AUDIT REPORT

Audit of NRC’s Telework Program

OIG-10-A-13 June 9, 2010

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

June 9, 2010

MEMORANDUM TO: R. William Borchardt

Executive Director for Operations

FROM: Stephen D. Dingbaum /RA/

Assistant Inspector General for Audits

SUBJECT: AUDIT OF NRC’S TELEWORK PROGRAM

(OIG-10-A-13)

Attached is the Office of the Inspector General’s (OIG) audit report titled, Audit of NRC’s

Telework Program.

The report presents the results of the subject audit. Agency comments provided at the 

April 30, 2010, exit conference and a subsequent meeting 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 Kathleen Stetson, Team Leader, Financial and Administrative Audit Team, 

at 415-8175.

Attachment: As stated 
Electronic Distribution

Edwin M. Hackett, Executive Director, Advisory Committee on Reactor

 Safeguards

E. Roy Hawkens, Chief Administrative Judge, Atomic Safety and

 Licensing Board Panel

Stephen G. Burns, General Counsel

Brooke D. Poole, Jr., Director, Office of Commission Appellate Adjudication 

James E. Dyer, Chief Financial Officer

Margaret M. Doane, Director, Office of International Programs 

Rebecca L. Schmidt, Director, Office of Congressional Affairs

Eliot B. Brenner, Director, Office of Public Affairs

Annette Vietti-Cook, Secretary of the Commission

Bruce S. Mallett, Deputy Executive Director for Reactor 

 and Preparedness Programs, OEDO

Martin J. Virgilio, Deputy Executive Director for Materials, Waste, Research, 

 State, Tribal, and Compliance Programs, OEDO

Darren B. Ash, Deputy Executive Director for Corporate Management 

 and Chief Information Officer, OEDO 

Nader L. Mamish, Assistant for Operations, OEDO

Kathryn O. Greene, Director, Office of Administration

Patrick D. Howard, Director, Computer Security Officer

Roy P. Zimmerman, Director, Office of Enforcement

Charles L. Miller, Director, Office of Federal and State Materials 

 and Environmental Management Programs

Cheryl A. McCrary, Director, Office of Investigations 

Thomas M. Boyce, Director, Office of Information Services

James F. McDermott, Director, Office of Human Resources

Michael R. Johnson, Director, Office of New Reactors

Michael F. Weber, Director, Office of Nuclear Material Safety and Safeguards 

Eric J. Leeds, Director, Office of Nuclear Reactor Regulation 

Brian W. Sheron, Director, Office of Nuclear Regulatory Research

Corenthis B. Kelley, Director, Office of Small Business and Civil Rights 

James T. Wiggins, Director, Office of Nuclear Security and Incident Response 

Samuel J. Collins, Regional Administrator, Region I

Luis A. Reyes, Regional Administrator, Region II

Mark A. Satorius, Regional Administrator, Region III

Elmo E. Collins, Jr., Regional Administrator, Region IV
Audit of NRC’s Telework Program

i

EXECUTIVE SUMMARY 

In recent years, the Federal Government has taken steps to increase 

opportunities for employees to telework. Telework is defined as work 

arrangements in which an employee regularly performs officially assigned 

duties at home or other worksites geographically convenient to the 

employee’s residence. Telework is also a tool that can be used to ensure 

continuity of essential Government functions in the event of national or 

local emergencies. 

The Nuclear Regulatory Commission (NRC), Office of Human Resources 

(HR) Employee/Labor Relations and Work Life Branch, has responsibility 

for implementing the NRC’s telework program in accordance with telework 

guidelines stated in the Collective Bargaining Agreement (CBA) between 

NRC and the National Treasury Employees Union, which covers 

approximately 68 percent of NRC permanent employees. NRC recently 

renegotiated the telework program guidelines in the CBA, effective 

November 1, 2009. 

This report addresses three categories of telework arrangements that are 

practiced at NRC: project-based, fixed-schedule, and full-time. Projectbased telework is used to complete portable short-term tasks such as 

writing performance appraisals. The time spent is normally measured in 

terms of days or hours. Fixed-schedule telework is a regular arrangement 

to perform portable duties for a specified period of time. For the period 

2006-2009, the number of NRC’s fixed-schedule teleworkers increased 

from approximately 200-700. Full-time telework is a type of fixed-schedule 

telework that occurs when an employee primarily works at an alternate 

workplace. As of January 2010, 27 employees had either obtained or 

requested full-time telework. 

