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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
EPA Needs to Improve
Management and
Monitoring of Time-Off
Awards
Report No. 20-P-0065
December 30, 2019
V
Time Off
Awarded

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Report Contributors:
John Trefry
Leah Nikaidoh
Phil Cleveland
Abbreviations
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
GS	General Schedule
OIG	Office of Inspector General
OPM	U.S. Office of Personnel Management
U.S.C.	United States Code
Cover Image: From calendar years 2015 through 2017, the agency awarded 355,511 hours of
time off. (EPA OIG image)
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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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Send us your Project Suggestions

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q* j.	U.S. Environmental Protection Agency	20-P-0065
•?	\ Office of Inspector General	December 30,2019
<
w 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
determine whether the agency
is appropriately using split and
combined time-off and monetary
awards. A split award is a
monetary award that has been
separated into two or more
smaller awards. A combined
award includes both time-off
and monetary awards.
In response to an OIG audit
completed in 2015 (EPA OIG
Report No. 16-P-0048, issued
November 30, 2015), the EPA
adopted an interim policy
related to the approval of
awards. This interim policy
requires a higher-level review
and approval of individual
employee monetary awards that
total more than $5,000 for any
one employee in a fiscal year.
This report addresses the
following:
• Operating efficiently and
effectively.
EPA Needs to Improve Management and
Monitoring of Time-Off Awards
What We Found
The EPA successfully implemented interim
policies and procedures for reviewing and
approving monetary awards that total more than
$5,000 in a fiscal year for any one employee.
However, the agency does not follow U.S. Office
of Personnel Management guidance for valuing
time-off awards. Specifically, the EPA does not
assess a value for time-off awards as part of its
awards program. The agency, therefore, cannot determine whether its time-off
awards are consistently assessed, approved at the appropriate level when
combined with monetary awards, and commensurate with employee
achievements.
The EPA's time-off
awards program needs
to be held to the same
standard as the
agency's monetary
awards program, both
in execution and
resource management.
We also found that the agency does not monitor time-off awards as a
resource. From calendar years 2015 through 2017, the agency awarded
355,511 hours—a total of over 170 full-time positions—in time-off awards.
However, these awards are not managed or monitored in regard to agency
productivity or workload management. A large number of time-off hours
awarded results in lost productivity, which can adversely impact the agency's
mission.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Mission Support (1) revise
EPA Manual 3130 A2, Recognition Policy and Procedures Manual, to
establish a methodology to determine the equivalent value of time-off awards;
(2) update its 2016 interim policy to include the combined value of all
awards—both monetary and time-off—when determining the appropriate level
of review and approval, and incorporate this update into EPA Manual 3130 A2;
and (3) establish internal control procedures to monitor time-off awards as part
of EPA resource management.
The EPA did not agree with Recommendations 1 and 2. The agency agreed
with Recommendation 3 but did not provide acceptable planned corrective
actions. We consider all three recommendations unresolved.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
Noteworthy Achievement
In 2019, the EPA streamlined its processing of monetary and time-off awards.
According to the agency, this streamlined process reduced the overall costs of
processing awards by 31.3 percent or $1.33 million annually.
List of OIG reports.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
December 30, 2019
MEMORANDUM
SUBJECT: EPA Needs to Improve Management and Monitoring of Time-Off Awards
Report No. 20-P-0065
FROM: Charles J. Sheehan, Acting Inspector General
TO:
Donna J. Vizian, Principal Deputy Assistant Administrator
Office of Mission Support
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-FY18-0090.
This report contains findings that describe the problems the OIG has identified and improvements 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
This report contains three unresolved recommendations. In accordance with EPA Manual 2750, the
resolution process begins immediately with the issuance of the report. We are requesting a meeting
within 30 days between the Assistant Administrator for Mission Support and the OIG's Assistant
Inspector General for Audit and Evaluation. If resolution is still not reached, the Office of Mission
Support is required to complete and submit a dispute resolution request to the Chief Financial Officer.
