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«OIG-14-A-05 December 11, 2013 All publicly available OIG reports (including this report) are accessible through NRC’s Web site at: ...»

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AUDIT REPORT

Audit of NRC’s Full-Time Telework Program

OIG-14-A-05 December 11, 2013

All publicly available OIG reports (including this report) are accessible through

NRC’s Web site at:

http:/www.nrc.gov/reading-rm/doc-collections/insp-gen/

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

OFFICE OF THE

INSPECTOR GENERAL

December 11, 2013 MEMORANDUM TO: Mark A. Satorius Executive Director for Operations Stephen D. Dingbaum /RA/

FROM:

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S FULL-TIME TELEWORK PROGRAM

(OIG-14-A-05) Attached is the Office of the Inspector General’s (OIG) audit report titled Audit of NRC’s Full-Time Telework Program.

The report presents the results of the subject audit. Agency comments provided at the November 22, 2013, exit conference have been incorporated, as appropriate, into this report.

Please provide information on actions taken or planned on each of the recommendations within 30 days of the date of this memorandum. Actions taken or planned are subject to OIG followup as stated in Management Directive 6.1.

We appreciate the cooperation extended to us by members of your staff during the audit. If you have any questions or comments about our report, please contact me at 415-5915 or Eric Rivera, Team Leader, Financial and Administrative Audit Team, at 415-7032.

Attachment: As stated cc: R. Mitchell, OEDO K. Brock, OEDO J. Arildsen, OEDO C. Jaegers, OEDO Audit of NRC’s Full-Time Telework Program

EXECUTIVE SUMMARY

BACKGROUND

The Telework Enhancement Act of 2010 The Telework Enhancement Act of 2010 (the Telework Act), 1 was enacted into law with the goal of ensuring that Federal agencies more effectively integrate telework into their management plans and agency cultures. The Telework Act defines telework as a work-flexibility arrangement under which an employee performs the duties and responsibilities of his or her position from an approved worksite other than the location from which the employee would otherwise work. A full-time teleworker is an employee who works 90 percent 2 or more of the time from an alternate worksite, generally their personal residence.

The Telework Act requires the head of each executive agency to ensure that employees eligible to telework and managers o

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OBJECTIVES The audit objectives were to determine (1) if NRC’s full-time telework program complies with applicable laws and regulations, and (2) the adequacy of internal controls over the program.

RESULTS IN BRIEF

While NRC’s full-time telework program provides a benefit to the agency and its employees, the Office of the Inspector General (OIG) identified an area of non-compliance with the Telework Act and an internal control

weakness. Specifically:

–  –  –

OIG’s findings and recommendations aim to improve the agency’s compliance and internal controls over the full-time telework program.

RECOMMENDATIONS

This report makes recommendations to improve the compliance and internal controls over the full-time telework program. A list of these recommendations appears on page 14 of this report.

AGENCY COMMENTS

OIG met with NRC management officials and staff at a November 22, 2013, exit conference, at which time the agency provided informal comments to the draft report. The informal comments were incorporated into the report as appropriate. Agency management stated their agreement with the findings and recommendations and opted not to provide formal comments for inclusion in this final report.

–  –  –

TABLE OF CONTENTS

EXECUTIVE SUMMARY

ABBREVIATIONS AND ACRONYMS

I. BACKGROUND

II. OBJECTIVES

III. FINDINGS

–  –  –

B. RECORDKEEPING INTERNAL CONTROLS

NEED IMPROVEMENT

IV. CONSOLIDATED LIST OF RECOMMENDATIONS

V. AGENCY COMMENTS

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Full-time teleworkers are required to change their official worksite to the telework location. The Office of Personnel Management Guide to Telework in the Federal Government recommends that agencies provide a self-certification safety checklist to telework employees as a guide when preparing the alternate worksite for telework.

The Telework Act establishes requirements for agencies when implementing their telework policies. The head of each executive agency needs to establish and implement a policy under which employees shall be authorized to telework. Also, employees must enter into written agreements with their agencies before participating in telework.

Moreover, the head of each executive agency must ensure that employees eligible to telework and managers of teleworking employees receive training on telework before the employee enters into a written telework agreement. However, an employee may be exempted from the training requirement by the agency head.





With regard to program implementation, each agency’s policies should identify whether full-time telework arrangements are allowable in the agency and, if so, what aspects of the employment arrangement could potentially change if an employee teleworks full-time (e.g., consequences to locality pay, benefits, and travel).

Program Responsibilities

The Work Life and Benefits Branch within the Nuclear Regulatory Commission’s (NRC) Office of the Chief Human Capital Officer (OCHCO) develops, coordinates, and implements work-life and benefits policies, including full-time telework, and is responsible for some of the following related activities: (1) retaining a record of all agency full-time teleworkers;

(2) disseminating full-time telework information to office directors, regional administrators, and staff; (3) providing day-to-day guidance for employees about full-time telework policies; (4) reviewing draft full-time telework documents and providing guidance and edits to staff prior to formal concurrence; and (5) coordinating with other offices to obtain concurrence on full-time telework agreements.

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Recommendations:

OIG recommends that the Executive Director for Operations:

1. Develop and implement a mandatory policy for full-time telework training in accordance with requirements in the Telework Enhancement Act of 2010.

