![](media/image1.wmf){width="8.28125in" height="1.5in"}

**INSPECTION MEMORANDUM**

**To:** Michell Clark

Acting Assistant Secretary for Management

and Chief Information Officer

**From:** Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection, and Management Services

**Subject:** Review of the Department's Voluntary Leave Transfer Program

(ED/OIG I13F0003)

This memorandum provides the results of our inspection of the Department
of Education's (Department's) Voluntary Leave Transfer Program. Our
inspection objective was to determine whether the Voluntary Leave
Transfer Program was being conducted in compliance with the Department's
Personnel Manual Instruction (PMI) 630-10, *Voluntary Leave Transfer
Program -- Administrative Procedures.*

The Federal Employees Leave Sharing Act of 1988[^1] and resulting Office
of Personnel Management (OPM) regulations[^2] directed federal agencies
to establish a program under which one employee's accrued annual leave
could be transferred to another employee in the event of a medical
emergency.[^3] The Department's program is operated under the auspices
of the Work/Life Programs Group (WLPG) in the Office of Management (OM).
In 2004, 3,727 hours of annual leave were donated through the program.
The participation rates of principal offices and regions correspond
closely in proportion to their number of employees (see Appendix A and
B).

**Inspection Objective: Determine whether the Voluntary Leave Transfer
Program is being implemented in compliance with the Department's
Personnel Manual Instruction (PMI) 630-10.**

In reviewing the Department's implementation of the Voluntary Leave
Transfer Program, we found that OM is conducting the program consistent
with the requirements of the PMI except in two areas: (1) OM does not
require the Department of the Interior (DOI), Bureau of Reclamation,
Payroll Operations Division to send notification of the initial amount
of available donated leave, as required by the PMI, and (2) there is a
minor deviation in the Leave Donation Form that OM uses from the form
included in the PMI.

Guidance for the leave transfer program is provided in PMI 630-10.[^4]
The PMI establishes procedures for participation in the program,
including eligibility requirements, how transferred annual leave may be
used, how to apply to become a leave recipient, the Department's
approval process for participation in the program, how to solicit leave
donations, how to make a donation, how the time period covered by the
medical emergency will be determined, the process for restoring unused
transferred annual leave, and the roles and responsibilities of the
Work/Life Programs Group.

Generally, to enroll, prospective leave recipients complete an
application that is available on the Department's connectED intranet
site. With the agreement of the applicant's supervisor, the application
and appropriate medical documentation are sent to WLPG for approval.
Once approved, WLPG sends confirmation to the applicant, his or her
supervisor, executive office, and timekeeper, along with a copy of PMI
630-10. The timekeeper is also provided with instructions on how to code
leave on a recipient's timecard. The executive office then creates a
solicitation for leave donations that is included in the ED Notebook and
connectED. Leave donations are anonymous and are submitted to WLPG. Both
Department employees and employees in other agencies can donate leave.
Approved recipients can use transferred leave on a current basis, can
retroactively substitute it for leave without pay, or can use it to
liquidate advanced annual or sick leave.[^5] Once WLPG receives the
leave donation forms, the program coordinator enters the information
into the SF-52 system, which tracks payroll and leave availability. The
payroll office at DOI's Bureau of Reclamation applies this available
donated leave to a recipient's account based on timecard information
provided by the timekeeper. WLPG monitors the status of the medical
emergency through the leave recipient's immediate supervisor.[^6] When
the immediate supervisor determines that the medical emergency has
ended, DOI restores the remaining transferred annual leave to the
accounts of the leave donors. The number of hours restored is determined
on a pro-rated basis among all employees donating to a particular
recipient.

Based upon interviews with OM staff, leave recipients, and executive
office personnel responsible for administering the program, along with a
review of PMI 630-10 and documentation received from WLPG, we determined
that OM is operating the program in a manner that is consistent with the
requirements of the PMI, with the two exceptions discussed below.

***Recipient Notification***

Attachment C to the PMI includes a copy of a form entitled "Shared Leave
Recipient Notification Memorandum." The PMI states that this memorandum
is to be sent by the DOI, Bureau of Reclamation, Payroll Operations
Division, which provides payroll services to the Department. "Upon
receipt of donated leave, the Department of the Interior (DOI), Bureau
of Reclamation will transmit a notification letter," the Shared Leave
Recipient Notification, to the "timekeeper, the employee, and the Agency
Program Coordinator (WLPG) of the initial donated amount available."[^7]
At the time of our inspection, this memorandum was not being sent by
DOI. A supervisor at the DOI payroll office indicated that DOI enters
leave information that it receives from the Department into the SF-52
system, but it does not send the referenced notification form.

The WLPG program coordinator acknowledged that DOI was not sending the
Shared Leave Recipient Notification. According to the program
coordinator, when the PMI was written in 1989, the Department did not
have an automated system for tracking leave. Since that has been in
place, the Department has not asked DOI to send the form because the
program coordinator now has access to DOI's SF-52 system.[^8] With
access to this system, the program coordinator can view the leave
amounts available for any recipient within the Department.