PURPOSE

The audit objectives were to determine NRC’s readiness to have staff 

telework under emergency situations, the adequacy of internal controls 

associated with the telework program, and if NRC’s telework program 

complies with relevant law and Office of Personnel Management 

guidance. Appendix A contains more information on the audit scope and 

methodology.
Audit of NRC’s Telework Program

ii

RESULTS IN BRIEF

NRC has established a telework program that supports the agency’s 

mission and work/life programs. However, the Office of the Inspector 

General identified opportunities for program improvements in the following 

areas:

Readiness to telework during emergency situations.

Telework program internal controls.

Compliance with law.

Readiness to Telework During Emergency Situations

NRC emergency plans require that employees potentially needed to 

telework during pandemic emergencies be identified and have the 

equipment needed to telework. However, NRC has not identified all of the 

individuals needed for teleworking during pandemic emergencies or the 

methods for accessing information technology systems that are not 

remotely accessible via Citrix or in the event of a power failure, but are 

potentially needed for telework to occur. This is because not all NRC 

offices have made completing the telework aspects of pandemic planning 

a priority. Without identifying the individuals needed to telework during 

emergencies and how systems would be accessed for telework during 

emergencies, the agency’s ability to perform mission-related functions in a 

pandemic emergency is diminished. 

Telework Program Internal Controls

Management has the fundamental responsibility to develop and maintain 

effective internal control over the telework program, such as ensuring that 

required telework documentation is properly approved, maintained, and 

readily available for examination. In addition, management is responsible 

for developing and implementing detailed telework policies and 

procedures that should appear in a management directive or operating 

manual. However, NRC is not maintaining complete telework 

documentation and has not developed or implemented a telework program 

policy that applies to all agency employees. These internal control 

weaknesses exist because agency policy and procedures regarding 

telework are not consolidated into a management directive and handbook. 

By strengthening internal controls, NRC staff can improve the telework 

program so that employees will have a common understanding of the 

program and an increased awareness of opportunities to telework.

 
Audit of NRC’s Telework Program

iii

Compliance with Law

NRC is required to establish telework policies that provide eligible 

employees the ability to telework to the maximum extent possible without 

diminished employee performance. CBA telework eligibility guidance 

requires that management consider covered employee performance for 

initial and continued participation. Despite these requirements, managers 

inconsistently assessed and reported the results of employee 

arrangements to HR and in some cases did not report the information. 

Performance was inconsistently assessed and reported because NRC has 

not established procedures to accomplish a consistent approach. As a 

result, the agency has no assurance that all employees who telework fulltime from alternate worksites are maintaining their expected performance 

levels. 

This report makes recommendations to improve the agency’s 

management of the telework program. A consolidated list of these 

recommendations appears in Section IV of this report.

At an exit conference on April 30, 2010, agency management stated their 

general agreement with the findings and recommendations in this report. 

Agency management also provided supplemental information that has 

been incorporated into this report as appropriate. As a result, the agency 

opted not to provide formal comments for inclusion in this report.
Audit of NRC’s Telework Program

iv

ABBREVIATIONS AND ACRONYMS

CBA Collective Bargaining Agreement 

COOP Continuity of Operations 

GAO U.S. Government Accountability Office

NRC Nuclear Regulatory Commission

HR Office of Human Resources

OIG Office of the Inspector General

OPM Office of Personnel Management

PMEF Primary Mission Essential Functions 

PPF Pandemic Priority Functions 
Audit of NRC’s Telework Program

v

TABLE OF CONTENTS

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

ABBREVIATIONS AND ACRONYMS................................................... iv

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

II. PURPOSE......................................................................................4

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

A. OPPORTUNITIES EXIST TO IMPROVE 

READINESS TO TELEWORK IN EMERGENCY 

SITUATIONS .....................................................................................5

B. STRENGTHENED INTERNAL CONTROL MEASURES 

ARE NEEDED TO BETTER IMPLEMENT THE

TELEWORK PROGRAM..................................................11

C. METHODS TO EVALUATE EMPLOYEE TELEWORK 

ARRANGEMENTS NEED TO BE IDENTIFIED FOR

COMPLIANCE WITH LAW...............................................15

IV. CONSOLIDATED LIST OF RECOMMENDATIONS ....................17

V. AGENCY COMMENTS.................................................................17

APPENDICES

A. SCOPE AND METHODOLOGY.....................................................18

B. OTHER MATTERS.........................................................................20
Audit of NRC’s Telework Program

1

I. BACKGROUND

In recent years, the Federal Government has taken steps to increase 

opportunities for employees to telework. Telework is defined as work 

arrangements in which an employee regularly performs officially assigned 

duties at home or other worksites geographically convenient to the 

employee’s residence.