2. Require telework training for full-time teleworkers and their managers, including those who had telework agreements prior to the enactment of the Telework Enhancement Act of 2010, or obtain an exemption from the head of the agency.

3. Develop procedures to track telework training on a continual basis.

–  –  –

and regional administrators to request the names and locations of all fulltime teleworkers in their respective offices. This exercise resulted in disclosing that one full-time telework agreement was missing. Neither the full-time teleworker, nor his supervisor, nor OCHCO could produce a copy of the approved telework agreement.

In addition, OIG identified two other files without a formal full-time telework agreement. These two files contained only a memorandum with the subject, “Request for Flexiplace Exception.” These documents do not represent a complete full-time telework agreement because they are missing essential elements such as a description of the work to be performed and drug testing requirements.

Missing Chief Human Capital Officer Approval

Many full-time teleworker agreements are missing proper approvals. Of the 44 telework agreements reviewed, 57 percent did not contain approval from the Chief Human Capital Officer or a designee. One full-time teleworker did not have a written agreement and, therefore, did not have any approvals.

Full-time Telework Agreements Not Current Some full-time telework agreements were out-of-date and did not contain current information. For example, OIG site visits to 14 full-time

teleworkers revealed:

Three instances where a supervisor change was not reflected in the • current full-time telework agreement.

Two instances where job responsibility and duty changes were not • reflected in the current full-time telework agreement.

One instance where a job title change was not reflected in the • current full-time telework agreement.

Two instances where an address change was not reflected in the • current full-time telework agreement.

–  –  –

Missing One or More Required Items OIG’s review of agency full-time telework records revealed that approximately 23 percent of the full-time teleworker files are missing one or more required forms or approvals. OIG also identified one full-time teleworker who did not have any of the required documentation.

Limited Access to OCHCO’s Telework Data Collection SharePoint Site

The agency developed a SharePoint Site to aid in managing its telework programs. Agency full-time teleworkers and their managers do not have access to OCHCO’s Telework Data Collection SharePoint Site. The agency telework coordinator and backup and an OCHCO information technology representative are the only individuals with access to the SharePoint full-time telework files. Consequently, if a manager wants to review a copy of the telework agreement, the current process is to contact the agency telework coordinator and request a copy.

Procedures Inadequate and Electronic Files Not Fully Implemented

OCHCO does not have adequate desk procedures detailing (1) the specific documentation that should be included in the telework file, (2) storage (hardcopy or SharePoint), and (3) how to create, maintain, or monitor SharePoint files. OCHCO provided a copy of its desk procedures to OIG, but the procedures did not include sufficient information regarding full-time telework file recordkeeping.

Additionally, the agency has not completed the implementation of an electronic filing system for full-time telework files using SharePoint.

Currently, not all full-time teleworker information and documentation is in this electronic system. For example, some full-time teleworkers’ names do not appear in SharePoint, while others have information such as their name and approval date, but no attached approved telework agreement and relevant documentation. OCHCO officials stated that they are in the process of completing the transition from hard copy documentation to electronic records in SharePoint. Furthermore, OCHCO is working to provide appropriate SharePoint access to designated individuals within program offices. OIG agrees that these efforts when completed will greatly benefit the full-time telework program.

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Increased Potential for Fraud, Waste, and Abuse The lack of adequately documented full-time telework agreements increases the potential for staff to work outside of their authority, thereby potentially leading to fraud, waste, and abuse. Recordkeeping is a fundamental internal control for ensuring that only authorized individuals are approved to engage in full-time telework. By enhancing NRC’s recordkeeping process, NRC will have more effective internal controls over the full-time telework program.

Recommendations:

OIG recommends that the Executive Director for Operations:

4. Develop and implement desk procedures for proper recordkeeping of full-time telework agreements and related documentation.

5. Complete the transition from hard copy to electronic files for full-time teleworkers. These files should include (i) a complete list of current full-time teleworkers and (ii) electronic records of all full-time telework agreements and related documentation.

6. Develop and implement a process to update the OCHCO Telework Data Collection SharePoint Site including, but not limited to, creating, maintaining, reviewing, and updating files.

7. Provide OCHCO Telework Data Collection SharePoint Site access to full-time teleworkers and their managers as appropriate.

–  –  –

IV. CONSOLIDATED LIST OF RECOMMENDATIONS

OIG recommends that the Executive Director for Operations:

1. Develop and implement a mandatory policy for full-time telework training in accordance with requirements in the Telework Enhancement Act of 2010.

2. Require telework training for full-time teleworkers and their managers, including those who had telework agreements prior to the enactment of the Telework Enhancement Act of 2010, or obtain an exemption from the head of the agency.

3. Develop procedures to track telework training on a continual basis.

4. Develop and implement desk procedures for proper recordkeeping of fulltime telework agreements and related documentation.

5. Complete the transition from hard copy to electronic files for full-time teleworkers. These files should include (i) a complete list of current fulltime teleworkers and (ii) electronic records of all full-time telework agreements and related documentation.

6. Develop and implement a process to update the OCHCO Telework Data Collection SharePoint Site including, but not limited to, creating, maintaining, reviewing, and updating files.

7. Provide OCHCO Telework Data Collection SharePoint Site access to fulltime teleworkers and their managers as appropriate.

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