FEDERAL

TELEWORK

Additional Controls 

Could Strengthen 

Telework Program 

Compliance and Data 

Reporting

Report to Congressional Requesters

February 2017

GAO-17-247

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-247, a report to 

congressional requesters

February 2017

FEDERAL TELEWORK

Additional Controls Could Strengthen Telework 

Program Compliance and Data Reporting

What GAO Found

The telework policies at four selected case study agencies GAO reviewed met 

select requirements of the Telework Enhancement Act of 2010 (the act) for 

telework eligibility and agreements. These agencies followed similar processes

for approving telework agreements. Office of Personnel Management (OPM)

guidance recommends managers complete telework training prior to approving 

telework agreements, but three of the four agencies did not have a mechanism

to help ensure managers have completed this training before approving 

employee telework agreements. Because managers in these agencies may not

have completed the training before entering into agreements, they may not be 

familiar with telework policies. Further, three of the four agencies did not require

a periodic documented review of telework agreements. By not requiring regular 

review of telework agreements, these agencies cannot be assured that the 

agreements reflect and support their current business needs. Consistent with the

act, all four agencies described efforts to encourage telework participation and 

provide for the technology to enable it. However, GAO’s focus groups with 

teleworkers provided some examples of how supervisors may discourage 

telework participation and reported that some level of managerial resistance to 

telework remains. Managerial resistance to telework can undermine reviewed

agencies’ ability to meet telework participation goals. In its leadership role for 

telework matters, OPM can assist agencies with tools to assess and resolve 

these types of concerns.

Consistent with the act, all four case study agencies have controls to help ensure

that telework does not diminish employee and organizational performance. 

These four agencies’ policies followed the act’s requirement that teleworkers be 

treated the same as nonteleworkers for the purposes of work requirements, 

performance appraisals, and other managerial decisions. Agency officials and 

focus groups reported that telework status did not impact performance 

expectations. Focus groups with supervisors described numerous strategies and 

resources they use to supervise and stay connected with teleworking employees.

The four agencies used varied methods to collect and report telework data to be

included in OPM’s annual telework reports, but all cited challenges to ensuring 

that employee-reported telework data were accurate because employees may 

not know or follow policies for recording telework. While three of these agencies 

use electronic systems to track telework agreements, the Department of Labor

(Labor) uses a manual system which limits its ability to access accurate, realtime telework agreement data that management uses to assess compliance and 

for resource allocation decisions. Further, GAO found that the Department of 

Education (Education) had not been reporting telework eligibility data compliant 

with the act. OPM also faced challenges in reporting accurate agency telework 

data and GAO identified errors in OPM’s annual reports to Congress. For 

example, OPM’s report cited Education’s fiscal year 2016 telework participation

goal as 5 percent, reflecting Education’s goal for increasing its participation rate, 

instead of its overall participation goal of 90 percent. OPM may be missing 

opportunities to improve its data because it does not always follow up with 

agencies on significant data differences or outliers. The errors and invalid data in 

OPM’s annual reports to Congress reduce the usefulness of these reports.

View GAO-17-247. For more information, 

contact Yvonne Jones at (202) 512-6806 or 

jonesy@gao.gov.

Why GAO Did This Study

The Telework Enhancement Act of 

2010 required agencies to develop 

telework policies and OPM to provide 

guidance and report on telework use, 

among other things. GAO was asked 

to review agency telework programs.

This report examines (1) how selected 

agencies comply with the act’s 

requirements, (2) the internal controls 

affecting federal supervisors’ ability to

hold teleworkers accountable for 

achieving results, and (3) the 

challenges selected agencies and 

OPM face in collecting and reporting 

telework data. GAO selected four case 

study agencies for review—Education, 

General Services Administration,

Labor, and Securities and Exchange 

Commission—based on agency size 

and telework participation rates. GAO 

reviewed OPM guidance and reports, 

and policies and data at case study 

agencies. GAO also interviewed OPM 

and case study agency officials and 

held focus groups with case study 

agency supervisors and teleworkers.

What GAO Recommends

GAO makes recommendations to each 

of the case study agencies, including

ensuring supervisors complete

telework training in a timely manner

and improving telework data. GAO also 

recommends that OPM develop tools 

to help agencies assess telework

barriers, and to improve telework data

reported to Congress. Three agencies 

agreed with the recommendations. 

One did not comment. OPM disagreed 

with GAO’s recommendations citing 

limited resources to expend on efforts 

not specifically required under the act. 

GAO maintains that OPM should 

implement these actions as discussed 

in the report.
Page i GAO-17-247 Federal Telework

Letter 1

Background 3

Selected Agency Telework Programs Reflect Requirements of the 

Act, but Some Controls Are Not Documented and Agencies 

Face Some Barriers to Increasing Participation 9

Selected Agency Telework Policies and Supervisors’ Strategies 

Enable Agencies to Manage for Results 24

OPM and Case Study Agencies Face Challenges in Collecting 

and Reporting Accurate and Consistent Telework Data 29

Conclusions 40

Recommendations for Executive Action 41

Agency Comments and Our Evaluation 42

Appendix I Objectives, Scope, and Methodology 45

Appendix II Comments from the Department of Education 50

Appendix III Comments from the General Services Administration 52

Appendix IV Comments from the Securities and Exchange Commission 53

Appendix V Comments from the Office of Personnel Management 55

Appendix VI GAO Contact and Staff Acknowledgments 58

Tables

Table 1: Reported Number of Federal Employees Participating in 

Telework, Fiscal Years 2012-2015 5

Table 2: Average Number of Teleworkers and Hours Teleworked 

per Pay Period at Four Agencies, September 30, 2015—

May 31, 2016 7

Contents
Page ii GAO-17-247 Federal Telework

Table 3: Office of Personnel Management’s Key Steps for 

Managers of Teleworkers 16

Table 4: Examples of How Supervisors and Managers Support 

and Discourage Telework Participation 21

Figures

Figure 1: Telework Eligibility and Participation Criteria for Four 

Agencies 11

Figure 2: Telework Agreement Approval Process Example Flow 

Chart 13

Figure 3: Telework Training Requirements at Four Agencies 15

Figure 4: Internal Control Objectives for Performance 

Management at Four Agencies 26

Figure 5: Strategies and Resources Managers at Four Case Study 

Agencies Use to Manage Teleworkers 28

Figure 6: Total Telework Hours at Four Agencies per Pay Period, 

for Pay Periods Ending October 3, 2015—June 11, 2016 32

Abbreviations

the act Telework Enhancement Act of 2010

CHCO Chief Human Capital Officers

COOP continuity of operations

Education Department of Education

EHRI Employee Human Resources Integration

FEVS Federal Employee Viewpoint Survey

GSA General Services Administration

IT information technology

Labor Department of Labor

OPM Office of Personnel Management

POC point of contact

SEC Securities and Exchange Commission

TMO Telework Managing Officer

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Page 1 GAO-17-247 Federal Telework

441 G St. N.W.

Washington, DC 20548

February 17, 2017

The Honorable Jason Chaffetz

Chairman

Committee on Oversight and Government Reform

House of Representatives

The Honorable Darrell Issa

House of Representatives

Congress has encouraged federal agencies to expand staff participation 

in telework, most recently in 2010 by passing the Telework Enhancement 

Act of 2010 (the act)1 which requires executive agencies to establish 

telework policies, incorporate those policies into their respective continuity 

of operations plans, and provide interactive telework training to 

employees eligible to telework and managers of teleworkers. The act 

describes the Office of Personnel Management’s (OPM) responsibilities 

and agencies’ telework program responsibilities. As telework participation 

expands, agencies must address how to develop and institute internal 

controls to ensure they are managing for results in a telework 

environment. Also, in accordance with the act, agencies must establish 

policies to ensure that telework does not diminish employee performance 

or agency operations.

You asked for us to review agency internal controls for telework, 

performance management in a telework environment, and how often 

employees are teleworking. This report identifies and examines (1) how 

selected agencies establish and monitor telework eligibility and 

participation, and comply with the requirements of and expectations 

included in telework agreements; (2) the internal controls and practices at 

selected agencies that affect supervisors’ abilities to manage for results in 

the telework environment, and hold employees who routinely telework 

accountable for achieving results; and (3) the challenges selected 

agencies and OPM face in collecting and reporting telework data.

To address these objectives, we reviewed and used as criteria the act, 

Standards for Internal Control in the Federal Government, OPM’s 

 1

Pub. L. No. 111-292, 124 Stat. 3165 (Dec. 9, 2010), codified primarily at chapter 65 of 

title 5, United States Code.

Letter
Page 2 GAO-17-247 Federal Telework

guidance and training on telework and performance management, and 

our prior work on agency telework programs. We also interviewed key 

OPM officials from Employee Services and Senior Executive Service and 

Performance Management as well as the Executive Director of the Chief 

Human Capital Officers (CHCO) Council. We also selected four agencies 

as case studies, including the Department of Education (Education), the 

General Services Administration (GSA), the Department of Labor (Labor), 

and the Securities and Exchange Commission (SEC) for our review. We 

selected these agencies using size and telework participation rates as 

criteria. We also conducted a series of focus groups at the four case 

study agencies with groups of supervisors of teleworkers and groups of 

teleworkers. When discussing these focus groups throughout the report, 

we use the word some to mean more than two but fewer than six focus 

groups.

To determine how the four case study agencies establish and monitor 

telework eligibility and compliance with requirements and expectations of 

telework agreements, we reviewed the act, OPM guidance, telework 

policies, telework training materials, blank telework agreements, and 

collective bargaining agreements. We interviewed agency officials 

responsible for telework policy and program implementation, including the 

Telework Managing Officer (TMO) or the telework coordinator, to discuss 

telework policy, program implementation, internal controls, and OPM 

guidance on telework. We then compared these four agencies’ policies to 

the act’s requirements, OPM guidance, and Standards for Internal Control 

in the Federal Government to assess compliance. We discussed telework 

eligibility and notification at our focus groups with teleworkers, and 

interviewed OPM officials about OPM’s role in providing telework 

guidance to federal agencies.

To determine how supervisors at the four case study agencies manage 

for results in a telework environment and hold employees who routinely 

telework accountable for achieving results, we reviewed requirements of 

the act and agency policies, reviewed OPM and agency-specific training 

materials on telework and performance management, and discussed 

agency performance management policy with case study agency officials. 

We also asked supervisors participating in our focus groups what 

strategies and resources they use to manage their teleworking 

employees, and what steps they take to help ensure telework does not 

diminish their employees’ performance. We asked participants at our 

teleworkers focus groups about how telework has affected their ability to 

meet performance goals, how their supervisor holds them accountable
Page 3 GAO-17-247 Federal Telework

for achieving results, and how the agency supports telework. 