The main legislative mandate for telework was established in Public Law

106-346 §359, Department of Transportation and Related Agencies 

Appropriations, 2001, dated October 23, 2000. This legislation requires

each executive agency to establish a policy under which eligible 

employees may telework to the maximum extent possible without 

diminished employee performance. Subsequent legislation requires that 

each executive agency ensure the removal of managerial, logistical, and 

other barriers to full implementation and successful functioning of the 

policy. Each agency should also provide adequate administrative, human 

resources, technical, and logistical support for carrying out the policy. 

NRC’s Telework Program 

The Office of Human Resources (HR), Employee/Labor Relations and 

Work Life Branch, has responsibility for implementing the Nuclear 

Regulatory Commission’s (NRC) telework program in accordance with 

telework guidelines stated in the Collective Bargaining Agreement (CBA) 

between NRC and the National Treasury Employees Union, which covers 

approximately 68 percent of NRC permanent employees. NRC recently 

renegotiated the telework program guidelines in the CBA, effective 

November 1, 2009. 

Staff in multiple NRC offices are involved in NRC telework program 

implementation. HR has responsibility for developing policy and 

procedures, including necessary forms, to implement, monitor, evaluate, 

and otherwise administer the program through the agency telework 

coordinator, an HR employee, and each office’s telework coordinator. The 

agency telework coordinator monitors the overall progress of the telework 

program, reports on trends or changes in the agency program and/or 

telecommuting issues in general to the Office of Personnel Management 

(OPM). The agency telework coordinator also provides program 

coordination with offices and regions, the Chief Information Officer, the 

Agency Safety and Health Manager, the Division of Facilities and Security,

the Computer Security Office, and the Office of the General Counsel. 

Each office’s telework coordinator gathers data to advise managers, 

participants, and other interested parties on matters pertaining to program 

implementation.
Audit of NRC’s Telework Program

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Telework Categories 

This report addresses three categories of telework arrangements that are

implemented at NRC: (1) project-based, (2) fixed-schedule, and (3) fulltime.

Project-based telework is used to complete portable short-term tasks 

such as writing performance appraisals. The time spent is normally 

measured in terms of days or hours and supervisors approve 

employee requests for this type of telework arrangement. Previously, 

managers approved employee requests for project-based telework

verbally or via e-mail. Revised CBA guidance now requires employees 

to request project-based telework using specific NRC forms. 

Numerous employees telework on a project basis; however, NRC is 

not required to track the number of project-based teleworkers. 

Fixed-schedule telework is a regular arrangement to perform portable

duties for a specified period of time. Office directors are authorized to 

approve fixed-schedule telework arrangements for up to 3 days a 

week. Fixed-schedule telework that exceeds 3 days per week requires

HR director approval. The following graph illustrates the number of 

fixed-schedule teleworkers at NRC.

Source: NRC data as reported to OPM.

0

100

200

300

400

500

600

700

800

2006 2007 2008 2009

NRC Fixed-Schedule Teleworkers, 2006 - 2009 
Audit of NRC’s Telework Program

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Full-time telework is a type of fixed-schedule telework that occurs

when an employee primarily works at an alternate workplace. As of 

June 2009, HR had approved 18 NRC employees’ agreements for 

telework on a full-time basis. These full-time teleworkers held a range 

of positions, including, an administrative judge, engineer, cybersecurity specialist, employee with specialized information technology 

skills, and health physicists. They worked varying schedules ranging 

from 8 to 40 hours per week; part-time employees can be approved to 

telework on a full-time basis. By January 2010, 27 employees had 

either obtained or requested full-time telework, reflecting an

approximate 50-percent growth in 6 months. 

Full-time teleworkers must receive approval for their arrangement from 

the HR director. The Offices of Information Services, Computer 

Security, and Administration concur on full-time telework requests to 

ensure that teleworkers:

Have the infrastructure services needed to support their telework.

Will conduct the work assigned in accordance with NRC computer 

security policy.

Could be drug tested at an appropriate facility, in accordance with 

agency policy when selected for random drug testing.

Telework During Emergencies 

Telework is one of the tools that can be used to ensure continuity of

essential Government functions in the event of national or local 

emergencies. OPM telework guidance states that managers must include 

telework in pandemic, as well as, Continuity of Operations (COOP) and 

other emergency response planning. Emergency planning guidance also 

cites the benefits of using telework to slow the spread of disease by 

keeping face-to-face contact to a minimum while at the same time 

maintaining operations as close to normal as possible. Implementing 

telework during emergencies helps agencies retain functionality if the main 

worksite is difficult to access. 
Audit of NRC’s Telework Program

4

II. PURPOSE

The audit objectives were to determine:

NRC’s readiness to have staff telework under emergency 

situations.

The adequacy of internal controls associated with the telework 

program.

If NRC’s telework program complies with relevant law and OPM 

guidance.