We will post this report to our website at www.epa.gov/oig.

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EPA Needs to Improve Management
and Monitoring of Time-Off Awards
20-P-0065
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Responsible Offices		2
Scope and Methodology		3
Prior Audit Report		3
Noteworthy Achievement		4
2	EPA Needs Methodology to Determine the Equivalent
Value of Time-Off Awards		5
Valuation of Combined Awards		5
Conclusions		7
Recommendations		7
Agency Response and OIG Evaluation		7
3	EPA Needs to Monitor Time-Off Awards		9
OPM Provides Time-Off Award Guidance		9
Significant Inconsistencies Shown in Time-Off
Awards Management		9
Conclusions		12
Recommendation		12
Agency Response and OIG Evaluation		12
Status of Recommendations and Potential Monetary Benefits		14
Appendices
A Office of Mission Support Response to Draft Report	 15
B Distribution	 19

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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 determine whether the agency is
appropriately using split and combined time-off and monetary awards. In
response to an OIG audit completed in 2015 (EPA OIG Report No. 16-P-0048.
issued November 30, 2015), the agency implemented new controls to require a
higher level of review for individual employee monetary awards that total more
than $5,000 in a fiscal year. We considered these new controls in our analysis.
Background
In accordance with 5 U.S.C. Chapter 45, Incentive Awards, and 5 CFR Part 451,
Subpart A, Agency Awards, federal agencies are authorized to pay monetary
awards and grant time off to their employees as warranted. These authorities also
establish requirements for agency awards programs.
Split Awards
A split award is a monetary award for one achievement that has been deliberately
separated (i.e., split) into two or more smaller awards so that each individual
award does not exceed the threshold that requires a higher level of review. Per the
EPA's Interim Policy Change to the Monetary Awards Approval Process, dated
May 18, 2016, this threshold is $5,000. Award officials should never split
monetary awards.
Combined A wards
Under EPA Manual 3130 A2, Recognition Policy and Procedures Manual,
agency employees can be granted a combined award—a time-off award in
conjunction with a monetary award—to recognize a single achievement.
The U.S. Office of Personnel Management's (OPM's) Time-Off Awards guidance
states that agencies decide when and how to use time-off awards to enhance their
overall awards program. Agencies do not have to provide additional funding for
these awards because they are "time off from duty" and do not have an "explicit
cash value." The OPM also states, "Agencies may grant time-off awards along
with other forms of awards as long as the total value of the awards given is
commensurate with the contribution being recognized."
20-P-0065
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Award Approval Process
In accordance with EPA Manual 3130 A2, an employee award nomination is
prepared by the recommending official (usually the employee's immediate
supervisor) and approved by another supervisor in the employee's office. If the
individual monetary award is greater than $5,000, then the award must be
approved by the Administrator or delegated/redelegated senior officials, including
Assistant Administrators, Regional Administrators, Associate Administrators and
regional office Directors.
In addition, as a result of a previous OIG audit, the EPA adopted the Interim
Policy Change to the Monetary Awards Approval Process on May 18, 2016. This
interim policy requires a higher-level award approval when an employee is
nominated and approved for a total of more than $5,000 in monetary awards in
1 fiscal year.
There are no specific or additional review requirements for combined awards.
Table 1 outlines the EPA's award approval process.
Table 1: Award approval process
Award type/amount
Recommending official
Approving official
Monetary award up to $2,000
Supervisor
Supervisor
Monetary award $2,001 to $5,000
Supervisor*
Another supervisor
Individual monetary award $5,001 to
$10,000
Supervisor
Executive-level official
(Assistant Administrators,
Regional Administrators,
General Counsels, etc.)
Cumulative monetary awards (per
employee) greater than $5,000 in
1 fiscal year
Supervisor
Executive-level official
Individual time-off award 1 day or less
Supervisor
Supervisor
Individual time-off award more than
1 day
Supervisor
Another supervisor
Source: EPA Manual 3130 A2 and EPA's Interim Policy Change to the Monetary Awards Approval
Process.