To identify and assess the challenges the four case study agencies and 

OPM face in collecting and reporting telework data, we reviewed our prior 

work on OPM telework data reporting as well as OPM’s Status of 

Telework in the Federal Government Report to Congress (Fiscal Year 

2013) and OPM’s Status of Telework in the Federal Government Report 

to Congress (Fiscal Years 2014 and 2015). We compared agency 

telework data to data in OPM’s reports to Congress to identify any 

discrepancies. To report data on numbers of teleworkers and the average 

number of hours employees telework per pay period, we analyzed 

telework data from each of the case study agencies. We reviewed 

documentation of data sources, tested the data for outliers, and 

interviewed case study agency officials about data reliability and 

determined these data to be reliable for the purposes of our report. We 

interviewed OPM and case study agency officials, teleworkers, and 

supervisors about the steps they take to collect, validate, and report 

telework data, and any challenges they may face in doing so. For more 

detailed information on our objectives, scope, and methodology, please 

see appendix I.

We conducted this performance audit from November 2015 to February

2017 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.

Increasingly, agencies are using telework to diminish the disruption that 

severe weather events and other events may have on agencies’ abilities 

to accomplish their missions. For example, OPM encouraged agencies to

use telework in the Washington, D.C. metropolitan area in response to 

the potential for disruptions caused by the papal visit in September 2015, 

the unplanned 1-day shutdown of the metropolitan area’s subway system 

in the spring of 2016, and ongoing subway track safety work begun in 

2016.

Background
Page 4 GAO-17-247 Federal Telework

In 2010, Congress passed the act to specify the requirements for 

executive agency telework programs and define OPM’s role in providing 

leadership over telework to agencies. In drafting the act, Congress 

acknowledged telework as an important human capital tool for agencies, 

as well as the need for legislation to overcome resistance to telework. We 

have previously reported on federal telework programs and 

recommended improving the reliability of agency-reported data, the extent 

to which agencies have implemented telework as a tool for continuity and 

emergency planning, and the information available on costs and benefits 

of telework programs.2

As required in the act, executive agencies are to designate a TMO. 

According to OPM guidance, the TMO develops telework policy, serves 

as a resource for teleworkers and their managers, and advises the CHCO 

on the agency’s telework matters. OPM guidance stresses that the TMO 

position encompasses more than administrative responsibilities. The 

TMO is the single agency official accountable for that agency’s telework 

program and its compliance with the act. Agencies may also designate a 

telework coordinator to implement the day-to-day operations of the 

telework program. 

The act requires OPM to work with agencies to implement the act’s 

requirements. This includes assisting agencies in establishing appropriate 

qualitative and quantitative measures and teleworking goals. Additionally, 

the act charges OPM with providing telework guidance on pay and leave, 

agency closure, performance management, official worksite information, 

recruitment and retention, accommodations for employees with 

disabilities, and maintaining a central telework website, 

www.telework.gov. 

The act also requires OPM to issue an annual report to Congress on the 

status of telework in the federal government.3 OPM has surveyed 

 2

See GAO, Federal Telework: Better Guidance Could Help Agencies Calculate Benefits 

and Costs, GAO-16-551 (Washington, D.C.: July 15, 2016); Federal Telework: Program 

Measurement Continues to Confront Data Reliability Issues, GAO-12-519 (Washington, 

D.C.: Apr. 19, 2012); Emergency Preparedness: Agencies Need Coordinated Guidance 

on Incorporating Telework into Emergency and Continuity Planning, GAO-11-628 

(Washington, D.C.: July 22, 2011); and Human Capital: Telework Programs Need Clear 

Goals and Reliable Data, GAO-08-261T (Washington, D.C.: Nov. 6, 2007).

3

Specifically, OPM, in consultation with the CHCO Council, is to report to House and 

Senate oversight committees on the telework programs of each executive agency.

Telework Enhancement 

Act of 2010
Page 5 GAO-17-247 Federal Telework

executive agencies with an annual data call to fulfill its role in reporting on 

progress towards telework related goals to Congress.4 While there are 

many ways to assess telework program success, the act requires OPM to 

report on agencies’ goals related to increasing participation rates in their 

telework programs, whether or not the agencies met their goals, and if 

not, what actions agencies are taking to identify and eliminate barriers to 

maximizing telework opportunities.5 The information collected by OPM 

can shed light on the barriers agencies may face in implementation, such 

as managerial resistance or technology limitations. While we have 

previously reported on data limitations related to OPM’s annual telework 

reports, the reports do provide useful context about the status of telework 

in the federal government and are comprehensive sources of information 

on telework in the executive branch.6 OPM reports that the number of 

federal employees teleworking has increased more than 40 percent since 

fiscal year 2012. Table 1 shows the number of teleworkers in the federal 

government, as reported in OPM’s annual Status of Telework in the 

Federal Government reports to Congress.

Table 1: Reported Number of Federal Employees Participating in Telework, Fiscal Years 2012-2015

FY 2012 FY 2013 FY 2014 FY 2015

Federal employees participating in telework 301,372 364,779 383,924 427,450

Source: GAO analysis of the Office of Personnel Management’s (OPM) Status of Telework in the Federal Government reports, FY 2012 - FY 2015. | GAO-17-247

Note: Not all agencies provided OPM with data on teleworkers each fiscal year for inclusion in the 

annual Status of Telework in the Federal Government reports. The total number of federal employees 

teleworking may be higher than the totals reported.

OPM has identified two general types of telework: routine telework and 

situational telework. Routine telework is telework that occurs as part of an 

ongoing, regular schedule. Routine telework may be part time or full 

time.7 The key feature of routine telework—also referred to as continuing, 

 4

OPM did not conduct a data call in 2014; instead OPM requested data for both fiscal 

years 2014 and 2015 in the 2015 data call. 

5

The act requires agencies to establish goals to increase participation, to the extent 

practicable or necessary. The act also requires OPM to report on other telework goals 

agencies may have established.

6

In 2012, we reported that OPM had been concerned about the reliability of telework data 

it received from executive agencies over the prior decade. GAO-12-519.

7

Full-time telework is also referred to as remote work and may require additional 

authorization or changes to the employee’s personnel records. 

Types of Telework 

Arrangements
Page 6 GAO-17-247 Federal Telework

regular, fixed, or recurring—is that it occurs on a predictable schedule. In

contrast, situational telework is approved on a case-by-case basis, and 

occurs outside of a routine telework schedule. Situational telework often 

occurs in response to a specific event such as inclement weather. 

Situational telework is also referred to as ad hoc, episodic, intermittent, 

and unscheduled telework.8 Situational telework may be approved for 1 

day or a number of days. For example, short-term telework is situational 

telework that occurs continuously for a finite number of days. Employees 

participating in short-term arrangements (e.g., because recuperating from 

surgery, maternity reasons, etc.) typically do not have in-office days; they 

work a full or part-time schedule from their homes. Before an employee 

can participate in any telework arrangement he or she must be approved 

to telework. 

The act requires OPM to report agencies’ progress towards meeting 

telework goals, such as telework participation rates; however, telework 

had existed at federal agencies before the act’s passage. As previously 

mentioned, for this review we included Education, GSA, Labor, and SEC 

as our case study agencies based on telework participation rates and 

agency size. Table 2 shows the average number of individuals 

teleworking for the pay periods that include September 30, 2015 through 

May 31, 2016.

 8

Unscheduled telework is a specific form of telework associated with OPM’s dismissal and 

closure policy that allows employees in the Washington, D.C. area to work from home or a 

nearby alternative location when OPM announces a modified operating status due to 

inclement weather or special events that severely affect commuting.

History of Telework at Four 

Case Study Agencies
Page 7 GAO-17-247 Federal Telework

Table 2: Average Number of Teleworkers and Hours Teleworked per Pay Period at Four Agencies, September 30, 2015—May 

31, 2016

Department of 

Education

General Services 

Administration

Department of 

Labor

Securities and 

Exchange 

Commission

Total employees (as of May 31, 2016) 4,350 11,255 15,738 4,657

Total number of telework agreements (as of 

May 31, 2016)

4,271 10,057 9,851 4,077

Average number of individuals teleworking 

per pay period

2,572 7,358 6,656 2,617

Average hours teleworked in a pay period 

per teleworker 

28.1 32.3 24.1 25.9

Source: GAO analysis of agency telework data. | GAO-17-247

According to Education officials, Education’s telework program began in 

1994 and became permanent in 2000. After the act was enacted, 

Education drafted a telework policy and notified all employees of their 

eligibility to participate in telework, officials stated. Education finalized its 

official telework policy in 2015. Education’s telework policy is set at the 

department level. The department’s components have some discretion in 

applying the rules set in the policy. Education has a negotiated collective 

bargaining agreement covering telework with one union that represents 

Education employees.

According to GSA officials, GSA began allowing informal telework in the 

early 1990s and developed its first telework policy in the mid-1990s. In 

2008, GSA developed and updated its official telework policy. The policy 

applied general criteria to eligibility and participation that, according to 

GSA, were later mandated by the act. In October 2011, GSA further 

updated its telework policies to fully comply with the act, officials said. 

GSA allows for telework up to and including full-time telework. GSA has a 

negotiated collective bargaining agreement that covers telework with 

each of the two unions that represent GSA employees nationwide.

Education

GSA
Page 8 GAO-17-247 Federal Telework

According to Labor officials, Labor’s telework program dates back to the 

1990s. Labor officials stated that when the act passed, Labor officials 

reviewed its telework program to ensure it complied with the act’s 

provisions. Labor has not changed its telework policy significantly since 

2010. While its telework policy is set at the department level, subagencies 

within Labor have discretion in interpreting and applying the policy, so 

long as it aligns with the department’s policy. Labor has negotiated 

collective bargaining agreements covering telework with three unions that 

represent its employees.

According to SEC officials, SEC launched its first official telework 

program in 2002, but had allowed telework more informally since the mid1990s. In 2007, SEC negotiated a new collective bargaining agreement 

with the one union that represents SEC employees. SEC officials said this 

agreement included an expanded telework pilot program that allowed for 

telework up to 5 days per week for certain employees. In 2013, SEC 

made the expanded telework pilot program permanent and expanded 

telework to others within the agency. SEC sets telework policy at the 

commission level. 

Standards for Internal Control in the Federal Government provides 

guidance for establishing and maintaining an effective internal control 

system in federal agencies.9 Internal control comprises the plans, 

methods, policies, and procedures used to fulfill the mission, strategic 

plan, goals, and objectives of an agency. Internal control is a process 

affected by the agency’s oversight body, management, and other 

personnel who provide reasonable assurance that the objectives of the 

agency will be achieved. These objectives and related risks can be 

broadly classified into one or more of the following three categories:

• Operations – Effectiveness and efficiency of operations

• Reporting – Reliability of reporting for internal and external use

• Compliance – Compliance with applicable laws and regulations

To be effective, an agency’s internal control system must incorporate a 

series of actions and activities that occur throughout its operations and on 

 9

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014).