Appendix A contains more information on the audit scope and 

methodology.
Audit of NRC’s Telework Program

5

III. FINDINGS

NRC has established a telework program that supports the agency’s 

mission and work/life programs.

1

 However, opportunities exist to improve 

NRC’s:

Readiness to telework during emergency situations.

Telework program internal controls.

Compliance with law.

Addressing these areas will improve the management of NRC’s telework 

program as employee use of telework continues to grow.

A. Opportunities Exist To Improve Readiness To Telework in Emergency 

Situations2

NRC emergency plans require that employees potentially needed to 

telework during pandemic emergencies be identified and have the

equipment needed to telework. However, NRC has not identified all of the 

individuals needed for teleworking during pandemic emergencies or the 

methods for accessing information technology systems that are not 

remotely accessible via Citrix3or in the event of a power failure, but are 

potentially needed for telework to occur. This is because not all NRC

offices have made completing the telework aspects of pandemic planning 

a priority. Without identifying the individuals needed to telework during 

emergencies and how systems would be accessed for telework during 

emergencies, the agency’s ability to perform mission-related functions in a

pandemic emergency is diminished.

 

1 Work/life programs are human capital tools that help attract and retain employees by allowing them to 

balance their work and personal or family lives. Telework is one of a variety of tools, along with alternate 

work schedules, annual and sick leave, childcare subsidy, and preventive health services.

2

Although this report focuses on telework during a pandemic emergency, other events envisioned in 

COOP plans and plans to address other emergencies, including natural and manmade disasters, will 

necessitate NRC’s preparedness to expand telework.

3 Citrix refers to an information technology application that allows employees remote computer access to 

NRC systems and applications. Citrix supports 1,215 licenses for headquarters and regions combined. 

This is the total number of users who could be remotely logged into the NRC network.
Audit of NRC’s Telework Program

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Emergency Planning Telework Requirements

On November 1, 2005, former President George W. Bush announced the 

National Strategy for Pandemic Influenza and directed all Federal

agencies to begin internal planning to ensure readiness in the event of an 

influenza pandemic. The NRC Pandemic Plan consists of (1) an overall 

agency plan that promulgates agencywide concepts, guidance, and policy 

and (2) individual office plans that supplement the agency plan with 

specific procedures and other details specific to their office mission and 

function. NRC’s pandemic plans provide guidance for managing tasks 

with a decreasing workforce. 

Requirement for Identification of Employees and Systems Needed 

To Perform Essential Functions 

The NRC Pandemic Plan requires NRC to identify the employees and 

systems potentially needed to telework during a pandemic emergency. 

Each headquarters and regional office must develop and implement 

pandemic related processes and procedures in sufficient detail to execute 

the agency and office pandemic plans. Offices with responsibilities for 

performing NRC’s essential functions4and the offices responsible for 

supporting them are required to develop and maintain lists that identify:

Personnel qualified to perform the functions and who can be 

reassigned to support other offices.

Systems required to support those functions.

Staff and contractors qualified to operate and maintain the support 

systems.

Information Technology Infrastructure Needed To Telework During

a Pandemic Emergency 

NRC’s Executive Director for Operations delegated overall responsibility 

for pandemic planning to the Office of Nuclear Security and Incident 

Response, which formed a Pandemic Task Group that coordinated tasks 

with offices and regions to ensure adequate telework capability during a 

pandemic. The Office of Information Services prepared for the Pandemic 

Task Group a concise description of the practical methods available for 

working at home and, for each method, the functional, equipment, time,

and other limitations on usage. The methods identified for adequate 

 

4

These essential functions are those NRC seeks to maintain in a pandemic influenza emergency. Some 

Pandemic Priority Functions (PPF) are termed ―primary mission essential functions‖ (PMEF) in NRC’s 

Continuity of Operations (COOP) Plan. One example of a PPF that is also a PMEF is threat assessment 

and dissemination, which pertains to communication of safety and security information in an emergency.
Audit of NRC’s Telework Program

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telework capability include Citrix access, Webmail (to access NRC e-mail 

from the Internet), laptops, access to certain sensitive information, 

Blackberries, work from alternate worksites, and teleconferencing.

Individuals and Methods To Access Information Technology

Systems Needed for Telework Not Identified 

NRC has not identified (1) all of the individuals needed to telework and 

(2) the methods for accessing information technology systems that are not 

remotely available but are potentially needed for telework during pandemic 

emergencies. Furthermore, the agency has not addressed how it would 

function in the event of a headquarters power failure, which would make 

Citrix, Webmail, and other systems needed to support essential functions

unavailable.

