Audit of NRC's Use of the NEWFlex Program

1) Intranet Information Is Inaccurate and Outdated

OIG reviewed NEWFlex information on NRC’s intranet site and determined that
some of the information is inaccurate and outdated. For example, during the 2009
implementation of NEWFlex, NRC procedures required employees to submit a
paper NRC Form 707 to document their work schedules. NRC subsequently
upgraded the NRC Human Resources Management System, and as of October
2011, employees now document their work schedules electronically. While officials
in the Office of the Chief Human Capital Officer pointed to the intranet site as a
resource for NEWFlex information, the site did not reflect the current work schedule
documentation requirement.

The NEWFlex intranet site also provided office and regional contact information for
employees. However, of 42 individuals listed as points of contact, 7 were no longer
NRC employees and 8 others were in different offices. Subsequent to OIG’s
review, Office of the Chief Human Capital Officer staff stated they had changed and
updated the contact information.

(2) NEWFlex Training Is Inadequate

OIG interviewed 25 employees regarding training and understanding of NEWFlex
features. Table 2 shows that not all supervisors and staff interviewed have
received training. For example, 11 of 25 respondents either did not receive or do
not recall receiving formal training related to NEWFlex and 6 of 25 respondents
stated that they lack a good understanding of some NEWFlex features.

Table 2: Employee Interview Results

Received Training on NEWFlex?

Yes Self-taught Unsure No
Supervisors (n = 8) 5 2 oO 1
Staff (n = 17) 9 1 z 4

Understanding of NEWFlex Features?
All Features Some Features

Supervisors (n = 8) g 1

Staff (n = 17) 12 5

What schedule do you work?

Compressed
Work NEWFlex Unsure
Schedule

‘Supervisors (n = 8) = 3 0
Staff (n = 17) 2 12 3

Source: OIG interview data.


Audit of NRC's Use of the NEWFlex Program

To assess whether NEWFlex adequately addresses unique situations such as drug
testing, official travel, and other events, OIG interviewed 13 NRC employees to
determine supervisor and staff understanding of NEWFlex features, including
issues related to unique situations. OIG also interviewed 12 employees and
contractors who participate in administrative activities of NEWFlex.

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 finding and conclusions based on our audit objectives. We believe that the
evidence obtained provides a reasonable basis for our finding and conclusion
based on our audit objectives.

The audit work was conducted by Eric Rivera, Team Leader; Mary Meier, Audit

Manager; Gail F.P. Butler, Senior Auditor; Larry Vaught, Senior Auditor; and
George Gusack, Student Analyst.

10


Audit of NRC's Use of the NEWFlex Program

The Federal Employee Viewpoint Survey (formerly known as Federal Human
Capital Survey) is a Governmentwide survey administered by the Office of
Personnel Management in compliance with the Chief Human Capital Officers Act of
2002. According to the Office of Personnel Management, this survey is a tool “to
measure employees’ perceptions of whether, and to what extent, conditions
characterizing successful organizations are present in their agencies.” However,
this survey does not contain any questions specific to NEWFlex. As shown in Table
4, the survey addresses “Alternative Work Schedules” in general.

Table 4: Excerpt from NRC Federal Employee Viewpoint Survey

Results for 2012
NUCLEAR REGULATORY COMMISSION
2012 FEDERAL EMPLOYEE VIEWPOINT SURVEY RESULTS
INot Available
Question 74 Yes No ous Total
[Do you participate in the following
fork/Life programs? Alternative Work] 1641 899 98 2638
‘Schedules (AWS)
Neither Do Not
Question 80 Satcheq | Satisfied] Satisfied or [Dissatisfied]. YE, | KnowiNo |. Tel
Dissatisfied its Basis to Judge | °°?!
How satisfied are you with the following}
Work/Life programs in your agency? | 993 | 544 54 13 6 2 1631
\Alternative Work Schedules (AWS)

Source: Excerpt from 2012 Federal Employee Viewpoint Survey, NRC Agency Results.