Labor

SEC

Federal Standards for 

Internal Control
Page 9 GAO-17-247 Federal Telework

an ongoing basis. Once in place, internal control provides a reasonable, 

but not absolute, assurance of meeting those objectives. 

As related to telework, management is responsible for adapting the 

internal control standards to develop activities and processes that allow 

the agency to achieve its telework policy goals. The activities adapted by 

the agency should help staff carry out specific program activities 

according to its telework policies and procedures. For this report, we 

limited our examination of internal controls to specific activities, 

processes, and policies that help the four case study agencies comply 

with the act. We also examined specific internal controls designed to help 

the four case study agencies achieve their telework goals as expressed in 

case study agencies’ individual telework policies.

The act sets out basic requirements for agencies for (1) telework 

eligibility, participation, and notification; (2) telework agreements; and (3) 

training. Furthermore, OPM also provides guidance on notifying newly

hired employees of their eligibility to telework. We reviewed the controls 

and processes that our four case study agencies had in place to help 

ensure they comply with the act and adhere to OPM guidance and other 

agency telework policies. While controls and policies varied for each 

agency, the agencies all met the act’s requirements and followed the 

same general process for approving telework agreements.

Selected Agency 

Telework Programs 

Reflect Requirements 

of the Act, but Some 

Controls Are Not 

Documented and 

Agencies Face Some 

Barriers to Increasing 

Participation

Case Study Agencies’ 

Telework Eligibility 

Processes Were 

Consistent with Legal 

Requirements, but Some 

Agencies Lack Controls 

for Timing of Manager 

Training 
Page 10 GAO-17-247 Federal Telework

The telework policies of all four case study agencies comply with the 

eligibility and participation requirements noted in the act. The act required 

agencies to determine all employees’ eligibility for telework and notify 

employees of their eligibility no later than 180 days after enactment. In 

keeping with the recognized importance of telework, the act describes the 

limited situations in which employees are ineligible to telework instead of 

prescribing eligibility.10 The act also describes situations in which 

participation in telework may be limited or not authorized. Beyond these 

exceptions, the act authorizes agencies to determine specific employees’ 

eligibility to participate. 

Education, Labor, and SEC designed additional policies to clarify when 

employees were either ineligible or could not participate in telework. 

GSA’s policies did not have additional eligibility or participation 

requirements. As noted in its telework policy, GSA supports the broadest 

possible use of telework. For example, GSA required all employees to 

have a telework agreement. Even if GSA employees choose not to 

telework, they may be required to have an agreement authorizing 

telework in the event of an unexpected need to telework.11 Figure 1

shows the 4 case study agencies’ policy compliance with the act’s 

eligibility and participation requirements, as well as additional related 

policies.

 10The act identifies 2 categories of employees who are ineligible for telework: employees 

who have been officially disciplined for absences without permission for more than 5 days 

in any calendar year or employees officially disciplined for viewing, downloading, or 

exchanging pornography on a government computer, or while performing official duties in 

violation of executive branch standards of conduct. 

11GSA’s telework agreement application includes the option of declining to telework. 

However, employees declining to telework may still be required to telework during an 

emergency situation if they are designated as emergency employees.

Telework Eligibility 

Determination and Notification
Page 11 GAO-17-247 Federal Telework

Figure 1: Telework Eligibility and Participation Criteria for Four Agencies

Note: Blank cells in the figure indicate additional telework eligibility or participation criteria not 

included in an agency’s telework policies.
Page 12 GAO-17-247 Federal Telework

The act required agencies to notify all employees of their eligibility to 

telework within 180 days of enactment.12 OPM reported in 2012 that most 

agencies required to make this notification did so within the given time 

frame. While the act does not specify when newly hired employees must 

be notified of their eligibility to participate, OPM guidance provides that 

agency policies should provide for notification of newly hired employees 

within a reasonable time frame. Officials at Education, GSA, and Labor 

said they include information on telework eligibility in employment 

announcements.13 According to agency officials at the four case study 

agencies, newly hired employees are informed of their eligibility in new 

employee orientation or during the onboarding process.14 SEC officials 

said all new employees are required to take telework training at which 

time employees are again informed of their eligibility. We heard in all of 

our focus groups with teleworkers that employees were notified through a 

variety of methods including agency-wide notices, union notifications, 

discussions with a supervisor, newsletters, intranet sites, and direct email notification. 

The act requires agencies’ employees to enter into a written telework 

agreement with an agency manager before they can telework.15 The 

telework agreement is to outline the specific work arrangement agreed 

upon between employee and supervisor. With slight variations, the 4 case 

study agencies generally follow the same telework approval process, as 

shown in figure 2.

 12Our review did not include whether or not our case study agencies took these initial 

actions within the time period prescribed in the act.

13Employment announcements give information on the eligibility of the position not the 

employee. GSA officials said they conducted a mass review of all positions and notified 

employees of the results in 2008 when the agency updated its telework policy. Education 

and Labor officials also said they conducted a mass review after passage of the act, and 

notified all employees of their eligibility.

14Officially, new Labor employees are to be notified within 60 days of being hired.

155 U.S.C. § 6502(b).

Telework Approval Process 
Page 13 GAO-17-247 Federal Telework

Figure 2: Telework Agreement Approval Process Example Flow Chart

Executive management at all four case study agencies require 

supervisors and, in one case, managers, to approve or deny telework 

applications. At GSA, Labor, and SEC, first-line supervisors are 

responsible for approving or denying agreements. At Education, first-level 

supervisors recommend approval or denial to second-level managers, 

who make the final decisions. Employees at Education, GSA, and SEC 

submit agreements to their direct supervisors or managers through 
Page 14 GAO-17-247 Federal Telework

electronic approval systems.16 Conversely, Labor’s telework application 

system is largely paper based. Labor employees submit paper 

agreements or electronic versions of paper applications to their direct 

supervisor for approval. Finalized telework agreements are then 

maintained either by supervisors or centrally within the agencies, by

reporting to a telework program official or in an electronic telework 

agreement system.

The four case study agencies provide supervisors and managers 

guidance on making telework agreement decisions through telework 

policies. Telework policy at all four case study agencies allows 

supervisors to use their professional judgment or discretion within the 

parameters of the official policy. According to these policies, decisions to 

approve or deny telework agreements should be based on sound 

business and performance management principles. For example, to help 

managers determine the eligibility of both positions and employees, Labor 

has developed a decision tree that includes a series of yes or no 

questions that help managers and supervisors determine whether or not 

to approve an agreement. Supervisors are also encouraged to discuss 

telework with their employees before formal requests are made. 

Telework policies at each case study agency include procedures for 

employees to appeal the denial of a telework agreement. In all four of our 

focus groups with supervisors we heard that telework denials due to 

performance or conduct issues are rare. In addition, collective bargaining 

agreements at each agency afford bargaining-unit employees the ability 

to file a grievance if denied telework. Agency or union officials at each 

case study agency also told us that grievances are rare.

The act requires that agencies provide interactive telework training to 

employees eligible to telework and to managers of teleworkers. The act 

also requires that employees successfully complete the training before 

entering into a telework agreement.17 Consistent with this requirement, all 

4 case study agencies require employees to complete and document

telework training before signing a telework agreement. To verify 

completion, Education, Labor, and SEC require employees to include a 

 16According to Education officials, Education completed its transition from a paper-based 

system to an electronic system in July 2016.

175 U.S.C. § 6503(a). 

Telework Training
Page 15 GAO-17-247 Federal Telework

certificate of telework training when they submit a telework agreement for 

approval. At GSA, employees are not granted access to the online 

telework agreement system until they have successfully completed 

telework training. Figure 3 shows the training requirements for both 

employees and managers at the 4 case study agencies.

Figure 3: Telework Training Requirements at Four Agencies
Page 16 GAO-17-247 Federal Telework

The act also requires agencies to provide training to managers of 

teleworkers. OPM provides tools and policy guidance intended to improve 

agency telework programs. In its guidance to managers and supervisors, 

OPM defines 13 basic steps managers should follow to help them 

effectively implement a telework program. This guidance sequences 

training completion (step 3) before entering into telework agreements 

(step 6). See table 3 for the key steps for managing teleworkers as 

sequenced by OPM. 

Table 3: Office of Personnel Management’s Key Steps for Managers of Teleworkers

Step 1 Know the agency’s Telework Managing Officer and telework coordinator

Step 2 Know the agency’s policies and procedures

Step 3 Successfully complete training

Step 4 Determine employee eligibility

Step 5 Understand and assess the workgroup needs

Step 6 Enter into signed, written telework agreements

Step 7 Communicate expectations

Step 8 Base denials on business reasons

Step 9 Use good performance management

Step 10 Make good decisions about equipment

Step 11 Be fair and equitable

Step 12 Address safety and security responsibilities

Step 13 Participate in telework and lead by example

Source: Office of Personnel Management’s telework guidance for telework managers. | GAO-17-247

Consistent with federal internal control standards, persons in the key role 

of approving or denying telework agreements need to possess and 

maintain a level of competence that allows them to accomplish their 

assigned task in accordance with established policies. To achieve this 

competency, management provides training to help staff develop the 

knowledge, skills, and abilities needed to accomplish assigned tasks. If 

an agency ineffectively times training for managers or supervisors or

lacks controls for ensuring the training is complete before entering into 

telework agreements, then managers or supervisors might make telework 

decisions before having completed the training.

All four case study agencies require managers and supervisors to 

complete telework training, but not all require it before signing telework 

agreements. Education’s and SEC’s telework policies stipulate that 
Page 17 GAO-17-247 Federal Telework

managers and supervisors are to complete telework training before 

entering into telework agreements. However, officials at Education and 

SEC told us that managers and supervisors are required to take training 

within a specific timeframe, but not necessarily before entering into 

telework agreements.18 Telework policies at GSA and Labor do not 

mention the timing of training for managers or supervisors. However, 

because GSA’s automated telework application system requires 

personnel to successfully complete telework training before granting 

access to either the employee or the supervisor, GSA supervisors and 

managers must complete telework training before approving telework 

agreements.19 Labor officials told us that new managers have 6 months to 

complete telework training.

Other than at GSA, case study agency training systems contain the 

mechanisms to track manager and supervisors’ completion of training and 

are not directly linked to the telework program system. At these three 

agencies, the internal controls in place for training completion do not 

interface with the telework systems and therefore may affect the ability of 

telework program officials to readily track completion. SEC officials told us 

that after receiving a biannual report listing managers, supervisors, and 

employees who have not completed the training, the TMO will send a 

reminder to complete training. Education and Labor telework officials said 

they can request data from the learning divisions on telework training, but 

they do not have direct access to the information. 