Individuals Needed To Perform Essential Emergency Functions Not 

Identified

NRC has not identified all of the individuals needed to carry out essential 

functions while teleworking during pandemic emergencies. As of 

October 30, 2009, 21 of 26 offices had not identified personnel who are 

required to perform essential functions and high priority tasks during a 

pandemic. Although most offices and regions identified the position titles 

in their plans, emergency planning guidance states that individuals should 

be identified. Moreover, the names of the individuals who fill the positions 

are needed to ensure that these individuals are prepared for their roles 

prior to an actual emergency. Agency management stated that offices 

were directed to identify titles rather than individual names so that the lists 

would remain current due to the turnover.

Information Technology Infrastructure Not Available Remotely

NRC has not completely identified methods for accessing information 

technology systems needed for telework during pandemic emergencies. 

NRC employees responsible for performing essential functions in an 

emergency would need to access systems to carry out their functions 

while teleworking during an emergency situation; however, not all systems 

required to support essential functions are available remotely. NRC 

identified 35 applications/systems5used to carry out the agency's 

essential functions; however, 28 of the 35 applications/systems are not 

 

5 Data Center Disaster Recovery Planning for U.S Nuclear Regulatory Commission, Task 2 - Business 

Impact Analysis, June 22, 2009, contains a matrix that identifies the NRC offices and systems needed to 

perform essential functions.
Audit of NRC’s Telework Program

8

accessible on Citrix or any other type of remote access.6Thus, these 

systems are not available to personnel who telework and compensating 

plans to use manual or other systems are not in place. 

Infrastructure Not Available During a Power Failure 

In the event of a headquarters power failure, NRC would be unable to 

access Citrix, Webmail, and other systems required to support essential 

functions.

7 Staff have stated that Citrix access is not necessarily needed 

for telework. However, some office pandemic plans do not indicate

(1) whether employees would use manual methods to continue data 

collection and (2) once the system/application has been restored, how to 

work until normal procedures are fully resumed. Even after a 

system/application becomes available, a mixture of manual (workaround) 

and normal procedures may be needed before office operations return to 

normal. 

Completing Telework Aspects of Pandemic Planning Not a 

Management Priority 

NRC has not identified all individuals and systems infrastructure 

potentially needed for telework during pandemic emergencies because the 

agency has not made completing the telework aspects of pandemic 

planning a priority. Although NRC was required to start pandemic 

planning in 2005, the agency has not: 

Developed a plan to identify and remove the information technology

barriers to telework.

Referenced the procedures for teleworking during an emergency within 

telework guidance.

No Plan Developed To Identify and Remove Information 

Technology Telework Barriers 

In 2009, NRC reported to OPM that one of NRC’s major barriers to 

telework is information technology funding issues; however, NRC did not 

 

6

Some systems that support essential functions would be accessed elsewhere in the event of an 

emergency.

7

In the event of some emergencies, 400 Citrix accounts are available through a regional office.
Audit of NRC’s Telework Program

9

specify what this barrier entails and has not developed a plan to remove 

the barrier. The Office of the Inspector General (OIG) identified agency 

efforts that describe information technology telework barriers.

8 Although 

HR has coordination responsbilities for the telework program, there has 

been no coordinated effort within the agency to identify information 

technology barriers, determine the impact that information technology

barriers have on the telework program, and the best method for removing 

them.

Telework Aspects of Pandemic Planning and Information 

Technology Tasks Relative to Telework Not Included in Telework 

Guidance 

Telework aspects of pandemic planning and information technology tasks 

are not referenced in telework guidance. HR has not communicated staff 

roles concerning emergency planning or information technology 

requirements needed during emergency situations. For example, NRC 

Pandemic Plan, revised March 2, 2010, contains the form, ―Contingency 

Plan for Telework (Work at Home).‖ This form is intended to be used as 

guidance throughout the agency for identifying the specific tasks an 

employee would perform in order to maintain important functions and 

services during significant, sustained periods of absenteeism. However, 

this form does not prompt managers to confirm the employee’s contact 

information, space, telephone, computer equipment, and support needs to 

facilitate the telework arrangement. Although a copy of this form is in the 

appendix of the NRC Pandemic Plan, it is not referenced in telework 

program guidance. 

Mission Accomplishment Diminished 

Without identifying all of the individuals needed to telework and methods 

for accessing systems infrastructure potentially needed for telework during 

pandemic emergencies, the agency’s ability to perform mission-related 

functions in a pandemic emergency is diminished. In addition, a power 

failure would exacerbate the situation and the agency does not have 

compensating plans in place to use manual or other systems. In effect, 

the ability of the agency to use telework during a long-term, severe 

emergency is limited.

 

8 Report From The Worklife Working Group, February 11, 2009, recommended that the current NRC 

telework program be optimized by providing additional focus on program development and infrastructure. 