The DOI notification form was intended to share donated leave
information with the timekeeper and the employee, as well as the agency
program coordinator. An accurate accounting for the leave initially
credited to the employee is important, and without notification or
access to the SF-52 system, leave recipients and timekeepers may have
difficulty in tracking available leave. While WLPG has suggested that
leave recipients can call the program coordinator or rely upon their
Earnings and Leave statement, leave recipients in eight out of 14
principal offices, expressed confusion in tracking the amount of leave
credited to their accounts.[^9]

OM needs to identify in the PMI its method for notifying recipients and
timekeepers of their available leave balance. OM may also want to
consider providing leave balance notification to the recipient's
immediate supervisor.

***Leave Donation Form***

The Leave Donation Form provided on the program's connectED site is
slightly inconsistent with the form provided in Attachment B of the PMI.
The form on the website was revised to make the donation process clearer
for prospective donors; however, OM has not modified the PMI to reflect
this change.

# Recommendations

1\. Section 630-10 of the PMI should be modified to reflect how OM will
provide information on the available leave balance to recipients and
their timekeepers.

2\. The PMI should be modified to include the updated Leave Donation
Form.

# Other Matters

Based upon our inspection activities, we would also like to bring to the
attention of OM the following observations:

-   When asked how they were informed of their responsibilities under
    the leave transfer program, executive office personnel in 14
    principal offices indicated that they primarily did their own
    research. Their research included consulting the PMI and accessing
    other information available on connectED. While WLPG staff indicated
    that the program is highlighted in a quarterly new supervisor
    orientation, OM may want to consider offering the training to all
    executive office personnel responsible for administering the
    program.

-   In addition to confusion among leave recipients in the tracking of
    leave, executive office personnel in six out of 18 principal
    offices[^10] also expressed difficulty in accounting for leave. OM
    may want to consider providing informational materials to leave
    recipients, supervisors, and executive office personnel regarding
    the tracking of leave.

```{=html}
<!-- -->
```
-   During the interviews that we conducted with leave recipients and
    executive office personnel, an issue was raised about insufficient
    leave donations, particularly in smaller principal offices.
    Recipients who knew fewer people or were new to the Department
    indicated that they had greater difficulty in receiving donated
    leave. One possible means to address this problem would be to
    establish a leave bank. The Department of Justice currently uses a
    leave bank, in conjunction with a leave transfer program, to help
    provide additional leave options for employees in medical
    emergencies.

# Scope and Methodology

This inspection was initially conducted between January and February
2005. Due to staffing changes, additional fieldwork was postponed until
June and July 2005. To conduct our fieldwork, we interviewed executive
office staff responsible for administering the program in each of the 19
principal offices in the Department. We also interviewed 17 voluntary
leave recipients. We attempted to interview at least one recipient in
each principal office; however, we were unable to contact individuals in
five of the offices that had recipients on their staff.

Additionally, we interviewed staff in the Office of Management's
Work/Life Programs Group, which is responsible for administering the
program in the Department. We obtained a listing of 2003-04 leave
recipients from the WLPG. In addition, we reviewed a sample of WLPG's
recipient documentation.

We reviewed the Federal Employees Leave Sharing Act (5 U.S.C. § 6332),
OPM regulations 5 C.F.R. § 630.903, and the Department's PMI 630-10.

This inspection was performed in accordance with the President's Council
on Integrity and Efficiency (PCIE) Quality Standards for Inspectors
(2005).

#### **Department Response**

We provided OM with a draft report. OM's comments and our responses are
presented below. The complete OM response is included as an addendum to
this report.

1.  **Section 630-10 of the PMI should be modified to reflect how OM
    will provide information on the available leave balance to
    recipients and their timekeepers.**

> **OM Comments:** Section 630-10 of the PMI will be updated to reflect
> the current procedures for providing information on the available
> leave balance to recipients and their timekeepers. A copy of the
> updated PMI will be placed in the inspection corrective action file as
> documentation supporting the completion of this corrective action.
>
> **OIG Response:** No change has been made to the recommendation.

2.  **The PMI should be modified to include the updated Leave Donation
    Form.**

> **OM Comments:** The PMI will be updated to include the current Leave
> Donation Form. A copy of the updated PMI will be placed in the
> inspection corrective action file as documentation supporting the
> completion of this corrective action.
>
> **OIG Response:** No change has been made to the recommendation.