"These awards may also be approved by an executive-level official without a supervisor
recommendation.
Responsible Offices
The Office of Mission Support leads the agency's core mission support functions.
Key functions of this office include facilities and critical asset protection,
acquisition activities, grants management, human capital, information technology,
and information management activities.
The Office of Human Resources, within the Office of Mission Support, is
responsible for providing policy and guidance on employment, pay, leave and
employee conduct.
20-P-0065
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Scope and Methodology
We conducted this audit from December 2017 to June 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 the audit
objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions presented in this report.
To determine whether the EPA split monetary awards, we performed the
following activities:
•	Reviewed OPM and agency policy regarding monetary awards.
•	Obtained award information for calendar years 2015 through 2017.
•	Reviewed award data to determine the basis for the awards provided to
individual employees in a given fiscal year.
•	Selected a judgmental sample of 23 multiple-award recipients to
determine whether individual awards were split to avoid a higher level of
management review.
To determine whether the EPA appropriately awarded combined time-off and
monetary awards, we performed the following activities:
•	Reviewed OPM and agency policy regarding monetary and time-off
awards.
•	Interviewed agency officials regarding annual award processes.
•	Reviewed award data for fiscal years 2015 through 2017 and selected a
judgmental sample of multiple individual awards for testing based upon
the dates, justifications, amounts and types of awards given to the same
employee.
•	Tested supporting documentation for compliance with federal regulations
and agency policy.
Prior Audit Report
EPA OIG Report No. 16-P-0048. Awards Made by EPA 's Office of the Chief
Financial Officer Raise Questions, issued November 30, 2015, found that an
agency employee received two $4,500 monetary awards within 3 months of the
20-P-0065
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employee's start date. The amounts and timing of the awards gave the appearance
that the awards may have been improperly split to avoid a higher level of review.
We recommended, and the agency agreed, that a higher level of management
review be established for individuals who receive multiple monetary awards
totaling more than $5,000 in a given fiscal year. The agency completed its
corrective actions to implement this recommendation on May 18, 2016.
Noteworthy Achievement
During this audit, we learned that the Office of Human Resources adopted new
operating procedures in March 2019 for processing awards. To reduce the volume
of documents that program and regional offices must submit for employee
awards, the Office of Human Resources began using a mass-approval process that
agency offices must only periodically complete. The Office of Human Resources'
Shared Service Centers review these mass submissions for compliance with
agency awards policies. Once the awards are reviewed and approved, the Office
of Human Resources transmits the information to the EPA's payroll provider. The
payroll provider then processes the awards, generates individual employee
personnel actions and uploads these actions to the employees' electronic official
personnel files. These procedures substantially reduced the manual processing of
awards. According to the agency, this streamlined process reduced the overall
costs of processing awards by 31.3 percent, or $1.33 million annually.
The agency subsequently issued an interim policy for awards records retention:
Interim Policy Change for Document Retention of Time-Off and Monetary Award
Forms, dated May 10, 2019. This interim policy requires that supporting
documentation for mass-processed, nonperformance-based awards be retained by
each regional Human Resources Officer or Program Management Officer, in
accordance with the EPA records schedule. Documentation for individually
processed awards will continue to be submitted to the Shared Service Centers and
maintained in the Federal Personnel and Payroll System.
20-P-0065
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Chapter 2
EPA Needs Methodology to Determine the
Equivalent Value of Time-Off Awards
The EPA successfully implemented its interim policy for reviewing monetary
awards greater than $5,000. We found that monetary awards were not being split
to avoid additional levels of approval. However, the agency cannot assess the
equivalent value of time-off awards because it has not formalized a methodology
for performing the assessment. Therefore, the agency cannot determine the total
value of a combined award, nor can the EPA confirm that the total value of the
combined award is equivalent to the contribution made by the award recipient, as
prescribed under OPM guidance. Further, the agency cannot determine whether
the combined award is being appropriately approved.