Managers and supervisors at Education, Labor, and SEC who do not 

undergo telework training prior to entering into telework agreements may 

not fully understand the agency’s telework policy before approving or 

denying a telework request.20 Without adequate knowledge of agency 

policy, these managers and supervisors may not be performing their 

assigned tasks in a manner that helps their respective agencies achieve 

telework program goals and objectives. Given the expectation that 

managers will apply professional judgment when approving or managing 

 18New SEC managers have 60 days to complete telework training. New Education 

managers have 1 year to complete training.

19GSA officials told us that they conducted an agency-wide review of training completion 

in 2014, which showed that 99 percent of all GSA employees, including supervisors and 

managers, had completed training by the end of 2014.

20As required by the act, supervisors or managers who themselves telework must 

complete telework training before entering into an agreement to telework.
Page 18 GAO-17-247 Federal Telework

telework agreements, it is important that they have the appropriate 

training before entering into agreements.

According to OPM’s best practice guidance for managers and 

supervisors, telework agreements are living documents that should be 

regularly reviewed and re-signed by both the manager and teleworker. 

However, our four case study agencies were inconsistent in whether they 

review or document the review of ongoing telework agreements. As a 

result, the telework agreements on file may not accurately reflect current 

telework participation and may undermine the quality of the telework data 

the agency has. Federal internal control standards state that agencies 

should use quality information to achieve agency objectives. To help 

ensure that the information contained in telework agreements is accurate, 

management should design control activities to respond to the risk of 

having inaccurate data, including outdated information. In addition, 

according to federal internal control standards, documentation is a 

necessary part of an effective internal control system. Therefore, as 

applied to telework agreements, these standards suggest that agencies 

should document these reviews. Unless telework agreements are 

regularly reviewed and these reviews documented, the agencies face the 

increased risk of having inaccurate information.

The four case study agencies varied in how frequently they reviewed and 

documented their review of telework agreements.

• Education’s telework policy requires telework agreements to be 

renewed annually. Telework agreements expire 1 year after their 

approval date. According to Education officials, Education’s new 

telework agreement management system will require all telework 

agreements to be renewed annually during the same time period and 

for this review to be documented in the system. 

• GSA’s telework policy does not require telework agreements to be 

periodically reviewed once they are approved. Instead, GSA officials 

told us they remind supervisors to review agreements as part of the 

performance appraisal process. However, unless a change is made to 

the agreement in GSA’s electronic system, the telework agreement 

review is not documented. GSA officials said the agency is 

considering a new policy to require a periodic, documented review of 

telework agreements. 

Some Selected Agencies 

Do Not Review Telework 

Agreements Annually nor 

Document Annual 

Renewals
Page 19 GAO-17-247 Federal Telework

• Labor’s policy requires supervisors to annually review agreements to 

help ensure that agency and employee needs are being met, but 

documentation of the review is not required.

• SEC’s telework policy notes that employees may be required to 

recertify agreements to help ensure the accuracy of the information in 

the agreement, but a periodic and documented review is not required. 

SEC officials said they anticipate updating SEC’s telework agreement 

system sometime in 2017, including requiring that all telework 

agreements be renewed annually and the actions documented.

By not requiring telework agreements to be regularly reviewed, GSA, 

Labor, and SEC cannot be assured that the agreements reflect and 

support their current business needs. Of these agencies, Labor is most 

vulnerable to the risk of having inaccurate data on current telework 

agreements because it uses a largely paper-based manual system to 

manage its telework agreements. Given the likelihood of changes in work 

responsibilities and employee schedules over time, telework agreements 

not subject to a periodic and documented review may contain outdated 

information. In turn, that may result in management at these agencies 

using inaccurate data when making decisions that require telework data, 

such as for space planning, technology investments, or calculating the 

costs and benefits of telework.21 Also, employees at these agencies may 

be teleworking more often than approved or on days not specified in their 

agreements. Without a documented periodic review, these agencies lack 

an important internal control to better help ensure the accuracy of 

reporting, and to reasonably assure that policy guidelines are being 

maintained.

Case study agency officials and some focus groups with supervisors and 

teleworkers report that while managerial resistance to telework has gone 

down, and telework technology has improved in the 6 years since the 

act’s passage, they remain the key challenges to increasing telework 

participation. In its 2014 report to Congress, OPM reported that the top 2

reported barriers to employees’ ability to telework were management 

resistance (22 percent) and information technology (IT)/infrastructure (20 

 21We have previously reported on challenges with measuring the costs and benefits of 

telework, which rely in part on telework participation rates gleaned from telework 

agreement data. See GAO-16-551; Federal Telework: Office of Personnel Management’s 

2012 Telework Report Shows Opportunities for Improvement, GAO-13-298R 

(Washington, D.C.: June 28, 2013); and GAO-12-519. 

Managerial Resistance 

and Technology 

Challenges Continue to Be 

Barriers to Telework 

Participation
Page 20 GAO-17-247 Federal Telework

percent). In its 2016 report, OPM continued to cite managerial resistance 

and technology limitations as barriers to telework.

According to the act, OPM shall assist agencies in establishing 

appropriate qualitative and quantitative measures and teleworking goals 

as well as consult with GSA on policy guidance for telework technology 

and equipment.22 OPM asks each agency in its annual data call to report 

its goal for increasing telework participation to the extent practicable or 

necessary. OPM also asks agencies to explain whether or not they met 

the participation goal and, if not, what actions are being taken to identify 

and eliminate barriers to maximizing telework opportunities.23 We 

previously identified 25 key practices that federal agencies should 

implement in developing successful telework programs. This includes 2

practices that demonstrate managerial support for telework and 5

practices related to technology.24 OPM has previously identified 

managerial resistance and technology limitations as common challenges 

to agency telework programs, which is consistent with what we found at 

our four case study agencies, as discussed in detail below.

All four of our case study agencies described agency-wide activities 

demonstrating the senior leadership’s efforts to design and implement a 

successful telework program. However, in our focus groups with 

teleworkers and supervisors we heard a range of examples of how 

supervisors or managers discourage or support agency telework 

programs. Table 4 provides examples of how supervisors reportedly 

demonstrated this support and discouragement at our case study 

agencies. Officials at three of our four case study agencies and two focus 

groups with teleworkers and supervisors reported that some managers do 

 22As the lead agency in the management of federal workplaces, GSA provides 

governmentwide workplace guidance related to telework, among other areas.

23OPM is required to include this information concerning participation goals and results in 

its annual report to Congress. 5 U.S.C. § 6506(b)(2).

24GAO, Human Capital: Further Guidance, Assistance, and Coordination Can Improve 

Federal Telework Efforts, GAO-03-679 (Washington, D.C.: July 18, 2003). The practices 

related to managerial support are to obtain support from top management for a telework 

program and to address managerial resistance to telework. The practices related to 

technology are: (1) assess teleworker and organization technology needs; (2) develop 

guidelines about whether organization or employee will provide necessary technology, 

equipment, and supplies for telework; (3) provide technical support for teleworkers; (4) 

address access and security issues related to telework; and (5) establish standards for 

equipment in the telework environment.

Managerial Resistance
Page 21 GAO-17-247 Federal Telework

not support telework because they believe it contributes to poorer 

performance, as compared to the performance of in-office employees. 

Table 4: Examples of How Supervisors and Managers Support and Discourage Telework Participation

Examples of Supporting Telework Examples of Discouraging Telework

Hosting annual telework weeks promoting the program Not allowing changes to agreed-upon telework schedules

Discussing the benefits of telework with new employees Not approving situational telework requests

Setting the example by teleworking Not allowing employees to call in to staff meetings

Allowing for flexibility with and changes to telework schedules Limiting the number of telework days allowed

Source: GAO analysis of focus groups with case study agency teleworkers and supervisors. | GAO-17-247

Agency and union officials said the frequency of telework varied across 

the agencies and supervisors. All four agencies noted in their telework 

policies that some supervisor discretion should be used when approving 

and monitoring telework agreements, but some agency and union officials 

said the resulting variation in telework usage contributed to a perception 

that the agency was inconsistently implementing the telework program. 

We heard from some union officials and focus groups with teleworkers 

that employees sometimes assumed that supervisors were approving 

telework based on favoritism or other reasons not supported by agency 

policy. Agency and union officials did not characterize the extent to which 

supervisors or managers were discouraging telework, partly because 

none of our case study agencies had conducted any recent agency-wide 

surveys on telework. We also heard at one focus group with teleworkers 

that employees did not always feel comfortable voicing concerns publicly 

for fear of negative consequences for their careers. However, if 

employees are not provided an opportunity to voice their concerns without 

concern for negative consequences to their jobs, agencies may be 

missing an opportunity to better identify and address barriers to telework, 

including managerial resistance. Addressing managerial resistance could 

help increase telework participation rates by reducing inconsistencies in 

how agency telework policy is applied. 

According to federal standards for internal control, management, along 

with oversight from the oversight body, should determine through an 

evaluation process the extent to which deviations are occurring that would 

prevent the organization from achieving its objectives. Although OPM is 

not in an oversight capacity, given the requirements the act has placed on 

OPM to assist agencies, OPM can help ensure that the agencies have 

the appropriate tools and processes to assess barriers to telework and 
Page 22 GAO-17-247 Federal Telework

develop solutions to address them. OPM officials said organizations that 

are the most successful at telework are those that incorporate telework 

throughout agency operations and policies as opposed to simply having a 

written policy on telework. 

Case study agency officials said technology issues remain a challenge to 

their telework programs’ success. We heard at ten of our eleven focus 

groups with supervisors and teleworkers that teleworkers have 

experienced challenges accessing needed equipment and applications. 

Sometimes this limits the type of work that could be done while 

teleworking. Seven of these focus groups discussed how network 

connectivity or access was a challenge, including having to repeatedly log 

on to the agency network after being disconnected and spending time 

getting assistance from their respective agencies’ IT help desks. One 

focus group with supervisors reported that when IT challenges arose, 

supervisors may have to cover teleworking employees’ daily tasks while 

the employee resolved the IT issues. We also heard at some of the focus 

groups that teleworkers and supervisors discussed what resources and 

tools the teleworker would need to perform work activities while 

teleworking, and how to address any telework technology-related 

problems. For example, we heard at one focus group that if a teleworker’s 

phone or other telework-related technology was not working properly, the 

teleworker may be expected to return to the office to work until the issue 

could be corrected.

