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

FROM: Stephen D. Dingbaum /RA/

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

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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 percent2 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 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.

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. Annual full-time equivalent usage associated 

with the administration of the agency's full-time telework program for fiscal 

years 2013-2014 is less than one full-time equivalent (.26) per year. As of 

May 9, 2013, NRC had 3,832 total staff with 45 employees engaged in 

full-time telework. 

 1 Enacted as Public Law 111-292; signed into law on December 9, 2010. 2 Based on an 80-hour biweekly pay period.
Audit of NRC’s Full-Time Telework Program

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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:

• The agency is not fully compliant with training requirements.

• Recordkeeping internal controls need improvement.

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.
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ABBREVIATIONS AND ACRONYMS

GAO Government Accountability Office

NRC Nuclear Regulatory Commission

OCHCO Office of the Chief Human Capital Officer

OIG Office of the Inspector General

OPM Office of Personnel Management
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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................ i

ABBREVIATIONS AND ACRONYMS........................................................iii

I. BACKGROUND .............................................................................. 1

II. OBJECTIVES.................................................................................. 4

III. FINDINGS....................................................................................... 5

A. AGENCY IS NOT FULLY COMPLIANT WITH 

TRAINING REQUIREMENTS.................................................... 5

B. RECORDKEEPING INTERNAL CONTROLS 

NEED IMPROVEMENT ............................................................ 9

IV. CONSOLIDATED LIST OF RECOMMENDATIONS ..................... 14

V. AGENCY COMMENTS................................................................. 15

APPENDIX

OBJECTIVES, SCOPE, AND METHODOLOGY........................... 16
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I. BACKGROUND 

The Telework Enhancement Act of 2010

The Telework Enhancement Act of 2010 (the Telework Act),3 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 percent4 or more of the time from an alternate worksite, 

generally their personal residence. 

Figure 1: NRC Full-Time Teleworkers’ Residential Work Sites

 Source: OIG photographs taken during site visits.

 3 Enacted as Public Law 111-292; signed into law on December 9, 2010. 4 Based on an 80-hour biweekly pay period.
Audit of NRC’s Full-Time Telework Program

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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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Also, there is an agency telework coordinator in OCHCO who (1) serves 

as agency liaison with the Office of Personnel Management and other 

Federal agencies on the full-time telework program, (2) administers the 

program through the NRC office/regional telework coordinators, 

(3) advises management and participants about the full-time telework 

program, (4) monitors the overall progress of the full-time telework

program, and (5) develops and updates training for the full-time telework 

program.

Annual full-time equivalent usage associated with the administration of the 

agency's full-time telework program for fiscal years 2013-2014 is less than 

one full-time equivalent (.26) per year. As of May 9, 2013, NRC had 3,832 

total staff with 45 employees engaged in full-time telework. There were 41 

managers who supervised the full-time teleworkers.

5

 The full-time 

teleworker locations are shown in Figure 2.

 5 There are four managers who each supervise two full-time teleworkers.
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Figure 2: NRC Full-Time Teleworker Locations6

Source: OIG generated.

II. 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. The report appendix 

contains information on the audit scope and methodology.

 6 NRC also has one full-time teleworker in Oxford, England, and another full-time teleworker in San Juan, 

Puerto Rico.
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III. FINDINGS

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:

• The agency is not fully compliant with training requirements.

• Recordkeeping internal controls need improvement.

OIG’s findings and recommendations aim to improve the agency’s

compliance and internal controls over the full-time telework program.

A. Agency Is Not Fully Compliant With Training Requirements

According to the Telework Act, teleworking employees and their managers 

must be trained before telework begins unless there is an exemption from 

the head of the agency. However, NRC is not in full compliance with 

training requirements in the Telework Act because (1) full-time teleworkers 

and their managers were not required by the agency to complete 

mandatory training, (2) the head of the agency did not issue training 

exemptions, and (3) the agency does not have adequate policy and 

procedures related to telework training. As a result, staff may not fully

understand the telework program and, subsequently, there may be an 

increased potential for fraud, waste, and abuse. 