This would be accomplished by, among other things, considering information technology needs for 

teleworkers when upgrading infrastructure such as laptop docking stations, Blackberry devices, and 

remotely accessible virtual meeting applications to further enhance NRC’s telework capability.
Audit of NRC’s Telework Program

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Recommendations 

OIG recommends that the Executive Director for Operations: 

1. Identify all staff with essential functions to facilitate teleworking in an 

emergency.

2. Identify methods for accessing information technology systems

needed to support essential functions during emergencies. 

3. Develop manual or other compensating systems to allow telework if 

access to the agency’s information technology systems is not 

available.

4. Coordinate agency efforts to identify and remove information 

technology telework barriers, which impede teleworking in an 

emergency.

5. Reference emergency planning and information technology 

procedures in telework guidance.
Audit of NRC’s Telework Program

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B. Strengthened Internal Control Measures Are Needed To Better 

Implement the Telework Program 

Management has the fundamental responsibility to develop and maintain 

effective internal control over the telework program, such as ensuring that 

required telework documentation is properly approved, maintained, and 

readily available for examination. In addition, management is responsible 

for developing and implementing detailed telework policies and 

procedures that should appear in a management directive or operating 

manual. However, NRC is not maintaining complete telework 

documentation and has not developed or implemented a telework program 

policy that applies to all agency employees. These internal control 

weaknesses exist because agency policy and procedures regarding 

telework are not consolidated into a management directive and handbook. 

By strengthening internal controls, NRC staff can improve the telework 

program so that employees will have a common understanding of the 

program and an increased awareness of opportunities to telework. 

Management Internal Control Responsibilities

Internal control is a significant part of managing a program or organization. 

U.S. Government Accountability Office (GAO) standards9provide that 

management should design and implement detailed program policies and 

procedures and ensure the accurate recording and documentation of all 

significant events. In addition, the GAO standards provide that all 

documentation should be readily available for examination. (Appendix B

of this report contains a listing of successful telework program practices

and internal controls used by other Federal agencies.)

Telework Program Policy Does Not Clearly Apply to All 

Employees

NRC has not developed and fully implemented a telework program policy 

that applies to all agency employees. The agency’s telework policy is 

found in Article 7, Telework, of the CBA between NRC and the National 

Treasury Employees Union. However, the telework policy in the CBA 

clearly does not cover approximately 32 percent of NRC permanent 

employees which amounts to 1,255 full-time non-bargaining unit 

employees. Although in practice, NRC follows the CBA for full-time nonbargaining unit employees, the agency’s telework policy should clearly 

apply to both bargaining unit and non-bargaining unit personnel. 

 

9

Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1, November 1999.
Audit of NRC’s Telework Program

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Telework Program Policy Does Not Include Key Roles and 

Responsibilities 

The current CBA, which contains the agency’s telework program policy, 

does not contain key roles and responsibilities of personnel who help 

manage the program. Key roles not included in the current CBA include

the agency telework coordinator and office/region telework coordinators.

However, roles and responsibilities for these telework personnel were 

included in the prior CBA. An NRC official stated that these agency 

responsibilities were not appropriate in a collective bargaining agreement, 

and thus were excluded from the November 2009 revision. The agency 

telework coordinator and office telework coordinator responsibilities are 

not included in any current NRC policies.

NRC Is Not Maintaining Complete Telework Documentation 

NRC is not maintaining complete telework documentation in accordance 

with internal control standards. OIG reviewed files containing the forms 

required for management to approve telework and found that 

concurrences (signatures and dates), forms, and files were missing in 

numerous cases. Specifically,

Of 18 files reviewed for headquarters and regional full-time teleworkers 

who primarily work from an alternate duty station, 9 were missing 

required signatures and another 9 were missing one or more of the 

necessary forms. 

Of 77 files reviewed of 400 headquarters fixed-schedule teleworkers, 

20 office directors did not note the date of their approval. 

Of 17 fixed-schedule teleworkers in one region10 who telework an 

average of 1 to 3 days per week, 5 files were missing.

 

10

 This region has the largest number of fixed-schedule teleworkers.
Audit of NRC’s Telework Program

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Table 1 reflects the results of OIG’s review of agency telework files.

Table 1. File Review Results:

Examples of Incomplete Documentation

Telework 

Arrangement

NRC

Teleworker

Universe*

Sample

Size

Number of 

Missing

Files

Number of 

Forms 

Missing

Signatures by 

Office 

Directors

Number of 

Files with 

Incorrect HR 

Approvals 

Number 

of Files 

Missing

Forms

Number 

of Forms 

Missing

Dates by 

Office 

Directors 

Full-time

teleworkers, 

headquarters 

and regions

18 **

18 

(100%) 9 (50%) 2 (11%) 9 (50%)

Fixedschedule 

teleworkers

at 

headquarters

400 77 (19%) 5 (6%) 20 (26%)

Fixedschedule 

teleworkers

at one region

17 17 

(100%) 5***(29%) 4 (23%)

*NRC teleworker universe is an approximation based on information provided by the agency. 