Case study agency officials described a number of actions to address 

telework technology challenges. For example, these agencies provide 

dedicated help desk support to teleworkers; provide equipment, including 

webcams, to teleworkers; and have upgraded IT systems to support 

telework. GSA officials said they focus IT investments on mobile 

strategies that allow employees to work from anywhere. Labor officials 

said they have upgraded IT to expand the number of programs supported 

remotely. SEC officials said they provide employees who telework 3 days 

a week or more with laptops, monitors, and printers to use in their 

telework location. SEC officials also said that in 2015, they introduced 

new tools, including phones with integrated cameras and upgraded 

videoconference equipment, which have helped enable more 

collaboration, among both teleworkers and employees across their 11 

field offices. 

We heard at all seven focus groups with teleworkers that teleworkers do 

not always have access to, or were not aware of, the IT tools available to 

teleworkers. For example, one focus group reported that some newly 

Technology
Page 23 GAO-17-247 Federal Telework

issued laptops at GSA did not have webcams. GSA officials confirmed 

that a recent order of laptops did not include webcams. Also, while 

external webcams were available to these employees, officials were 

unsure if the affected employees had been notified about how to request 

one. 

GSA officials said they had recently surveyed teleworkers about 

technology issues to assess the user experience and determine if there 

was capacity for additional telework. Education officials said they have 

solicited feedback from employees during training, which identified IT 

challenges for the telework program, but had not conducted other surveys 

on telework IT. Labor and SEC officials said they have not surveyed their 

employees about their IT needs or experiences. However, these case 

study agency officials said they conduct IT tests to monitor their networks’ 

abilities to handle telework needs and identify areas needing 

improvement.

Case study agency officials told us that OPM telework guidance generally 

met their needs, although some agencies would like more clarity on 

OPM’s guidance on unscheduled telework.25 In accordance with the act, 

OPM provides telework guidance to agencies on its website, 

www.telework.gov. The website covers a number of areas including 

agency closure.26 OPM officials said they also have had multiple 

meetings with TMOs and coordinators to clarify its meaning of 

unscheduled leave.27 They added that agencies should treat unscheduled 

telework the same as unscheduled leave. Officials also stated that since 

OPM introduced the concept of being telework ready, employees are 

expected to telework when there is an adverse weather event. This has 

led to less confusion about what agencies should do. 

 25Officials at one case study agency also noted the need for guidance on calculating costs 

and benefits of telework. We reported on this and made recommendations to OPM on 

providing such guidance in GAO-16-551.

26As required by the act, OPM also provides guidance on a number of topics, including 

pay and leave, performance management, official worksite, recruitment and retention, and 

accommodations for employees with disabilities. 5 U.S.C. § 6504(b)(1).

27Unscheduled leave is the ability for non-emergency employees to use leave, as 

appropriate, when OPM announces a modified operating status due to inclement weather 

or special events that severely impact employees’ ability to report to or remain in the 

office. Office of Personnel Management, Washington, D.C., Area Dismissal and Closure 

Procedures (Washington, D.C.: Dec. 2015).

Case Study Agencies 

Report Being Generally 

Satisfied with OPM’s 

Telework Guidance
Page 24 GAO-17-247 Federal Telework

Education and Labor officials said that OPM’s announcements of

unscheduled telework and unscheduled leave have created difficulties for 

them. These agency officials told us that employees assume OPM’s 

announcement allows them to telework even though agency policy 

requires employees to either request permission to telework or notify their 

supervisors of their intentions to telework. To decrease the confusion, 

Labor communicates with employees to remind them of the agency policy 

requiring them to notify their supervisors ahead of known continuity of 

operations (COOP) events, such as weather-related closures. Labor 

officials also encourage managers to speak with employees ahead of a 

known event to work out details of telework or leave in advance. In 

addition to sending notifications to all employees ahead of known COOP 

events, Education advises supervisors to have procedures and guidance 

in place beforehand when inclement weather or other possible closures 

are expected. Education officials said they would like OPM to more 

strongly emphasize the need for employees to follow their agency’s policy 

in its announcements.

OPM officials said that when OPM receives multiple questions on a 

particular area, OPM usually issues clarifying guidance to all agencies. If 

a question comes up often enough, OPM officials said the topic is 

included on OPM’s Frequently Asked Questions page at telework.gov. 

For example, in August 2016, OPM revamped the site to include answers 

to specific questions concerning unscheduled telework and unscheduled 

leave.

Selected Agency 

Telework Policies and 

Supervisors’ 

Strategies Enable 

Agencies to Manage 

for Results 
Page 25 GAO-17-247 Federal Telework

Consistent with the act, all four case study agencies have developed 

internal controls designed to help ensure employee and organizational 

performance is maintained with telework. The act calls for agencies to

establish performance related internal controls by making performance a 

criterion for continued program participation. Specifically, the act states 

that telework policies should ensure that telework does not diminish 

employee performance or agency operations.28 It also requires agencies 

to ensure that teleworkers and nonteleworkers are treated the same for 

the purposes of performance appraisals, among other management 

activities.29 In addition to the requirements of the act, three of the four 

case study agencies had additional performance management controls 

related to employee telework eligibility. For example, some agencies 

limited telework for new employees and those employees on a 

performance-improvement plan. Figure 4 shows performance-related 

controls included in each case study agency’s telework policy.

 28The act also states that agencies’ telework policies shall “provide that an employee may 

not be authorized to telework if the performance of that employee does not comply with 

the terms of the written agreement between the agency manager and that employee.” 5 

U.S.C. § 6502(b).

29Other areas where teleworkers and nonteleworkers are to be treated the same are 

training, rewarding, reassigning, promoting, reducing in grade, retaining, and removing 

employees; work requirements; and other acts involving managerial discretion. 5 U.S.C. § 

6503(a)(3).

Policies Include Internal 

Controls Designed to 

Maintain Performance and 

Consistent Performance 

Expectations 
Page 26 GAO-17-247 Federal Telework

Figure 4: Internal Control Objectives for Performance Management at Four Agencies 

Supervisors at all four case study agencies may reduce or revoke 

telework participation if an employee’s performance declines.30 We heard 

in all of our focus groups with supervisors that denying or limiting telework 

for performance reasons was rare. Many supervisors said they have 

never done so. We heard at some focus groups with supervisors that 

supervisors assess whether a teleworking employee’s performance has 

declined through performance reviews and monitoring work flow. We 

have previously reported that day-to-day performance management 

 30Agencies allow employees whose telework agreements have been revoked to apply for 

new telework agreements once performance has improved sufficiently.
Page 27 GAO-17-247 Federal Telework

activities like those discussed below can help marginal staff improve 

performance.31

The act requires that teleworkers and nonteleworkers be treated the 

same for the purposes of work requirements, performance appraisals, 

and promotions, among other managerial decisions.32 We heard from 

agency officials and in ten of our eleven focus groups with teleworkers 

and supervisors that telework status did not affect performance 

expectations. Some agency officials, supervisors, and teleworkers also 

said that employee performance problems were generally not specific to 

telework status. For example, we heard at two of four focus groups with 

supervisors that teleworkers with performance problems typically have 

them when in the office as well. Further, teleworkers cited personal 

benefits that they believed improved their performance. For example, we 

heard at all of our focus groups with teleworkers that employees often felt 

more productive, were able to concentrate on their work better, and 

experienced fewer interruptions when they teleworked. 

Supervisors in our focus groups described numerous strategies and 

resources they use to supervise and stay connected with their 

employees, including teleworking employees. For example, some 

supervisors required all employees to work in the office on a certain day 

so everyone could participate at weekly staff meetings in person. 

Supervisors in one focus group said they monitor employees’ work tasks 

online, regardless of telework status. Figure 5 shows the strategies and 

resources supervisors discussed using to manage teleworking 

employees. Because employees are not always collocated with their 

supervisors, these strategies can also be used for managing across 

locations, whether the employee is teleworking or not.

 31GAO, Federal Workforce: Improved Supervision and Better Use of Probationary Periods 

Are Needed to Address Substandard Employee Performance, GAO-15-191 (Washington, 

D.C.: Feb. 6, 2015).

325 U.S.C. § 6503(a)(3) 

Supervisors Cited Several 

Strategies and Resources 

for Managing Teleworkers
Page 28 GAO-17-247 Federal Telework

Figure 5: Strategies and Resources Managers at Four Case Study Agencies Use to 

Manage Teleworkers

Participants in our supervisor and teleworker focus groups spoke about 

the importance of discussing the expectations and preferences for 

communicating before beginning a telework arrangement. Supervisors 

and teleworkers in these focus groups also reported that they rely on 

phone calls, conference calls, e-mails, instant messaging, and, for some, 

videoconferencing to stay in contact when teleworking. In all of our focus 

groups with teleworkers we heard that telework status either had no effect

on how often employees communicated with their supervisor or, in some 

cases, led to increased communication. For example, one focus group 

discussed that some teleworkers communicate with their supervisors 

almost exclusively through e-mail or phone calls, regardless of telework 

status. We also heard in some of our focus groups that sharing calendars 

allows other team members to see what individuals were working on and 

when they were available to collaborate. 
Page 29 GAO-17-247 Federal Telework

Having robust telework data is important for managing and improving 

telework programs. Telework data can inform management decisions 

about investing resources, planning for COOP events, assessing

compliance with the act, and managing physical space needs. For 

example, Education officials said they use telework data to support 

space-reduction efforts by informing work space allocation decisions. 

SEC uses telework data to ensure those teleworking full-time are 

assigned to their proper duty station.33 Having reliable and timely data 

available to management for decision making and reporting is both 

important to managing agency telework programs and consistent with 

federal internal control standards.34

While our case study agencies varied in the methods used to collect, 

validate, and report telework data, all agreed that there are challenges to 

ensuring that telework data are accurate. Three of our case study 

agencies use an electronic telework agreement management system, but 

Labor’s manual system creates challenges in tracking the number of 

telework agreements. GSA and SEC use electronic systems for storing 

and tracking telework agreements. Education transitioned to an electronic 

system in 2016. The electronic telework agreement systems allow 

 33Generally, the official duty station (worksite) for an employee covered by a telework 

agreement is the location of the regular worksite for the employee’s position (where the 

employee would normally work absent a telework agreement), as long as the employee is 

scheduled to report physically at least twice each biweekly pay period on a regular and 

recurring basis to that regular worksite. However, the official worksite for an employee 

under a full-time telework agreement (under which the employee is not scheduled to 

report physically to the regular worksite on such a regular and recurring basis) is the 

location of the telework site (e.g., home or other alternative worksite), except in certain 

temporary situations. 

34GAO-14-704G.

OPM and Case Study 

Agencies Face 

Challenges in 

Collecting and 

Reporting Accurate 

and Consistent 

Telework Data

Agencies Faced Some 

Challenges in Collecting 

and Reporting Telework 

Data 
Page 30 GAO-17-247 Federal Telework

Education, GSA, and SEC to integrate certain internal controls into the 

telework agreement and data collection process. For example, the 

electronic systems can prevent employees from applying for telework if 

they have not completed training. They can also show supervisors their 

employees’ approved telework schedule when approving employee 

timesheets. 

