
Leave Handbook to
incorporate new
laws and regulations
on a regular basis.
OMS already has an
established process in place to
identify policy priorities and
updates. The priorities are
established based on senior
management decisions, Office
of Personnel Management
guidance, changes in
regulation, law, executive
order, Office of Inspector
General commitments, and
customer requests. The
progress of these policies are
tracked monthly in the Office
of Human Resources' policy
tracker.
Updates to the new
Leave Manual will be
made as soon as
possible to reflect
changes to the law or
regulations. In order
to affect a change
quickly, an HR
bulletin or guidance
may be issued to
ensure the agency has
a policy in place.
Completed; the
most recent
update to the
OHR policy
tracker was
September 4,
2019
CONTACT INFORMATION
If you have questions on this response, please contact Debbi Hart, director, Policy, Planning and
Training Division, at (202) 564-2011 or Loretta Hunt, chief, Policy and Accountability Branch,
at (202) 564-6963.
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Attachments
cc: John Trefry
Jean Bloom
Angela Bennett
Kevin Collins
David Penman
Sherri Anthony
Annette Morant
Brittany Wilson
David Bloom
Carol Terris
Diane Kelty
Betsy Shaw
Scott Monroe
Wesley J. Carpenter
Mara J. Kamen
Hitch Peabody
Debbi Hart
Liz Engebretson
Tracye Smith-Starkey
Loretta Hunt
Janice Jablonski
Marilyn Armstrong
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Appendix B
OCFO Response to Draft Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
U V H'Ni .1 N ti „ 0 •, \
SEP 05 2011
memorandum
SUBJECT: Response to the Office of Inspector (lateral's Draft Report,
Outdated hPA Leave Po!ic\ and Control Weaknesses Caused irregularities in Office of
Alr d J-^r|?lon s ' '"keeping Practices"" dated August 7, 2019
FROM:
•-Office of the Chief Financial Officer
TO:	John I re fry. Director. Forensic Audits
Office of Inspector General
Thank you for the opportunity to respond to the issues and recommendations presented in the
Office of Inspector General Draft Report, Project No. OA-FY17-0090 pertaining to the Office of
Air and Radiation's time and attendance practices. The draft report includes five
recommendations, two of which are directed to the Office of the Chief Financial Officer. Note
that the Office of Mission Support and the OCFO have agreed that the OMS will respond to the
OIG's Recommendation No. 5 regarding Travel Compensatory Time Off. For the remaining
recommendation directed to the OCFO, the U.S. Environmental Protection Agency does not
agree. We explain our position and provide alternatives to this recommendation below.
RESPONSE TO RECOMMENDATION:
RECOMMENDATION 3: We recommend that the Chief Financial Officer implement a policy
that defines time frames for time and attendance adjustments and implement controls in
PeoplePlus to prevent adjustments, without prior approval to make changes, after the
established time frames.
• The EPA disagrees with this recommendation as adequate policies and procedures are
currently in place to address prior period pay adjustments. The Interior Business
Center, the agency's payroll provider, allows prior period timecard adjustments and
corrections to be processed up to 52 pay periods after the original entry. All employee
prior pay period adjustments referenced in Table 1 and Table 2 of the draft report fall
within the IBC 52-pay period window for adjustments. Additionally, the Resource
Management Directive System No. 2540-08-P1, Payroll, Time and Attendance
Reporting, dated September 5, 2014, sets forth specific responsibilities for employees
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and supervisors in the biweekly time and attendance process and reaffirms their
responsibility for timely submission of accurate time and attendance.
•	The agency believes that instituting time limitations or set timeframes to make prior
pay period adjustments may be burdensome and may negatively impact the EPA's
programs. For example, the Superfund Program necessitates the need for prior-period
timecard adjustments to ensure proper accounting for cost recovery. Also, the
PeoplePlus system, a Commercial Off the Shelf product, does not impose time
limitations and does not have the ability to monitor prior pay period timecard
adjustments against set timeframes.
•	The agency recognizes the need to continuously review and strengthen controls over
its processes. The OCFO issued timecard reconciliation instructions to the agency's
PeoplePlus Coordinators on August 22, 2019. In addition, the OCFO will provide a
Program/Region-specific reconciliation report to the agency PeoplePlus Coordinators
identifying their organization's timecard reconciliation anomalies. The report will
help identify discrepancies between an employee's timecard and leave requests
submitted using the leave management module in PeoplePlus. Effective immediately,
the OCFO will institute a process to regularly remind supervisors and PeoplePlus
Coordinators to run the reconciliation report as part of their biweekly time and
attendance duties.