Valuation of Combined Awards
We sampled 50 individual awards made to 23 employees from fiscal years 2015
through 2017. Awards made to 13 of the 23 employees had both monetary and
time-off components. The monetary amounts of these combined awards ranged
from $1,190 to $5,000, and the total time-off portions ranged from 20 to
80 hours,1 as shown in Table 2.
Table 2: Assessment of 13 employees with combined awards
Employee
Award
effective
date
Monetary
award
Time-off
award
(hours)
Equivalent
value of time-
off awards *
Combined value **
1
7/21/16
$4,000
20
$1,514
$5,514
2
5/9/17
$2,000
-
-
$6,423
6/6/17
$2,000
-
-
6/15/17
-
40
$2,423
3
5/16/16
$4,999
-

$7,203
5/17/16
-
30
$2,204
4
7/3/17
-
40
$3,103
$8,102
7/10/17
$4,999
-
-
5
7/19/17
-
40
$3,074
$7,974
7/20/17
$4,900
-
-
6
6/6/16
$4,000
40
$2,964
$6,946
7
5/19/17
-
40
$3,031
$9,062
5/22/17
-
40
$3,031
6/2/17
$3,000
-
-
8
8/10/17
$1,500
20
$1,350
$5,700
8/17/17
$1,500
20
$1,350
1 As shown in Table 2, Employees 7 and 9 received two 40-hour time-off awards in the same fiscal year, for a total
of 80 hours each.
20-P-0065
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Employee
Award
effective
date
Monetary
award
Time-off
award
(hours)
Equivalent
value of time-
off awards *
Combined value **
9
7/19/16
$1,190
-
-
$6,060
7/20/16
-
40
$2,435
7/21/16
-
40
$2,435
10
5/19/15
$4,750
-
-
$7,792
5/21/15
-
40
$3,042
11
1/2/15
$5,000
40
$2,979
$7,979
12
6/17/15
$2,000
-
-
$7,242
6/19/15
$2,200
-
-
6/24/15
-
40
$3,042
13
6/5/15
$4,600
-
-
$7,342
6/8/15
-
40
$2,742
Source: OIG analysis of agency award documentation.
•	We calculated the equivalent value of the time-off award by multiplying the
number of hours awarded by the individual employee's hourly rate at the time of
the award.
** Combined value is the monetary awards plus the equivalent value of the
time-off awards.
The OPM's Time-Off Awards guidance allows agencies to decide when and how
to use time-off awards. The OPM guidance also states that agencies:
•	"[M]ay grant time-off awards along with other forms of awards as long as
the total value of the awards given is commensurate with the contribution
being recognized."
•	"[N]eed to remember these are salary dollars being paid for time not
worked, so there is a cost involved."
However, the EPA does not determine the equivalent value for time-off awards
because there is no defined methodology or formal guidance documenting how
time-off awards should be valued. Without a defined value for time-off awards,
the agency cannot determine whether a combined award is commensurate with
the employee's achievements. For example, under the EPA's interim policy, the
following two awards would be assessed as having the same value, and neither
would require higher-level approval:
•	A $5,000 monetary award.
•	A $5,000 monetary award and 40 hours of time off.
Further, a single monetary award of $5,001 would require a higher-level approval
than the combined award of $5,000 and 40 hours, which would not require any
additional review. To improve management oversight, the EPA should assess
awards according to their total value of the combined award, not just the value of
the monetary award component.
20-P-0065
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In addition, the agency's lack of a defined methodology to assess the equivalent
value of time-off awards results in inconsistencies. Managers are forced to use
various methods to attempt to assess the equivalent value of time off when
making award decisions. For example, one supervisor we interviewed determines
the equivalent value of time-off awards by using the "average" hourly rate for
staff reporting to that supervisor. We identified one combined award where the
manager increased an employee's monetary amount by $840 and reduced the
time-off amount by 4 hours. This substitution could give the appearance that the
manager equated 4 hours of time-off to $840, resulting in an effective rate of $210
per hour, which was considerably higher than the employee's hourly rate.