In 2016, Education transitioned from tracking telework agreements on 

paper to using an electronic system where employees request telework 

agreements electronically. As part of this conversion, Education 

employees created new telework agreements in the electronic system. 

Education officials said this process will serve two key functions: first, it 

will convert telework agreements from paper files to electronic 

agreements; second, it will require all agreements to be renewed annually 

to ensure they continue to fit the needs of the employee or the agency 

unit. The electronic system will generate annual reminders to employees 

to renew their telework agreements. 

Unlike the three other case study agencies, Labor uses a manual, largely 

paper-based system. Labor officials said budget limitations had prevented 

them from procuring an electronic telework management system. Labor 

employees submit a written request for telework to their supervisor, either 

on paper or an electronic document. If approved and signed by the 

supervisor, the telework agreement is then forwarded to a telework pointof-contact (POC) in the employee’s division or region. The POC then logs 

the agreement into a spreadsheet and scans the agreement if it is 

submitted on paper. POCs supply telework data for their respective 

divisions or regions to the TMO quarterly via a spreadsheet; the TMO 

aggregates the data for management reporting and for inclusion in OPM’s 

annual reports. 

Labor officials said their data on telework agreements may be inaccurate 

due, in part, to this manual process and some individuals not following 

policy. For example, an employee is allowed to telework as soon as a 

supervisor signs the agreement. However, if the agreement is not 

forwarded on to the POC, it is not included in the telework data the POC 

transmits to the telework coordinator and TMO. Thus it may not be 

included in the telework data used by senior department leadership for 

decision-making and reporting purposes. Further, Labor officials said that 

they began collecting information on scheduled telework hours quarterly 

beginning in October 2015, but they did not yet routinely use the data 

because they are known to not reflect actual telework hours. Additionally, 

Labor officials said that many employees have situational telework 
Page 31 GAO-17-247 Federal Telework

agreements and use them to telework fairly regularly. Such situational 

telework would not be part of the scheduled telework hours reported. 

These officials also said they are working towards improving telework 

data quality to use more data to manage and expand the telework 

program. 

Because employees may adjust their telework agreement throughout the 

year, Labor’s manual process may prevent the agency from being able to 

have accurate real-time data on the total number of employees 

authorized to telework or accurate expectations for levels of scheduled 

telework. Labor officials said senior leadership reviews telework data at 

least quarterly. It uses the data for such decision-making purposes as 

COOP planning and assessing compliance with the act. If these data are 

inaccurate, then any decisions or internal controls based on these data 

may be less effective.

All of our case study agencies reported actual telework hours through 

employee self-reported data in electronic time and attendance tools. All of 

our case study agencies have employees input their bi-weekly work hours 

into their electronic timesheet and code for the number of work hours that 

were spent teleworking. Supervisors review and certify these timesheets, 

and the data are sent to OPM’s Enterprise Human Resources Integration 

(EHRI) system. Figure 6 shows the number of telework hours agencies 

reported for the pay periods ending October 3, 2015 through June 11, 

2016.
Page 32 GAO-17-247 Federal Telework

Figure 6: Total Telework Hours at Four Agencies per Pay Period, for Pay Periods Ending October 3, 2015—June 11, 2016

Our case study agencies, as well as OPM, agreed that self-reported 

telework data may be inaccurate because employees may be unsure how 

to correctly report telework hours. Some case study agency officials said 

they continue to field questions from employees about how to properly 

code for telework hours. This shows that confusion remains about how to 

report telework hours correctly. Case study agency officials also said they 

sometimes identify instances of incorrect telework time coding in periodic 

reviews of telework data. The case study agencies may require 

timesheets be corrected when discrepancies are identified. 
Page 33 GAO-17-247 Federal Telework

To address issues with improper recording of telework hours, telework 

officials at our case study agencies took a variety of training and 

communication approaches. For example, they said they stress the need 

for telework data accuracy in communications to supervisors, send 

frequent reminders to both teleworkers and supervisors on how to 

properly code for telework hours, and offer training and provide job aids to 

both teleworkers and supervisors on how to properly code telework time.

Supervisors in our focus groups identified some tools they use to help 

ensure their employees’ timesheets properly reflect their telework hours. 

For example, supervisors in one focus group said they refer to shared 

calendars to verify telework hours before certifying timesheets. At SEC, 

electronic timesheets are pre-filled with an employee’s telework schedule, 

so employees need only to change the telework time coding if there is a 

change to their telework schedule for the pay period, such as for 

situational telework. Supervisors at SEC can also run reports from their 

telework agreement system showing the telework schedule for all 

employees reporting to them. 

All four of our case study agencies periodically reviewed telework data to 

identify and address trends and outliers, as well as to assess compliance. 

Officials at the four case study agencies said they compare lists of 

individuals charging telework codes against a list of individuals with valid 

telework agreements on file. This helps ensure that everyone who 

teleworks is authorized to do so. Agency officials said that when they 

identify discrepancies, they notify the individual charging telework and 

potentially others, such as the supervisor and local telework coordinator, 

of the need for a valid agreement. For example, SEC officials said they 

identified 66 individuals teleworking without an agreement in their most 

recent review. They then followed up with the individuals to get a telework 

agreement in place. SEC officials said they also review situational 

telework hours to determine if employees are teleworking routinely and 

need a continuing telework agreement. According to agency officials at 

our four case study agencies, incorrectly coding work time and 

teleworking without a valid agreement were the most common types of 

telework data errors.

The case study agencies varied in how they collect and report telework 

data. GSA and SEC’s electronic telework management systems and 

electronic timesheets provide aggregated data reports. Officials at both 

agencies said they can readily collect and report the telework data 

required in OPM’s annual telework data calls and for other internal needs. 

Officials at Education and Labor said they had some difficulty reporting 
Page 34 GAO-17-247 Federal Telework

certain telework data. As previously discussed, Labor’s telework 

management process relies on manual quarterly reporting from 

subagencies which does not allow for a real-time assessment of some 

telework data. Education officials also said they have had difficulty with 

reporting annualized numbers of telework days per employee, as 

originally requested by OPM. The process of generating such data 

includes comparing data across several systems which is difficult and 

time-consuming. For this reason, Education has instead reported to OPM 

biweekly telework data for a full year. 

We identified errors in OPM’s 2014 and 2016 Status of Telework in the

Federal Government reports issued to Congress. The act requires the 

Director of OPM, in consultation with the Chief Human Capital Officers 

(CHCO) Council, to submit a report annually to Congress addressing 

telework at executive branch agencies.35 This report is to include data on: 

• telework participation and eligibility;

• methods for gathering telework data;

• explanations for changes in participation rates of 10 percent or more;

• agency goals for increasing telework participation;

• a discussion of whether agencies met prior year goals and, if not,

what actions are being taken to identify and eliminate barriers to 

maximize telework opportunities;

• an assessment of agencies’ progress towards meeting telework goals;

and 

• best practices in agency telework programs.36

 355 U.S.C. § 6506(b). The CHCO Council is composed of the Director of OPM, who 

serves as chairman; the Deputy Director for Management of the Office of Management 

and Budget, who acts as vice chairman; the CHCOs of the 15 Executive departments; and 

the CHCOs of 12 additional agencies designated by the OPM Director. Additionally, the 

Council has an Executive Director who coordinates and oversees the activities of the 

Council. The CHCO Council advises and coordinates the activities of members’ agencies 

on such matters as the modernization of human resources systems, improved quality of 

human resources information, and legislation affecting human resources operations and 

organizations.

36Agencies are to include goals for increasing telework participation to the extent 

practicable or necessary for the next reporting period. 

OPM’s 2014 and 2016 

Telework Reports to 

Congress Contained 

Some Incorrect Data
Page 35 GAO-17-247 Federal Telework

OPM issued a Status of Telework in the Federal Government report for 

fiscal years 2012, 2013, and 2014, reporting on data from the prior fiscal 

year. However, OPM did not issue the 2014 report until November 2015. 

OPM did not issue a fiscal year 2015 report. Instead, it issued a fiscal 

year 2016 report in September 2016, using data from fiscal years 2014 

and 2015.37 For the purposes of this report, we refer to the two most 

recent reports as the 2014 report and the 2016 report.

To gather data for these annual reports, OPM requests that telework 

officials at executive branch agencies and subagencies complete a data 

call that includes a series of questions on participation rates and telework 

goals, among other topics. OPM updated data standards in March 2012

to assist agencies in reporting telework data properly. It aggregates and 

analyzes the data in a spreadsheet and compiles them into the annual 

report. OPM officials said that to issue the report, they work within a tight 

timeframe and with limited staff resources. They stated, however, that 

data accuracy in these reports is a priority. Consistent with federal 

internal control standards, OPM provides agencies with a chance to 

review their data to help ensure they are accurate before completing the 

report. Specifically, these internal control standards state that agency 

management should communicate with and obtain quality information 

from external parties, and also use quality information (data that are 

relevant and from reliable sources) to meet agency objectives. However, 

despite this step, we identified some instances of inaccurate agency data 

being included in both the 2014 and the 2016 reports. Examples include 

the following: 

• In the 2016 report, Education’s telework participation goals are listed 

as 5 percent (the lowest percentage goal for agencies reporting one). 

This sharply contrasts with prior fiscal year goals of 85 percent. 

Education officials said that they interpreted the question in the data 

call as asking for the increase in the telework participation rate goal, 

and provided 5 percent as the agency response. The overall 

participation goal for fiscal year 2016 should have been 90 percent. 

Education officials also said that the data call instructions for this item 

and others are not always clear.

• In the 2014 report, OPM erroneously reported Labor’s participation 

goal. Labor officials said that when OPM provided them with a chance 

 37OPM, Status of Telework in the Federal Government Report to Congress, Fiscal Years 

2014-2015 (Washington, D.C.: September 2016). 
Page 36 GAO-17-247 Federal Telework

to review the data to be included in the 2014 report, Labor identified 

an error in its reported telework participation goal. Labor officials 

notified OPM of the error and supplied the corrected goal information. 

However, the published report did not include this corrected goal 

information. 

• In the 2014 report, OPM highlighted the fact that Labor reported 

having varying telework eligibility criteria among its subagencies. 

However, Labor’s actual telework eligibility criteria are uniform across 

the entire department, as had been reported in the prior annual report. 

Labor officials said that they had mistakenly supplied incorrect 

information to OPM on eligibility criteria for four subagencies. They 

added that they did not recognize the error until the final report was 

issued. 

Education officials said that although OPM sometimes follows up on data 

supplied in the data call, they believe it would be helpful if OPM reviewed 

agencies’ year-to-year data and followed up on any unexpected or large 

changes.38 For example, OPM did not contact Education to clarify why its 

overall telework participation goal dropped from 85 percent to 5 percent. 