Moreover, in 2010, one year after NEWFlex implementation, the Office of the Chief
Human Capital Officer conducted an informal survey of 120 NRC supervisors to
determine if NEWFlex was working. The Chief Human Capital Officer stated that
the results of that survey were positive. However, some supervisors were not
comfortable with managing the flexible work schedules. No other surveys specific
to NEWFlex have been completed since 2010.

Agency Has Not Developed a Process for Updating Information, a Mandatory
Training Program, or Metrics to Monitor NEWFlex

The agency has not created a process to review and revise NEWFlex information,
resulting in outdated program materials available to employees.

In addition, management has not established a mandatory training program for
NEWFlex. NEWFlex training is not provided in the Supervisor Development
Program to help supervisors understand and manage NEWFlex features and to
effectively counsel staff on work schedule options. Moreover, management has not
provided explicit split work schedule procedures for agency employees, resulting in


Audit of NRC's Use of the NEWFlex Program

OIG also examined the training curriculum for new supervisors and found that there
was no mandatory training for managing NEWFlex work schedules or NEWFlex
time and attendance. Further, staff do not have access to an online training course
about NEWFlex. Office of the Chief Human Capital Officer staff stated they
recognized that training in this area could be improved and have spent considerable
effort planning and conducting general work schedule and associated
compensation rules training sessions when requested.

In addition, the online training materials for the NRC Human Resources
Management System do not provide complete instructions for employees on how to
enter split work schedules. There are cases where employee work schedules
entered into the NRC Human Resources Management System do not reflect the
actual split work schedule. OIG identified work schedules where the planned start
and stop times reflected 9%4- to12-hour workdays, but employees normally worked
8-hour days. Three employees interviewed stated that they have a split work
schedule but they did not know how to enter the split work schedules into the NRC
Human Resources Management System.

(3) NEWFlex Performance Measures Lacking

The agency does not have performance indicators specific to NEWFlex to
determine if NEWFlex aids in recruitment, retention, and enhancement of work-life
balance. The Strategic Human Capital Plan for Fiscal Year 2010-2014 states the
strategy for the Office of the Chief Human Capital Officer is to explore and
implement possible work-life flexibilities to create a great place to work. The metric
that defines success is when the Federal Human Capital Survey results report NRC.
as a great place to work. Neither the strategy nor the metric are specific to
NEWFlex (see Table 3).

Table 3: Excerpt from Strategic Human Capital Plan Fiscal Year 2010-2014

NRC Strategic Plan | Human Capital Goals Strategies
s ce. | Office of the Chief Human
Capital Officer will...

Well know we are
successful when...

Improve support services
to make them more
efficient and make it
easier to accomplish
jency goals.
Source: OIG summary of NRC's Strategic Human Capital Plan for Fiscal Year 2010-2014.

An environment rich in
work-life balance
Imaking NRC a great
place to work.



Audit of NRC's Use of the NEWFlex Program

OIG recommends that the Executive Director for Operations:

5. Establish an ongoing program to conduct targeted data collection and
analysis of specific NEWFlex features to monitor NEWFlex program
goals and identify potential problem areas.

AGENCY COMMENTS

An exit conference was held with the agency on November 25, 2013. Agency staff
generally agreed with the report finding and recommendations, and provided
technical comments on a draft version of the report. OIG has incorporated these
comments, as appropriate. NRC management and staff reviewed the revised draft
report and agreed with the finding and recommendations. The agency opted not to
provide formal comments for inclusion in this final report.

SCOPE AND METHODOLOGY

The audit focused on reviewing the internal controls over administration of
NEWFlex during calendar year 2012. We conducted this performance audit at NRC
headquarters in Rockville, MD, from March 2013 to August 2013. Throughout the
audit, we were aware of the possibility or existence of fraud, waste, or misuse in the
program.

To assess NRC’s compliance with applicable Federal laws and regulations, OIG
compared NRC's Management Directive related to work schedules to the
requirements of the Federal Employees Flexible and Compressed Work Schedules
Act of 1982, relevant sections of the Code of Federal Regulations, and Office of
Personnel Management guidance. OIG found NEWFlex to be compliant with
applicable Federal laws and regulations.

OIG also reviewed additional agency guidance, including policies and procedures
pertaining to NEWFlex administration, as well as audit reports of other Federal
agencies related to this topic.