Conclusions
Although the EPA has guidance and a methodology for assessing the equivalent
value of an employee's contribution with respect to monetary awards, the agency
lacks a comparable process to determine the equivalent value of time-off awards.
As a result, we found that, even when monetary and time-off awards were
combined to create an award with an equivalent value of more than $5,000, no
additional review and approval from a higher designated official was required or
sought. However, there are costs associated with time-off awards, since
employees continue to draw their salaries while authorized to be absent. Agency
policies, therefore, need to consider the equivalent value of all awards in totality
with respect to both the justification and approval of the award and the
determination of whether an award is commensurate with the employee's
achievements.
Recommendations
We recommend that the Assistant Administrator for Mission Support:
1.	Revise EPA Manual 3130 A2, Recognition Policy and Procedures
Manual', to establish a methodology for determining the equivalent value
for time-off awards.
2.	Update the EPA's 2016 Interim Policy Change to the Monetary Awards
Approval Process and incorporate the policy into EPA Manual 3130 A2 to
require that the combined value of all awards (both monetary and time-
off) be used to determine if the award is commensurate with the
employee's achievements and has the appropriate level of review and
approval.
Agency Response and OIG Evaluation
The agency disagreed with Recommendations 1 and 2 in its response to the draft
report.
20-P-0065
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For Recommendation 1, the agency stated that there is no regulatory requirement
for determining the monetary value of time-off awards, and the recommendation
conflicts with OPM guidance. We do not agree with the agency's position. While
the OPM's guidance states that time-off awards do not have an explicit monetary
value, the OPM also recognizes that there is a cost involved related to salary
dollars being paid for time not worked. Additionally, the agency proposed an
alternative recommendation to revise its interim policy to ensure the total value of
the awards given is commensurate with the contributions being recognized. We
believe the total value of the awards given cannot be determined without
determining the equivalent value of the time-off awards.
As part of the agency's response, the Office of Mission Support said that it would
update its awards manual and enter it into the directives clearance review process
by October 31, 2022. However, given the length of time estimated (almost
3 years) for entering an updated manual into the review process and the potential
for a lengthy review, we believe the Office of Mission Support should issue an
interim policy with a methodology for determining the equivalent value of time-
off awards to address our recommendation. We consider Recommendation 1 to be
unresolved.
For Recommendation 2, the agency stated that time-off awards do not have an
explicit cash value and proposed an alternative recommendation to revise the
Recognition Policy and Procedures Manual. However, the EPA's proposal does
not meet the intent of our recommendation because the proposal does not assess
the total value of the combined award, including the appropriate level of review
and approval. This recommendation remains unresolved.
The agency's full response to our draft report can be found in Appendix A.
20-P-0065
8

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Chapter 3
EPA Needs to Monitor Time-Off Awards
The agency does not monitor time-off awards as a resource because the EPA does
not assess any value to time-off awards as part of its awards program. From
calendar years 2015 through 2017, the EPA awarded a total of 170.3 full-time
positions in time-off awards. By applying salary averages for EPA employees to
the number of awarded time-off hours, we estimated the equivalent value to be
over $19.47 million. The number of time-off hours awarded each year results in
lost productivity because top performers may not be at work, which can adversely
impact the agency's mission.
OPM Provides Time-Off Award Guidance
While the OPM's Time-Off Awards guidance allows agencies to decide when and
how to use time-off awards, it also states that each federal agency needs to
manage its use of time-off awards and consider the following:
•	"Whether the organization can afford to do without one of its top
performers for this period of time."
•	"Who will do the work while the time-off award recipients are away from
the office."
•	"Whether the organization as a whole would suffer because too many top
performers are not at work if managers across the organization give time-
off awards instead of cash awards because awards funds are low."
Significant Inconsistencies Shown in Time-Off Awards Management
The EPA does not monitor the impact of time-off awards on productivity and
workload management, even though the agency awards a substantial amount of
time-off to its employees each year. We estimated that for the 3 calendar years in
our audit scope, the cost of time-off awards was approximately $19.47 million
(Table 3).