CONTACT INFORMATION
If you have any questions regarding this response, please contact Ebonie Smith, Agency Audit
Follow Up Coordinator, at (919) 541-4387 or smith.ebonie@epa.gov.
cc: Carol Terris
Jeanne Conklin
Richard Gray
Meshell Jones-Peeler
Paige Hanson
Eva Ripollone
Kevin Christensen
Aileen Atcherson
Sherri' Anthony
Angela Bennett
Ebonie Smith
Heidi Gross
Larisha McKnight
Nikki Wood-Newton
Diane Kelty
Anne L. Idsal
Clint Woods
Scott Monroe
Ann Campbell
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Donna J. Vizian
David Zeckman
Marilyn Armstrong
Wes Carpenter
Mara Kamen
Hitch Peabody
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Appendix C
OAR Response to Draft Report
^7 I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C 20460
August 21, 2019
OFFICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT: Response to Office of Inspector General's Draft Report. Outdated EPA Leave
Manual and Control Weaknesses Caused Irregularities in Office of Air and
Radiation 's Timekeeping Practices (OA-FY17-0090)
The Office of Air and Radiation (OAR) welcomes the opportunity to review and respond
to the Office of Inspector General's (OIG) draft report, Outdated EPA Leave Manual and
Control Weaknesses Caused Irregularities in Office of Air and Radiation's Timekeeping
Practices (OA-FY17-0090).
In this and prior audits of OAR's time and attendance practices, we appreciated the audit
teams' thoroughness and responsiveness in sharing their findings. OAR endeavors to comply
with the Environmental Protection Agency's policies for time and attendance and leave. While
we believe we have made great progress in promoting a culture of efficiency and accountability
in this respect, we also recognize that employees sometimes make mistakes in reporting and
approving time. OIG's recommendations help OAR understand where to direct our focus in
providing both direction and support to the workforce.
The draft report directed one of its five recommendations to OAR. OAR's response is
below.
Recommendation 4: Implement controls to enforce compliance with the requirements
associated with requesting and approving Travel Compensatory Time Off, including established
time frames.
FROM: Anne L. Idsal
Acting Assistant Administrator
/
TO:
John Trefry, Director, Forensic Audits
Office of Audit and Evaluation
Office of the Inspector General
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Response: OAR agrees with this recommendation. In response, OAR's Program Management
Official issued a memorandum to OAR Office Directors on August 21, 2019, explaining the
requirements and associated time frames for requesting and approving travel compensatory time
off (TCTO). A copy of the memorandum is attached.
For purposes of implementing controls, OAR will include TCTO as a standing topic for
annual management reviews with each OAR office. The Deputy Assistant Administrator (DAA)
conducts the reviews with the director of each of OAR's four primary program offices.
Management reviews address key administrative areas such as status of funds, FTE and onboard
ceilings, travel, and invoice approval, as well as other topics that may vary from year to year.
The DAA's staff prepare analyses in advance of each management review in order to
assess current status as well as compliance, where appropriate. Staff will determine who reported
earned and used TCTO and will review supporting documentation for a sample of instances
across offices to verify compliance. As an illustration, we found that, across all FY2016 pay
periods, over 240 employees in all four program offices earned TCTO. (OIG's draft report
focused on a judgmental sample of three OAR employees who reported TCTO in FY2016.)
Planned Completion: Completed with the issuance of the OAR memorandum referenced above
that explained procedures to ensure compliance with the requirements associated with requesting
and approving Travel Compensatory Time Off, including established time frames. OAR's
controls will be ongoing.
Again, OAR thanks the OIG for your thorough attention to our operations and for your
recommendation on how we may improve our management controls for TCTO. If you have
questions regarding this response, please contact Scott Monroe at (202) 564-1271 or
monroe.scott@epa.gov.
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Appendix D
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Assistant Administrator for Mission Support
Chief Financial Officer
Assistant Administrator for Air and Radiation
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Mission Support
Associate Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Administration and Resources Management,
Office of Mission Support
Associate Chief Financial Officer
Associate Chief Financial Officer for Policy
Deputy Assistant Administrator for Air and Radiation
Senior Advisor to the Assistant Administrator, Office of Air and Radiation
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Resources and Business Operations, Office of Mission Support
Director, Office of Human Resources, Office of Mission Support
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Mission Support
Audit Follow-Up Coordinator, Office of the Chief Financial Officer
Audit Follow-Up Coordinator, Office of Air and Radiation
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