Had OPM done so, Education officials could have clarified their response. 

We have previously found that OPM may be missing opportunities to 

improve upon data it reports by not following up with agencies on data 

differences.39

OPM officials, however, said that they do some data verification, but that 

they rely on the agencies to submit the correct data compliant with OPM’s 

data standards. OPM holds training sessions for each data call to answer 

questions telework officials may have about completing the data call. 

OPM officials also said that given the sheer volume of data that they 

receive, it is unrealistic for OPM to catch all reporting errors. However, 

given that OPM has aggregated data call responses into spreadsheets, it 

would be feasible to automate some comparisons of numeric data across 

these spreadsheets to identify changes in year-to-year data, and follow 

up with agencies on changes above a given threshold.

We also identified instances where the agencies failed to properly report 

data on telework eligibility. For example, in the 2014 report, Labor 

 38Education officials said OPM has done such outreach to Education once since instituting 

the data call.

39GAO, Labor Relations Activities: Actions Needed to Improve Tracking and Reporting of 

the Use and Cost of Official Time, GAO-15-9 (Washington, D.C.: Oct. 23, 2014).
Page 37 GAO-17-247 Federal Telework

reported the number of individuals eligible to participate in telework as 

higher than the number of total employees for several subagencies, with 

the difference sometimes as high as 32 percent. Labor officials explained 

that at the time of the 2013 data call—which provided the data used in the 

2014 report—they counted the number of positions eligible to telework, 

regardless of whether the positions were filled or not. This resulted in 

some subagencies reporting a higher number of eligible teleworkers than 

total employees. Labor officials said they have since changed the way 

they count the number of individuals eligible to telework. They included 

this adjusted methodology when providing data for the 2016 report. 

In the 2014 report, Education also reported the number of individuals 

eligible to participate in telework as higher than the number of total 

employees for several of its offices. According to Education officials, they 

last determined telework eligibility by position in 2011 and have reported 

the same number of eligible positions for all data calls since, including in 

the 2016 report. Education officials said that they interpreted the 

instruction on the data call as allowing for such static data reporting. OPM 

officials said that for the 2016 report they systematically compared the 

reported number of employees, eligible employees, and teleworking 

employees to identify situations in which the number of eligible 

employees exceeded the number of employees or when the number of 

teleworkers exceeded the number of eligible employees. They then 

contacted every agency where they found inconsistent data, including 

Education. According to OPM officials, they discussed with Education 

officials OPM’s expectation that agencies update their eligibility records 

regularly. However, OPM officials said they deferred to Education’s 

decision regarding what eligibility information it wanted to provide and 

published Education’s static eligibility data despite the accuracy issues 

identified. 

Agencies reporting on position eligibility and not individual eligibility 

overstate telework eligibility. As a result, they also understate other data 

points calculated from eligibility data, such as total participation rates.40

Further, the methodology of counting eligible positions does not take into 

account the additional telework eligibility requirements of the act at the 

individual level, such as personal conduct and performance history. 

Accounting for these requirements may further reduce the total number of 

 40To calculate total participation rates, agencies divide the total number of teleworkers by 

the total number of eligible employees. 
Page 38 GAO-17-247 Federal Telework

employees eligible for telework. The methodology Education officials 

described using for counting and reporting eligibility indicates that the 

data Education has been reporting to OPM do not comply with the act.

In the 2016 report, OPM recognized that some agencies have not 

revisited eligibility determinations since early implementation of telework. 

However, it concluded that this may result in agencies understating, not 

overstating, eligibility because more individuals may become eligible as 

agency telework policies and capacities expand. OPM officials said this is 

a reasonable conclusion because as agency telework programs mature, 

more individuals should become eligible. Furthermore, Federal Employee 

Viewpoint Survey data show that both self-reported eligibility and telework 

participation have been increasing over time. The version of the 2016 

report issued to Congress in September 2016 did not explain why some 

agencies report a higher number of eligible employees than total 

employees. However, OPM included some discussion of this data 

discrepancy in an updated version of the report posted on 

www.telework.gov in November 2016.41

Agencies are responsible for providing OPM with telework data that 

comply with OPM’s data standards, but OPM’s responsibility for reporting 

telework data annually is not limited to aggregating and reporting data 

directly from agencies without verifying its reliability. Consistent with 

federal internal control standards, OPM is responsible for taking 

reasonable measures to help ensure the accuracy of the information it 

reports and, where necessary, indicating in the report where data may be 

of questionable accuracy.42 Although OPM has taken some steps over 

the years to improve the accuracy of the telework data it reports, in

reviewing OPM’s two most recent telework reports we found that the 

report included some inaccurate data for two of our four case study 

agencies. Without clear and accurate data in these annual reports, 

Congress does not have all of the information necessary to conduct its 

oversight work and federal agencies and other users of the report do not 

 41OPM officials also said that they made additional minor editorial corrections to this 

updated version of the report based on the result of our review.

42GAO-14-704G. To allow OPM to achieve its objective of reporting telework data 

annually to Congress, internal control standards provide for OPM to gather relevant and 

timely data from agencies to include in reports sent to oversight bodies. Further, OPM 

should help ensure these data are appropriate, current, complete, accurate, accessible, 

and provided on a timely basis.
Page 39 GAO-17-247 Federal Telework

have an accurate picture of how telework is working across the federal 

government. 

In an August 11, 2016, memorandum, OPM announced to CHCOs and 

TMOs that it will begin using telework data in the EHRI system to 

automate the telework data collection process.43 OPM plans to use these 

data to meet the act’s annual reporting requirements to Congress, and to 

analyze cross-agency telework data to demonstrate links between 

telework and agency outcomes. While this will not eliminate the annual 

telework data call, according to the memorandum, it will reduce the 

manual reporting burden for agencies. OPM stated that it will continue to 

administer an annual data call to collect telework program information not 

available in EHRI, such as agency progress towards reaching telework 

goals and best practices for telework programs.

Although we have previously reported that EHRI data are sometimes 

incomplete or inaccurate, using these data could be helpful in identifying 

and addressing data quality issues.44 Further, OPM officials told us there 

are known problems with some telework data because agencies vary in 

how they report them. To address these limitations and help ensure 

agencies are following data standards, OPM set a timeline for testing and 

assessing the accuracy of telework data in EHRI over the course of fiscal 

year 2017. This process includes as a first step having agency TMOs and 

human resources staff examine telework data pulled from EHRI for one 

pay period to assess the accuracy of the data and determine any 

 43OPM developed EHRI, a data warehouse for human capital data, following the 

electronic government (e-Government) initiative, which was aimed at using IT to enhance 

access to and delivery of government information and service to citizens, business 

partners, and employees, and to improve the internal efficiency and effectiveness of the 

federal government. OPM designed EHRI to leverage its existing IT infrastructure, staff, 

and tools to integrate federal personnel, payroll, training, and retirement databases. OPM 

is tasked with supporting agencies’ human capital management activities, which includes 

ensuring that agencies have the data needed to make staffing and resource decisions to 

support their missions. 

44GAO, Federal Human Resources Data: OPM Should Improve the Availability and 

Reliability of Payroll Data to Support Accountability and Workforce Analytics, GAO-17-127 

(Washington, D.C.: Oct. 7, 2016). We have also discussed challenges with other aspects 

of EHRI data in Office of Personnel Management: Actions Are Needed to Help Ensure the 

Completeness of Political Conversion Data and Adherence to Policy, GAO-16-859 

(Washington, D.C.: Sept. 30, 2016), Federal Workforce: Opportunities Exist to Improve 

Data on Selected Groups of Special Government Employees, GAO-16-548 (Washington, 

D.C.: July 15, 2016), and GAO-15-9. 

OPM’s Plans to Report 

Telework Data from the 

Enterprise Human 

Resources Integration 

System May Improve Data 

Consistency
Page 40 GAO-17-247 Federal Telework

potential issues affecting data accuracy. OPM then plans to hold a series 

of meetings with agency TMOs, human resources directors, and payroll 

providers to discuss the steps and assistance needed to ensure telework 

data in EHRI are reported accurately. OPM officials said they plan to 

pursue an iterative process with agencies to verify the accuracy of 

telework data in EHRI.

OPM’s plan to use EHRI data for future telework data reporting is a 

positive step toward improving the accuracy of telework data and OPM’s 

ability to compare data year to year. For prior data calls, agencies 

supplied telework data from their own systems, which may have differed 

from data reported to EHRI. OPM officials told us they were unsure how 

much, if at all, agencies were adjusting their telework data across various 

data sources before responding to data calls. OPM did not compare these 

data to payroll data aggregated in EHRI because, according to OPM 

officials, doing so would have been inappropriate given the known 

limitations of the EHRI data at the time. According to OPM officials, 

reporting telework data directly from EHRI going forward will reinforce to 

agencies the importance of recording and certifying telework data 

regularly through payroll reporting. Further, reporting data consistently 

from one source for all agencies will allow the federal government to

compare telework data more consistently across agencies and across 

years.

Telework is an important tool agencies can use to realize benefits for both 

themselves and their employees. As technology and the nature of work in 

the federal government evolve, incorporating telework into agency 

operations and expanding telework participation could help agencies 

continue normal operations during adverse weather or other COOP

events, as well as attract and retain employees. But to have a telework 

program that can achieve these benefits and comply with the act’s 

requirements, the four case study agencies we reviewed must ensure that 

their telework policies, procedures, and other controls are implemented 

appropriately, and that the technology needed for employees to telework 

functions as it should. Documenting that those responsible for 

implementing agency telework policy are trained before doing so and 

reviewing telework agreements regularly can help these agencies ensure 

that they are applying their telework policies consistently, and improve 

telework data accuracy. Identifying pain points for teleworkers can also 

help agencies prioritize ways to improve and investments in their 

programs.

Conclusions
Page 41 GAO-17-247 Federal Telework

Because telework data are used across the government, such as by 

Congress for oversight, and by agencies for decision-making purposes, 

the four agencies and OPM need to ensure that the data they report 

accurately reflect the status of telework at federal agencies. Reporting 

and using data that either do not comply with the act or are known to be 

of questionable quality compromises these agencies’ abilities to 

effectively manage their telework programs, and limits the usefulness of 

OPM’s annual reports to Congress. OPM’s plans to use data in EHRI and 

a shorter data call instrument could improve telework data accuracy. 

However, OPM and agencies must also take steps to help ensure that 

these annual reports include only accurate data or clearly explain why this 

is not possible. 

To support the consistent application of agency telework policy 

throughout the agency, the Secretaries of the Departments of Education 

and Labor and the Chair of the Securities and Exchange Commission 

should implement controls to verify that supervisors have completed 

telework training prior to entering into telework agreements with their 

employees and that completion of this training is documented.