20-P-0065
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Table 3: Cost of time-off awards, calendar years 2015-2017
Calendar
year
Time-off award
hours
Computed
full-time
positions*
EPA national
average salary
Annual equivalent
value of time-off
awards**
2015
108,965
52.2
$113,512
$5,925,326
2016
118,728
56.9
113,820
6,476,358
2017
127,818
61.2
$115,555
7,071,966
Total
355,511
170.3
-
$19,473,650
Source: OIG analysis of agency award data and OPM guidance.
* To calculate the number of full-time positions represented by the time-off hours awarded
each calendar year, we divided the number of time-off award hours by 2,087 hours. This is
the number of hours used by the OPM to convert a federal employee's annual salary to an
hourly rate.
** This is the value computed by multiplying the computed full-time positions and the EPA
national average salary. To determine the annual equivalent value for the time-off awards,
we multiplied the agency national average salary obtained from the FederalPay.org website
with the computed number of full-time positions for each applicable year.
We calculated that for the 3 years we reviewed, the average amount of time off
awarded to EPA employees was 7.6 hours per person (Table 4).
Table 4: Average time-off award amounts, calendar years 2015-2017
Calendar
year
Total number of
EPA employees
Total number of
hours awarded
Agencywide average
hours awarded
2015
15,384
108,965
7.1
2016
15,553
118,728
7.6
2017
15,797
127,818
8.1

46,734
355,511
7.6
Source: OIG analysis of agency award and OPM employee staffing data.
Upon further analysis, we found that there are differences between the time-off
award amounts granted to higher- and lower-graded employees, as well as to
regional and headquarters employees.2 As Figure 1 shows, while headquarters
awarded only a slightly larger number of time-off awards than the regions (11,685
to 10,564, or about a 10 percent difference), headquarters awarded more than
twice as many hours as the regions (238,495 to 117,016, or about a 104 percent
difference). In addition, the average time-off award amount for headquarters was
over 20 hours, which is 45 percent higher than the average of 11 hours for the
regions. Therefore, the average headquarters employee receives 9 hours (or the
equivalent value of $495) more than the average regional employee.3
2	"Headquarters" means those EPA employees who report to an Assistant Administrator, as opposed to "regional"
employees who report to a Regional Administrator.
3	We computed the hourly payroll average by dividing the agency's total equivalent value of time-off awards for
calendar years 2015-2017 ($19,473,650) by the number of total hours awarded that same time period
(355,511 hours): $19,473,650 355,511 hours = $55/hour. By applying the hourly rate, we computed that the
average headquarters employee receives $495 more in time-off awards than the average regional employee:
9 hours x $55 = $495.
20-P-0065
10

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Figure 1: Time-off awards comparison by headquarters and regions, calendar years 2015-2017
Award hours
¦ Headquarters ¦ Regions
fcaa»fcfcEbn
Total: 117,016
Number of awards *
I Headquarters ¦ Regions
Total: 11,685 ¦ Total: 10,566
Average hours per award
¦ Headquarters ¦ Regions
90,000
80,000
70,000
60,000
50,000
40,000
30,000
20,000
10,000
0
86,213
.,605
5,000
4,000
3,000
2,000
1,000
4,267
704
25 n
20
15 -
10 -
0
20.37 20.68 20.20
2015 2016 2017
2015 2016 2017
2015 2016 2017
Source: OIG analysis of agency award data.
* The total number of individual awards granted per calendar year, not the number of employees receiving
awards. An employee may receive multiple individual awards.
As presented in Figure 2, we also noted similar variances when we assessed the
average hours awarded to higher-graded employees—General Schedule (GS)-14
employees and higher—against lower-graded employees—GS-13 employees and
below. Higher-graded employees were awarded on average 5 hours more of time
off (or about 40 percent more) than lower-graded employees.