To assess the adequacy of NRC’s controls over employee schedules and time and
attendance policy, we analyzed 313,975 timekeeping records for calendar year
2012, as provided to us by the Office of the Chief Financial Officer on April 30,
2013. OIG tested the control to limit the use of credit hours to employees in a
NEWFlex schedule who are not members of the Senior Executive Service.


UNITED STATES

NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001

OFFICE OF THE
INSPECTOR GENERAL

December 19, 2013

MEMORANDUM TO: Mark A. Satorius
Executive Director for Operations

J. E. Dyer
het Financial “he | P

4

oe CD
FROM: Stephen D. ean
Assistant Inspector Géheral for Audits

SUBJECT: AUDIT OF NRC’S USE OF THE NEWFLEX PROGRAM
(OIG-A-14-08)

The Office of the Inspector General (OIG) audited the administration of the Nuclear
Regulatory Commission’s (NRC) Employee Work Schedule Flexibilities (NEWFlex)
program to assess (1) NRC’s adherence to applicable laws and regulations, (2) the
adequacy of NRC’s internal controls associated with the program, and (3) whether
the program adequately addresses unique situations such as drug testing, official
travel, and other events.

Overall, NRC’s administration of the NEWFlex program complies with applicable
laws and regulations, management applies generally adequate internal controls,
and internal procedures adequately address unique situations. However, OIG
identified opportunities for the agency to enhance administration of the program.
Specifically, the agency has not updated its NEWFlex intranet information, provided
adequate NEWFlex training, or established performance standards and metrics to
measure program success. OIG makes recommendations to address these issues.

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


Audit of NRC's Use of the NEWFlex Program

inconsistent and inaccurate entry of employee split work schedules. The agency
Official in charge of maintaining NEWFlex intranet information concurred that the
information was not routinely updated and NRC does not provide specific training to
new supervisors and staff on NEWFlex features.

Additionally, management has not developed independent metrics or established
specific performance standards to monitor and analyze NEWFlex. Nonsupervisory
staff have never been surveyed regarding NEWFlex.

Inadequate NEWFlex Information, Training, and Monitoring

Without reliable information, some staff lack understanding of certain NEWFlex
features and procedures. Without clear NRC Human Resources Management
System training, some staff are unsure of the correct format to enter split work
schedules.

Furthermore, without up-to-date specific program metrics, the agency cannot
determine whether NEWFlex is meeting the goals of enhancing work-life balance
and improving recruitment and retention efforts.

RECOMMENDATIONS
OIG recommends that the Executive Director for Operations:

1. Develop and implement a process to provide current and accurate
NEWFlex information on the agency's intranet.

2. Modify the Supervisor Development Program to include training for
managing NEWFlex work schedules and NEWFlex time and
attendance reporting.

3. | Make the NEWFlex work schedule and NEWFlex time and attendance
training provided in the Supervisor Development Program available
online for all employees.

OIG recommends that the Chief Financial Officer:
4. Enhance the NRC Human Resources Management System training

module to provide clear step-by-step procedures for entering
NEWFlex split work schedules.


Audit of NRC's Use of the NEWFlex Program

internal procedures adequately address unique situations. However, opportunities
exist for the agency to improve its administration of NEWFlex.

Opportunities Exist To Improve NRC’s Administration of NEWFlex

OIG identified three areas where management could improve administration of the
NEWFlex program: (1) NEWFlex information on the intranet site is outdated, (2)
NEWFlex training is inadequate, and (3) NEWFlex performance measures are
lacking. Federal law and internal control standards require agencies to provide
current and accurate program information, provide adequate program training, and
monitor program performance for effectiveness. However, the agency has not
created an adequate process for updating NEWFlex intranet information and has
not established a mandatory training program for NEWFlex. Further, management
has not established and monitored performance indicators specific to NEWFlex. As
a result, not all employees fully understand basic NEWFlex features because they
lack mandatory training, and management is unable to monitor the NEWFlex
program effectively.