Training Requirements Under the Telework Act

According to the Telework Act,

7 the head of each executive agency shall 

ensure that a telework training program is provided to (1) employees 

eligible to participate in the agency’s telework program and (2) all 

managers of teleworkers. In addition, the Telework Act8 provides that the 

head of each executive agency shall ensure that an eligible employee has 

successfully completed the telework training before that employee enters 

 7 § 6503(a)(1)(A)(B). 8 § 6503(a)(2).
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into a written telework agreement. Finally, an employee may be exempted 

from the training requirement upon the agency head’s determination that 

training is unnecessary because the employee is already teleworking 

under an arrangement in effect before the date of enactment of the 

Telework Act.9 

Agency Not Fully Compliant With Training Requirements 

The agency did not fully comply with the training requirements of the 

Telework Act. OIG obtained a list from NRC’s iLearn Learning 

Management System of all employees who completed telework training, 

and compared it to the list of full-time teleworkers as of May 9, 2013. 

OIG’s analysis (illustrated in the following table) determined that a 

significant majority of full-time teleworkers and managers of full-time 

teleworkers had not completed the required training.

OIG Analysis of Completed Telework Training

Training

Completed

Training Not

Completed Total

Percentage

Not Trained

Full-Time Teleworkers 12 33 45 73%

Managers of Full-Time Teleworkers 8 33 41 80%

Source: OIG analysis of agency training data.

In addition, 10 of 15 employees who had a full-time telework agreement in 

effect before the enactment of the Telework Act,10 and 10 of 15 managers 

of these full-time teleworkers,11 did not take the required training and did 

not obtain an exemption from the head of the agency. 

 9 § 6503(a)(4)(b). 10 The Telework Enhancement Act of 2010 was enacted on December 9, 2010.

11 Managers on record in the agency’s full-time telework files OIG reviewed.
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Lack of Agency Action To Comply With Training Requirements

NRC is not fully compliant because (1) full-time teleworkers and their 

managers were not required by the agency to complete mandatory 

training, (2) NRC did not request a training exemption from the head of the 

agency, and (3) the agency does not have adequate procedures to track 

telework training. 

NRC did not require telework training for full-time teleworkers and their 

managers as is specified by the Telework Act. Rather, agency guidance12

only states “it is strongly recommended” that the employee and supervisor 

take telework training. The agency does not have any other guidance on 

telework training. OCHCO officials confirmed that currently NRC does not 

require telework training, but assured OIG that in the future it will be made 

mandatory for all full-time teleworkers and their managers. 

NRC did not request a training exemption from the head of the agency for 

those full-time teleworkers and their managers who had an agreement in 

place prior to the enactment of the Telework Act. OCHCO did not provide 

an explanation of why they did not seek an exemption, but agreed to 

(1) train all full-time teleworkers and their managers or (2) obtain an 

exemption from the head of the agency. 

Furthermore, the agency does not have adequate procedures to track 

telework training. Telework training completion is tracked in the agency’s 

iLearn Learning Management System and OCHCO’s Telework Data 

Collection SharePoint Site. However, OCHCO is not effectively using 

these tools to routinely track telework training completions.

Staff May Not Fully Understand the Program 

Because NRC is not fully compliant with training requirements, staff may 

not fully understand their responsibilities or the benefits of the full-time 

telework program. The telework training provides information related to 

the full-time teleworkers’ and managers’ responsibilities and limitations. 

Without a proper understanding of the program, there may be an 

increased potential for fraud, waste, and abuse.

 12 OCHCO telework brochure titled The Telework Program – Be There From Anywhere.
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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.
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B. Recordkeeping Internal Controls Need Improvement

NRC’s full-time telework records are inconsistent and not maintained in 

accordance with Federal Government standards or existing agency 

policies and procedures. Federal Government standards state that 

agencies should create and maintain records that provide evidence of 

execution of activities and those records should be readily available for 

examination. In addition, the agency has guidelines for developing a fulltime telework package. However, full-time telework records are 

inconsistent because agency desk procedures are inadequate and the 

electronic filing system is not fully implemented. As a result, there is 

increased potential for fraud, waste, and abuse regarding improper 

execution of full-time telework agreements.

Federal Government Standards and Agency Policy

The Government Accountability Office (GAO) Standards for Internal 

Control in the Federal Government13 states that agencies should create 

and maintain records that provide evidence of execution of activities. It 

also states these records should be readily available for examination.

OCHCO developed a template to inform managers and potential full-time 

teleworkers of the information needed to have a full-time telework 

agreement approved. Along with the telework agreement, potential fulltime teleworkers are required to submit to OCHCO the following forms:

• NRC Form 621, Employee Request to Participate in the Telework 

Program.

• NRC Form 622, Evaluation of Employee Request to Participate in 

the Telework Program.

• NRC Form 624, U.S. Nuclear Regulatory Commission Telework

Program Participation Agreement.