**Voluntary Leave Transfer Program Participation, 2003-04**

*Six out of the 100 recipients participated in the program twice.*

Appendix A. Participation by Principal Office

+------------------+----------+------+----------+------+--------+---+
| **Principal**    | **Number |      | **Pct.   |      | **Pct. |   |
|                  | of       |      | of       |      | of**   |   |
| **Office**       | Partic   |      | Partic   |      |        |   |
|                  | ipants** |      | ipants** |      | **ED   |   |
|                  |          |      |          |      | Sta    |   |
|                  |          |      |          |      | ff\*** |   |
+------------------+----------+------+----------+------+--------+---+
| OS               | 1        |      | 1%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| ODS/OUS          | 3        |      | 3%       |      | 3%     |   |
+------------------+----------+------+----------+------+--------+---+
| OCFO             | 5        |      | 5%       |      | 7%     |   |
+------------------+----------+------+----------+------+--------+---+
| OCIO             | 4        |      | 4%       |      | 25%    |   |
+------------------+----------+------+----------+------+--------+---+
| OCR              | 16       |      | 15%      |      | 15%    |   |
+------------------+----------+------+----------+------+--------+---+
| OESE             | 8        |      | 8%       |      | 4%     |   |
+------------------+----------+------+----------+------+--------+---+
| OELA             | 1        |      | 1%       |      | 1%     |   |
+------------------+----------+------+----------+------+--------+---+
| OGC              | 1        |      | 1%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| OII              | 1        |      | 1%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| OIG              | 6        |      | 6%       |      | 7%     |   |
+------------------+----------+------+----------+------+--------+---+
| IES              | 8        |      | 8%       |      | 4%     |   |
+------------------+----------+------+----------+------+--------+---+
| OIIA             | 6        |      | 6%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| OLCA             | 1        |      | 1%       |      | 0%     |   |
+------------------+----------+------+----------+------+--------+---+
| OM               | 7        |      | 7%       |      | 4%     |   |
+------------------+----------+------+----------+------+--------+---+
| OPE              | 4        |      | 4%       |      | 5%     |   |
+------------------+----------+------+----------+------+--------+---+
| OSDFS            | 1        |      | 1%       |      | 4%     |   |
+------------------+----------+------+----------+------+--------+---+
| OSERS            | 9        |      | 8%       |      | 1%     |   |
+------------------+----------+------+----------+------+--------+---+
| OVAE             | 1        |      | 1%       |      | 3%     |   |
+------------------+----------+------+----------+------+--------+---+
| FSA              | 23       |      | 22%      |      | 25%    |   |
+------------------+----------+------+----------+------+--------+---+
| **Total**        | **106**  |      |          |      |        |   |
+------------------+----------+------+----------+------+--------+---+

\* Percentage of Full Time Permanent (FTP) staff, December 2004

Appendix B. Participation by Region

+------------------+----------+------+----------+------+--------+---+
| **Region**       | **Number |      | **Pct.   |      | **Pct. |   |
|                  | of       |      | of       |      | of**   |   |
|                  | Partic   |      | Partic   |      |        |   |
|                  | ipants** |      | ipants** |      | **ED   |   |
|                  |          |      |          |      | Sta    |   |
|                  |          |      |          |      | ff\*** |   |
+------------------+----------+------+----------+------+--------+---+
| Headquarters     | 80       |      | 75%      |      | 72%    |   |
+------------------+----------+------+----------+------+--------+---+
| Region I         | 0        |      | 0%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region II        | 2        |      | 2%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region III       | 5        |      | 5%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region IV        | 3        |      | 3%       |      | 5%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region V         | 5        |      | 5%       |      | 5%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region VI        | 3        |      | 3%       |      | 3%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region VII       | 3        |      | 3%       |      | 2%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region VIII      | 0        |      | 0%       |      | 1%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region IX        | 5        |      | 5%       |      | 4%     |   |
+------------------+----------+------+----------+------+--------+---+
| Region X         | 0        |      | 0%       |      | 1%     |   |
+------------------+----------+------+----------+------+--------+---+
| **Total**        | **106**  |      |          |      |        |   |
+------------------+----------+------+----------+------+--------+---+

\* Percentage of Full Time Permanent (FTP) staff, December 2004

![](media/image2.jpeg){width="7.816666666666666in"
height="10.294444444444444in"}

[^1]: P.L. 100-566, 5 U.S.C. § 6332

[^2]: 5 C.F.R § 630.903, *et seq.*

[^3]: Under the PMI, a "medical emergency" is defined as any medical
    condition of an employee or a family member "that is likely to
    require an employee's absence from duty for a prolonged period of
    time and to result in a substantial loss of income to the employee
    because of the unavailability of paid leave." PMI 630-10, Section IV
    D.

[^4]: Issued 10/2/89 and amended 9/2/94, 2/12/99, and 7/12/00.

[^5]: PMI 630-10, Section VI.

[^6]: PMI 630-10, Section XII.

[^7]: PMI 630-10, Section VII A.4.

[^8]: OM has amended the PMI three times since 1989 (in 1994, 1999, and
    2000). This section was not modified as part those revisions.

[^9]: We were unable to interview recipients in five principal offices.

[^10]: The Office of Management (OM) and the Office of the Chief
    Information Officer (OCIO) share the same executive office.