Program Information, Training, and Monitoring Requirements

Federal laws and internal control standards establish requirements for agencies to
provide employees with relevant and reliable communications and adequate
training, as well as to monitor agency programs for effectiveness. The Government
Accountability Office established internal control standards that require agencies to
communicate reliable and timely information to employees who need it. The
Federal Employees Flexible and Compressed Work Schedules Act of 1982 requires
agencies to provide adequate training to ensure employees understand work-life
program features.

Furthermore, Government Accountability Office guidance requires agencies to
establish and monitor performance indicators to measure and analyze the
effectiveness of their programs.

NEWFlex Administration Needs Improvement

OIG found three areas where the administration of the NEWFlex program could be
improved: (1) the agency intranet site for NEWFlex contains inaccurate and
outdated information, (2) training for NEWFlex is inadequate, and (3) the agency
does not monitor performance measures specific to NEWFlex.


Audit of NRC’s Use of the NEWFlex Program

The agency tracks employee schedules and biweekly time and attendance
reporting through the NRC Human Resources Management System.? Calendar
year 2012 data from the NRC Human Resources Management System
demonstrates that most NRC employees have chosen a NEWFlex schedule (see
Figure 1).

Figure 1: Distribution of NRC Employees by Work Schedule
for Calendar Year 2012

NRC Employees by Work Schedule

All Other Work
Schedules

Compressed Work
Schedule

m NEWFlex Work
Schedule

Source: OIG analysis of NRC Human Resources Management System data.

OBJECTIVES

The audit objectives were to assess (1) NRC’s adherence to applicable laws and
regulations, (2) the adequacy of NRC’s internal controls associated with the
program, and (3) whether the program adequately addresses unique situations
such as drug testing, official travel, and other events.

RESULTS

OIG compared applicable laws and regulations to NRC Management Directives,
tested program internal controls, and reviewed internal procedures related to
unique situations. OIG determined that, overall, NRC’s administration of NEWFlex
complies with applicable laws and regulations, management applies generally
adequate internal controls related to NEWFlex time and attendance reporting, and

? NRC Human Resources Management System is the agency's system for capturing time, attendance, and
labor data.


Audit of NRC's Use of the NEWFlex Program

BACKGROUND

The U.S. Congress determined “that the use of flexible ... work schedules has the
potential to improve productivity in the Federal Government and provide greater
service to the public.” Congress and the President signaled their support for flexible
work-life programs by passing the Federal Employees Flexible and Compressed
Work Schedules Act of 1982. Congress amended the act to incorporate a 1994
presidential memorandum that directed executive agencies to implement work-life
balance initiatives, including flexible work schedules. The memorandum stated,
“Broad use of flexible work arrangements ... can increase employee effectiveness
and job satisfaction, while decreasing turnover rates and absenteeism.”

NRC has implemented increasingly flexible work schedule initiatives over a number
of years. The agency began flexible work schedule pilot programs in 1977. In
1989, the agency added the compressed work schedule’ option to provide
additional alternative work schedule choices. In November 2009, NRC
implemented NEWFlex, adding more features to provide an “environment rich in
work-life balance.” Table 1 summarizes NEWFlex work schedule features.

Table 1: Summary of NEWFlex Features

Normally Monday to Friday over 10 or fewer workdays per pay period
Saturdays as a normal work day by approval

Earliest arrival: 5:00 AM

Latest departure: 8:00 PM (11:00 PM with approval)

Core hours: work day/hour(s) employee must account for each pay period
Account for up to 11.25 hours a day (including regular hours, credit hours
earned/used, leave used, etc.)

Vary arrival/departure times and number of hours worked each day

Include non-contiguous hours in work schedules

Arrive/depart up to 1 hour before to 1 hour after scheduled

arrival/departure time .

> Hours worked in excess of a basic schedule to vary the length of a
workweek/workday (excludes senior executive service employees)

>» Maximum credit hour carry over to the next pay period: 24 credit hours for

full-time employees, up to 25 percent of scheduled tour of duty for part-

time employees

viviv VVVVVV

Source: OIG summary of information in the handbook of Management Directive 10.42, Work Schedules and
Premium Pay.

"A 5-4/9 compressed work schedule is a work schedule with a full-time, 80 hour, biweekly basic work
requirement that is fixed and scheduled for nine basic workdays, eight of which are 9-hour workdays and one of
which is an 8-hour workday.