Figure 2: Time-off awards comparison by employee grade level, calendar years 2015-2017
Headquarters
Average hours per award
¦	GS-13 and below
¦	GS-14 and above
Regions
Average hours per award
¦	GS-13 and below
¦	GS-14 and above
Headquarters and regions
Average hours per award
¦	GS-13 and below
¦	GS-14 and above

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Source: OIG-produced images derived from analysis of agency award data.
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The EPA does not provide any guidance regarding the budgets or numbers for
time-off awards to its offices or regions. This lack of guidance may contribute to
the differences between how many time-off awards and how much time off are
given, both from location-based and grade-level perspectives. These differences
may be warranted based on employee contributions and may not be problematic.
However, the agency's lack of controls to monitor these awards prevents an
analysis from determining whether these differences are appropriate.
During discussions with select EPA regions and offices, we found that some
management teams nonetheless developed and used a budget for time-off awards.
For example, in fiscal year 2018, EPA Region 2 budgeted 1.5 full-time positions
(3,132 hours) for time-off awards. Region 2 then allocated the time-off hours to
each of its divisions based on the staffing level within each division. Region 2 had
756 full-time positions as of October 14, 2017, which would equate to an average
of 4.14 hours of time off per employee.4 Each division then had the discretion to
award time off throughout the year based upon "noteworthy contributions of
staff."
Conclusions
The agency's use of time-off awards is a valuable and highly-used tool for
management to recognize employee accomplishments, yet that tool comes at a
significant cost to the taxpayer. As such, reliable monitoring of time-off awards is
necessary to properly manage them in accordance with OPM guidance.
Recommendation
We recommend that the Assistant Administrator for Mission Support:
3. Establish internal control procedures to manage time-off awards as part of
EPA resource management.
Agency Response and OIG Evaluation
The agency agreed with our recommendation and provided planned corrective
actions and a milestone date. The agency stated that it would conduct evaluations
of its usage of time-off awards as part of the agency's human capital
accountability responsibilities, in accordance with 5 CFR Part 250.5 When asked
to provide additional information on its planned corrective actions, the agency
stated that it is required to maintain an independent audit program to periodically
review all human capital and human resources transactions. The agency said that
4	3,132 hours budgeted ^ 756 onboard full-time positions = 4.14 hours per employee.
5	Per 5 CFR Part 250, Personnel Management in Agencies, Subpart B, agencies are required to perform assessments
of the management of human capital.
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it plans to evaluate time-off awards by December 31, 2021, as part of an overall
assessment of the EPA's human capital practices.
However, the proposed corrective action does not meet the intent of our
recommendation. The agency has provided a general commitment to review time-
off awards but has neither explained what controls it will put in place to manage
the awards nor indicated when internal controls will be implemented. We consider
Recommendation 3 to be unresolved.
The agency's full response to our draft report can be found in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1
7
Revise EPA Manual 3130 A2, Recognition Policy and
Procedures Manual, to establish a methodology for determining
the equivalent value for time-off awards.
U
Assistant Administrator for
Mission Support


2
7
Update the EPA's 2016 Interim Policy Change to the Monetary
Awards Approval Process and incorporate the policy into EPA
Manual 3130 A2 to require that the combined value of all awards
(both monetary and time-off) be used to determine if the award is
commensurate with the employee's achievements and has the
appropriate level of review and approval.
U
Assistant Administrator for
Mission Support


3
12
Establish internal control procedures to manage time-off awards
as part of EPA resource management.
u
Assistant Administrator for
Mission Support


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
Office of Mission Support Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C. 20460
SEP - 3 2019	OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OA-FY18-0090 "EPA Needs
to Improve Management and Monitoring of Time-Off Awards," dated August 8. 2019
FROM: Donna J. Vizian, Principal Deputy Assistant Admini
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.
Following is a summary of the Office of Mission Support's overall position, along with its position on
each of the report recommendations. For the report recommendation with which the agency agrees, we
have provided a high-level corrective action and an estimated completion date. For those report
recommendations with which the agency does not agree, we have explained our position and have
proposed alternative recommendations.