**These full-time teleworkers primarily work at home and do not come into the office.

***At the conclusion of the audit, NRC reported that one of the five missing files belonged to a 

teleworker whose agreement ended in February 2007.

Telework Policy and Procedures Are Not Consolidated into a 

Management Directive and Handbook 

Telework internal control weaknesses occurred because agency telework 

policy and procedures are not consolidated in a management directive 

and handbook. According to NRC Management Directives System,

Directive 1.1, NRC issues management directives and handbooks to 

communicate NRC policies, requirements, and procedures necessary for 

the agency to comply with Executive orders, pertinent laws, and 

regulations. Telework policy and procedures have been developed over a 

period of time and documented in several sources such as the CBA, 

Yellow Announcements, internal and external Web sites, and agency 

telework coordinator handouts. Although these sources for telework 

information are helpful, consolidation of this guidance into a management 

directive would better enable managers to access the information needed 

to consistently implement the program. Moreover, with consolidated 

guidance, employees would have a better opportunity to reach a common 
Audit of NRC’s Telework Program

14

understanding of the program and an increased awareness of 

opportunities to telework. Furthermore, the agency would have a telework 

policy that clearly applies to both bargaining and non-bargaining 

personnel. 

Recommendations

OIG recommends that the Executive Director for Operations: 

6. Develop and implement a management directive and handbook for the 

telework program. 

7. Issue consolidated interim telework guidance pending development of 

a telework program management directive and handbook.
Audit of NRC’s Telework Program

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C. Methods To Evaluate Employee Telework Arrangements Need To Be 

Identified for Compliance with Law

NRC is required to establish telework policies that provide eligible 

employees the ability to telework to the maximum extent possible without 

diminished employee performance. CBA telework eligibility guidance 

requires that management consider covered employee performance for 

initial and continued participation. Despite these requirements, managers 

inconsistently assessed and reported the results of employee 

arrangements to HR and in some cases did not report the information. 

Performance was inconsistently assessed and reported because NRC has 

not established procedures to accomplish a consistent approach. As a 

result, the agency has no assurance that all employees who telework fulltime from alternate worksites are maintaining their expected performance 

levels. 

Requirement for Assessing Teleworker Employee Performance

Public Law 106-34611 stipulates that agencies must establish telework 

policies that allow eligible employees to participate in telework to the 

maximum extent possible without diminished employee performance. The 

CBA requires that management consider employee performance to 

determine initial and continued eligibility to participate in the program. 

Inconsistent Assessment and Reporting of Full-Time

Teleworker Employee Performance to the Office of Human 

Resources

Managers inconsistently assessed and reported the results of full-time

teleworker employee arrangements to HR. Agreements for some 

employees to telework full-time from an alternate worksite were approved 

with the stipulation that the employee’s manager assess and report the

results of the telework arrangement to HR. However, as of June 11, 2009, 

the documentation maintained by the agency telework coordinator for the 

1812 HR approved full-time teleworker agreements contained the following 

performance assessment inconsistencies:

7 files contained an agreement for a semiannual evaluation of the 

arrangement.

7 files contained an agreement for an annual evaluation of the 

arrangement.

 

11 Public Law 106–346—Oct. 23, 2000, Department of Transportation and Related Agencies Appropriations, 2001.

12 OIG notes that HR provided the file of one employee whose full-time telework agreement was approved 

as a condition of employment; however the employee did not accept employment at NRC.
Audit of NRC’s Telework Program

16

1 file contained an agreement for an evaluation at the end of the 

arrangement.

3 files did not mention an evaluation of the arrangement.

Based on the agreements for the 17 full-time teleworkers as of June 11, 

2009, managers should have provided HR with an evaluation of 8 telework

arrangements. However, only two files contained documentation 

indicating that an assessment had occurred. Of these, one evaluation of 

the telework arrangement was a multiple-page, detailed description of the 

tasks performed, while the second described the employee’s performance 

in a single sentence. 

No Established Procedures for Assessing and Reporting 

Full-Time Teleworker Performance 

Performance was not consistently assessed and reported because NRC

has not established procedures for evaluating the results of the full-time

telework arrangement. 

No Assurance That Performance Is Being Maintained 

Without periodically assessing and reporting the results of the telework 

arrangement to HR, as stipulated in the telework agreement, NRC has no 

assurance that employees who telework full-time from an alternate 

worksite are maintaining expected performance levels.