• NRC Form 625, Telework Program Employee Self-Certification 

Safety Checklist.

 13 GAO/AIMD-00-21.3.1, November 1999.
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Also, a potential full-time teleworker must obtain approval from the Office 

of Information Services regarding computer security, the Computer

Security Office regarding information security, and the Office of 

Administration regarding drug testing.

NRC’s Collective Bargaining Agreement, Article 7, Telework, provides that 

any fixed schedule telework proposal for more than 3 days per week 

requires approval from the Chief Human Capital Officer.

14

OCHCO officials stated that full-time telework records are maintained by 

the agency telework coordinator. Currently, the agency is in the process 

of transitioning from hard copy to electronic files using OCHCO’s Telework 

Data Collection SharePoint Site.

NRC Records Are Inconsistent and Do Not Meet Standards

NRC’s full-time telework records are inconsistent and not maintained in 

accordance with Federal standards and existing agency policies. 

Specifically, there are:

• Missing full-time telework agreements. 

• Full-time telework agreements missing approval from the Chief 

Human Capital Officer.

• Full-time telework agreements that are not current.

• Full-time telework files missing one or more required items. 

Moreover, agency full-time teleworkers and their managers do not have

access to OCHCO’s Telework Data Collection SharePoint Site.

Missing Full-Time Telework Agreements

There are full-time telework agreements missing from the agency’s official 

records. OIG reviewed 44 full-time teleworker files15 obtained from 

OCHCO official records. OIG also contacted all agency office directors 

 14 Previously, the Director, Office of Human Resources.

15 As of May 9, 2013.
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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.
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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. 
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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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V. 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.
Audit of NRC’s Full-Time Telework Program

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APPENDIX

OBJECTIVES, SCOPE, AND METHODOLOGY

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.

SCOPE

This audit focused on reviewing internal controls over the agency’s fulltime telework program. Specifically, OIG focused on compliance with 

training requirements and recordkeeping internal controls associated with 

the agency’s 45 full-time teleworkers as of May 9, 2013. We conducted 

this performance audit at NRC headquarters in Rockville, MD, and 14

telework sites across the United States, from April 2013 through 

September 2013. Internal controls related to the audit objectives were 

reviewed and analyzed. Throughout the audit, auditors were aware of the 

possibility or existence of fraud, waste, or misuse in the program under 

review.

METHODOLOGY

To accomplish the audit objectives, OIG reviewed relevant laws, 

regulations, and guidance, including the Telework Enhancement Act of 

2010, the Office of Personnel Management’s (OPM) Guide to Telework in 

the Federal Government, NRC’s input into OPM’s 2012 Call for Telework 

Data, OPM’s Web site: telework.gov, and an OIG staff member’s test 

completion of OPM’s On-line Telework Training for Employees and 

Managers. We also reviewed Office of Management and Budget Circular 

A-123, Management's Responsibility for Internal Control; the Government 

Accountability Office Standards for Internal Control in the Federal 

Government; Article 7, Telework, in the Collective Bargaining Agreement 

between NRC and the National Treasury Employees Union; and a prior 

OIG report titled Audit of NRC's Telework Program, issued June 2010, for 

relevance to this audit.

OIG also reviewed agency guidance and documents, including NRC 

Operating Procedure for Telework, effective February 11, 2013; NRC’s 

Telework Program Brochure, Be There From Anywhere, October 2009;
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an undated and unsigned document titled Considerations in Approving 

Full-time Telework, which includes current authority for approving telework 

for more than 3 days per week; NRC’s Drug Free Workplace Plan, dated 

August 2007; and required forms to become a full-time teleworker at NRC.

OIG interviewed NRC staff at headquarters to obtain insights on the 

agency’s full-time telework program. In addition, OIG made site visits to 

Maryland, Idaho, Georgia, North Carolina, and California to interview 14 of 

the agency’s 45 full-time teleworkers. OIG also interviewed 5 of the 

managers responsible for the 14 full-time teleworkers. The purpose of the 

site visits was to assess the teleworkers’ compliance with applicable laws

and regulations, determine challenges and whether the 14 full-time 

teleworkers still maintain office space at the agency, and to personally 

observe their work area. Finally, OIG interviewed staff at three Federal 

agencies to review best practices. 

We conducted this performance audit 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.

The audit work was conducted by Eric Rivera, Team Leader; Terri Cooper, 

Audit Manager; Michael Steinberg, Senior Auditor; Larry Weglicki, Senior 

Auditor; and George Gusack, Student Intern.