AGENCY OVERALL POSITION
The Office of Mission Support concurs with recommendation number three found within the draft report.
We do not concur with recommendations one and two because there is no regulatory requirement to
determine the monetary value of time-off awards and the recommendations conflict with the U.S. Office
of Personnel Management's guidance specifically stating time-off awards do not have explicit cash value.
AGENCY RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended Correction Action(s)
Estimated Completion
3
Establish internal
control procedures to
monitor time-off
awards as part of
EPA resource
management.
Conduct evaluations of the agency's usage
of time-off awards as part of the agency's
human capital accountability
responsibilities in accordance with 5 CFR
250.
December 31, 2021
^6DSX
* A
I® I
VRo^°
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Disagreements
No.
Recommendation
Agency Explanation/Response
Proposed Alternative
Estimated
Completion
1
Revise EPA Manual
3130 A2, Recognition
Policy and
Procedures Manual,
to establish a
methodology for
determining the
monetary value for
time-off awards.
OIG's recommendation conflicts
with OPM's guidance that time-
off awards do not have explicit
cash value and 5 CFR 451.104(f)
prohibits time-off awards from
being converted to a cash
payment.
OPM's guidance states agencies
should ensure the total value of
the awards given are
"commensurate with the
contribution being recognized."
This is not an attribution to the
monetary value of the time-off
award, but the level of effort
involved in the employee's
contribution and the benefit the
agency derives from the results.
Also, in line with OPM guidance,
agencies should not attempt to
establish methodologies for
determining the monetary value
for time-off awards. Per an email
on August 23, 2019, OPM
confirmed that this statement is
"consistent with the requirement
found in 5 CFR 451.104(f)."
Revise EPA Manual
3130 A2, Recognition
Policy and Procedures
Manual to ensure the
total value of the
awards given are
commensurate with the
contribution being
recognized.
The agency will update
the manual to provide
guidance to supervisors
and managers on how
to determine the
appropriate amount of
time-off that should be
awarded for a
contribution.
Revised manual to
be entered into
directives
clearance review
by October 31,
2022
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No.
Recommendation
Agency Explanation/Response
Proposed Alternative
Estimated
Completion
2
Update the EPA's
2016 Interim Policy
Change for
Document Retention
of Time-Off and
Monetary Award
Forms and
incorporate the
policy into EPA
Manual 3130 A2 to
require that the
monetary value of
all awards (both
monetary and time-
off) be used to
determine if the
award is
commensurate with
the employee's
achievements and
the appropriate level
of review and
approval.
OPM's guidance states time-
off awards do not have explicit
cash value. The 2016 memo
referenced in OIG's report is
specific to monetary awards.
Monetary awards have a cash
value and are paid in addition
to the employee's salary.
Also, current policy already
requires time-off awards in
excess of one workday to
receive a higher-level approval.
Revise EPA Manual
3130 A2,
Recognition Policy
and Procedures
Manual, to include
guidance on how to
determine the
appropriate amount
of time-off that
should be awarded
for a contribution
when given in
conjunction with a
monetary award.
Revised manual
to be entered into
directives
clearance review
by October 31,
2022
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.
cc: John Trefiry
Jean Bloom
Angela Bennett
Kevin Collins
David Penman
Sherri Anthony
Annette Morant
Brittany Wilson
Wesley J. Carpenter
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Mara J. Kamen
Hitch Peabody
Debbi Hart
Liz Engebretson
Tracye Smith-Starkey
Loretta Hunt
Janice Jablonski
Marilyn Armstrong
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Appendix B
Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Assistant Administrator for Mission Support
Principal Deputy Assistant Administrator for Mission Support
Chief of Staff
Deputy Chief of Staff
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Associate Deputy Assistant Administrator for Mission Support
Deputy Assistant Administrator for Administration and Resources Management, Office of
Mission Support
Director, Office of Continuous Improvement, Office of the Administrator
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
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