Recommendation

OIG recommends that the Executive Director for Operations:

8. Develop and implement a procedure for assessing and reporting the

results of full-time telework arrangements to the Office of Human 

Resources.
Audit of NRC’s Telework Program

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IV. CONSOLIDATED LIST OF RECOMMENDATIONS

OIG recommends that the Executive Director for Operations:

1. Identify all staff with essential functions to facilitate teleworking in an 

emergency.

2. Identify methods for accessing information technology systems

needed to support essential functions during emergencies. 

3. Develop manual or other compensating systems to allow telework if 

access to the agency’s information technology systems is not 

available.

4. Coordinate agency efforts to identify and remove information 

technology telework barriers, which impede teleworking in an 

emergency.

5. Reference emergency planning and information technology 

procedures in telework guidance.

6. Develop and implement a management directive and handbook for the 

telework program. 

 

7. Issue consolidated interim telework guidance pending development of 

a telework program management directive and handbook.

8. Develop and implement a procedure for assessing and reporting the 

results of full-time telework arrangements to the Office of Human 

Resources.

V. AGENCY COMMENTS

At an exit conference on April 30, 2010, agency management stated their 

general agreement with the findings and recommendations in this report. 

Agency management also provided supplemental information that has 

been incorporated into this report as appropriate. As a result, the agency 

opted not to provide formal comments for inclusion in this report.
Audit of NRC’s Telework Program

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Appendix A

SCOPE AND METHODOLOGY 

The audit objectives were to determine (1) NRC’s readiness to have staff 

telework under emergency situations, (2) the adequacy of internal controls 

associated with the telework program, and (3) if NRC’s telework program 

complies with relevant law and OPM guidance.

To accomplish the audit objectives, OIG obtained and analyzed pertinent 

laws, regulations, and authoritative guidance, and NRC policies and 

procedures, including relevant sections of the CBA.

Additionally, OIG reviewed various reports, HR documents, and internal 

communications and conducted interviews with staff to:

Gain an understanding of NRC’s telework program.

Determine relevant current issues, problems, and known deficiencies.

Assess internal controls.

OIG met with the agency’s Pandemic Working Group and identified

requirements for telework as outlined in the NRC Pandemic Plan. OIG 

also performed a site visit at Region I and performed additional work via 

telephone related to telework at Region II.

This audit did not include a review of the special circumstances work-athome policy because this provision is not implemented in accordance with 

the same public law and collective bargaining agreement provisions as 

telework. 

Internal controls that relate to the audit objectives were reviewed and 

analyzed. Throughout this audit, auditors were aware of the possibility or 

existence of fraud, waste, or misuse in NRC’s telework program.

We conducted this performance audit in accordance with generally 

accepted government auditing standards from May 2009 to February 

2010. 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 stated audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on the stated audit objectives.
Audit of NRC’s Telework Program

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The work was conducted by Steven Zane, Team Leader; Vicki Foster, 

Audit Manager; Yvette Mabry, Senior Auditor; Elaine Kolb, Senior Auditor; 

Michael Steinberg, Senior Auditor; and Dennis Sylvester, Auditor. We 

performed this audit work at NRC Headquarters in Rockville, Maryland,

and Region I offices in King of Prussia, Pennsylvania.
Audit of NRC’s Telework Program

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Appendix B

OTHER MATTERS

During the course of this audit, OIG considered other matters, including 

telework program practices and internal controls used by other Federal 

agencies such as the U.S. Patent and Trademark Office and the Office of 

Personnel Management. Key successful telework program practices and 

internal controls follow.

Successful Telework Program Practices and Internal Controls

In addition to their Collective Bargaining Agreement, the U.S. Patent 

and Trademark Office maintains telework policy provisions in a 

separate policy.

Communicate with teleworking employees on a regular basis through 

traditional methods and videoconferencing, document sharing (e.g.,

use of SharePoint sites), and virtual meetings.

Plan the work in advance, set expectations, and monitor performance 

on a continual basis.

Track the following information: general/salary level, number of days of 

telework, number of eligible positions teleworking in each office, 

agencywide teleworkers, percentage of eligible positions teleworking, 

and percentage of total positions teleworking.

Consider entering telework information, including telework agreements,

into an enterprise-wide telework database by the agency telework 

coordinator. This should facilitate retrieving the information for the 

OPM annual data call.

Consider the applicability and adaptability of reimbursing teleworking 

employees for costs (subject to limitations) associated with maintaining 

high-speed internet access at employees’ homes. (A January 2007 

GAO decision allows agencies to reimburse employees for high-speed 

Internet service at employees’ homes associated with the agency’s 

telework program.)

Establish controls to help ensure that high-speed Internet access 

services are reimbursed only for official purposes.