To help ensure that telework agreements accurately reflect telework 

participation, and to further ensure the accuracy of telework data reported 

internally and externally, the Secretary of the Department of Labor, the 

Administrator of the General Services Administration, and the Chair of the 

Securities and Exchange Commission should require documentation of 

regular or periodic reviews of all telework agreements in agency telework 

policies.

To improve the accuracy of telework data transmitted to OPM, the 

Secretary of the Department of Labor should direct the Chief Human 

Capital Officer to work with the Telework Managing Officer to develop and 

implement a plan to modernize Labor’s telework agreement tracking 

system to enable more timely access to accurate telework data.

To help ensure the employee eligibility data transmitted to OPM comport 

with what OPM is required to report under the Telework Enhancement Act 

of 2010 and accurately reflect the current number of employees eligible to 

telework, the Secretary of the Department of Education should direct the 

Telework Managing Officer to take the steps necessary to regularly 

update employees’ eligibility status. 

Recommendations for 

Executive Action
Page 42 GAO-17-247 Federal Telework

To provide additional guidance to agencies and encourage the elimination 

of barriers to increased telework opportunities consistent with the act, and 

to ensure the accuracy of telework information OPM annually reports to 

Congress, the Director of OPM should:

• develop tools to help agencies assess and analyze persistent barriers 

to telework, including managerial resistance, such as a survey or 

other feedback mechanism; and

• strengthen controls for reviewing, validating, and reporting telework 

data in annual Status of Telework in the Federal Government reports. 

Specifically, OPM should follow up with agency officials on data 

outliers, including significant changes in year-to-year data. 

We provided a draft of this report to Education, GSA, Labor, SEC, and 

OPM for review and comment. We received written comments from 

Education, GSA, SEC, and OPM which are reprinted in appendixes II, III, 

IV and V, respectively. Education, Labor, and OPM also provided 

technical comments, which we incorporated into the report as 

appropriate. Labor also commented on the recommendations addressed 

to it, which we summarize and discuss below.

Education, GSA, and SEC agreed with the recommendations in our 

report. GSA and SEC stated they are making changes to require a 

periodic and documented review of telework agreements. Education and 

SEC stated they will implement controls to help ensure supervisors

complete telework training before entering into telework agreements with 

employees. Education also agreed to take steps necessary to regularly 

update employees’ eligibility status and report data that meet the criteria 

in the act. 

Labor neither agreed nor disagreed with our recommendations but 

provided comments on the report’s recommendations. Labor stated that 

budgetary constraints have prevented it from employing an automated 

telework agreement system, as we noted in the report. We recognize this 

in our recommendation by stating Labor should modernize its telework 

agreement tracking system to allow for more timely access to accurate 

data, which can include changes other than implementing an automated 

system. Labor also stated that it has controls to monitor manager 

telework training and telework agreement review. We agree that Labor 

takes steps to monitor manager training and has a process for regularly 

reviewing telework agreements. However, these processes could be 

strengthened by requiring additional documentation.

Agency Comments 

and Our Evaluation
Page 43 GAO-17-247 Federal Telework

OPM did not concur with the two recommendations directed to it. For the 

first recommendation on creating tools to help agencies assess and 

analyze persistent barriers to telework, OPM agreed with our assessment 

of the value of such tools and their ability to help agencies increase 

participation rates. However, OPM stated it has fulfilled its responsibilities 

under the act through training, policy guidance, and tools for program 

evaluation and management, and that, given limited resources, it is not in 

a position to expand upon materials and tools for an area not required by 

the act. We agree that OPM has provided resources to agencies to help 

identify barriers to telework and are encouraged that it is developing 

additional tools. However, we disagree with OPM’s assertion that 

developing tools to address persistent barriers is not related to internal 

controls. Federal internal control standards state that to help ensure an 

agency is meeting its objectives management should identify, analyze, 

and respond to risks related to achieving objectives, such as by 

addressing deviations from established policies. Barriers to telework 

reflect a risk to an agency’s ability to meet the goals they have 

established for increasing telework participation, as directed in the act. 

And as noted in our report, some managers’ decisions to limit or deny 

employees’ ability to telework may be for reasons other than those 

outlined in the agencies’ policies, suggesting deviations from established 

policy that should be addressed. Because agencies and OPM continue to 

identify persistent barriers to telework participation, as did responses in 

our focus groups and discussions with agency officials, we continue to 

believe that OPM should play a key role in aiding agencies in assessing 

and analyzing, not just identifying, barriers to telework participation.

For the second recommendation, OPM said it recognizes the importance 

of data accuracy and states it takes reasonable steps to follow up with 

agencies to resolve possible reporting errors, but that agencies are 

ultimately responsible for providing complete and accurate data. OPM 

further states that the act does not obligate OPM to spend significant 

resources to independently validate agency telework data. We agree that 

OPM should not independently validate agency data, but OPM should 

take the steps necessary to identify and explain data outliers and 

limitations. Because OPM is the agency responsible for reporting telework 

data, OPM should ensure its annual reports to Congress include a clear 

discussion of data reliability limitations, as we have previously 

recommended. Following up on data outliers and large year-to-year 

changes can help OPM identify data errors that could be corrected by 

agencies and provide OPM with the opportunity to discuss data limitations 

with agencies. Including such information clearly in the annual telework 
Page 44 GAO-17-247 Federal Telework

reports to Congress can make them more useful to Congress and to 

others.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to OPM, 

Education, GSA, Labor, and SEC as well as to interested congressional 

committees and other interested parties. In addition, this report is 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-6806 or at jonesy@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VI.

Yvonne D. Jones

Director, 

Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-17-247 Federal Telework

This report identifies and examines (1) how selected agencies establish 

and monitor telework eligibility and participation, and comply with the 

requirements of and expectations included in telework agreements; (2)

the internal controls and practices at selected agencies that affect 

supervisors’ abilities to manage for results in the telework environment, 

and hold employees who routinely telework accountable for achieving 

results; and (3) the challenges selected agencies and the Office of 

Personnel Management (OPM) face in collecting and reporting telework 

data.

To address these objectives, we reviewed and used as criteria the 

Telework Enhancement Act of 2010 (the act), Standards for Internal 

Control in the Federal Government, OPM’s guidance and training on 

telework and performance management, and our prior work on agency 

telework programs. We also interviewed key OPM officials from 

Employee Services and Senior Executive Service and Performance 

Management as well as the Executive Director of the Chief Human 

Capital Officers (CHCO) Council.

To address all of our objectives, we selected the Department of Education 

(Education), General Services Administration (GSA), the Department of 

Labor (Labor), and the Securities and Exchange Commission (SEC) as 

case study agencies for our review. Because a case study approach does 

not allow for generalizable results, we limited our case study agencies to 

four to compare telework programs across agencies of varying sizes. We 

selected these agencies using size and telework participation rates as 

criteria. We reviewed OPM’s 2014 Status of Telework in the Federal 

Government Report to Congress (Fiscal Year 2013) and created a list of 

all of the agencies that reported telework data that year.

1 To ensure that 

our case study agencies would have a sufficient number of active 

teleworkers, we limited this list to agencies with more than 2,500 

employees. Using data from OPM’s report, the most recent available at 

the time of our analysis, we compiled a list containing data on each 

agency’s number of employees, number of employees eligible to 

telework, number of employees with telework agreements, percentage of 

employees with telework agreements, and percentage of employees who 

teleworked in fiscal year 2013. We also reviewed data from the 2015 

Federal Employee Viewpoint Survey (FEVS), the most recent data 

 1

At the time we were selecting agencies to include in our review, the 2014 report was the 

most recent report issued by OPM.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-17-247 Federal Telework

available at the time of our analysis, and incorporated data on telework 

frequency rates into our list of agencies.2 After building this universe of 

agencies and their associated telework data, we applied 3 filters to the 

list: 

• agencies where the percent of employees eligible to telework is 

greater than or equal to 50 percent;

• the percent of eligible employees with telework agreements is greater 

than or equal to 50 percent; and

• the percent of employees teleworking at least once per week is 

greater than or equal to 25 percent.

These filters produced a list of seven agencies. To compare and contrast 

telework programs of different sizes, we divided the remaining agencies 

into 2 groups: 1 of agencies with more than 10,000 employees and the 

other with fewer than 10,000 employees. We eliminated one large agency 

because it was negotiating its telework program with relevant labor 

unions, and had been the subject of recent reports on telework internal 

controls. For the smaller agencies, we rank ordered the agencies by the 

number of teleworkers as of February 2014, the most recent data 

available across the agencies. These filters produced GSA and Labor as 

the large agencies, and Education and SEC as the smaller agencies for 

inclusion as our case study agencies.

To address all of our objectives, we conducted a series of focus groups at 

our four case study agencies with groups of supervisors of teleworkers 

and groups of teleworkers. When discussing these focus groups 

throughout the report, we use the word some to mean more than two but 

fewer than six focus groups. To determine supervisor focus group 

participants, the agencies sent us lists of all supervisors and the agency, 

office, or division where they worked. We randomized the list using a 

random number generator and sorted the list in rank order. To avoid 

inviting individuals who work closely with each other to the focus groups, 

we chose from the list the first individual from each agency, office, or 

division, and created a list of alternates in the event the first individual 

could not participate. We then confirmed with the agencies that these 

 2

The FEVS is a tool that measures employees' perceptions of whether, and to what 

extent, conditions characterizing successful organizations are present in their agencies. 

Survey results provide valuable insight into the challenges agency leaders face in 

ensuring the federal government has an effective civilian workforce and how well they are 

responding. The FEVS includes questions on telework.
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-17-247 Federal Telework

supervisors on our invite and alternates lists met the following criteria: (1) 

they were not senior executives and (2) they supervised at least one 

employee with a regular telework agreement. We sent invitations to 

participate in the focus groups to the first 10 individuals who met our 

criteria. We then invited alternates for individuals who could not attend. 

Each focus group had between 6 and 8 participants.

To determine focus group participants for teleworkers, agencies sent us 

lists of employees, which included, at a minimum, the employee’s name, 

location, and whether they had a telework agreement. To ensure we 

could gather information from nonsupervisory employees, we removed 

from the lists, as necessary, any individuals who were supervisors or 

otherwise not covered by a collective bargaining unit. We also excluded 

individuals from the Offices of Inspector General. We additionally 

excluded individuals with only a situational telework agreement. We 

randomized the list using a random number generator and sorted the lists 

in rank order. Similar to supervisors, to avoid inviting individuals who work 

closely together, we chose from the list the first individual from each 

agency, office, or division. Also, to determine if employees similarly 

experienced telework in the field as in headquarters, we created two lists 

of potential focus group participants—one for employees who work in 

Washington, D.C., and one for employees who work in a regional or field 

office. For field employees, we chose the first individual from each 

location from the ranked list to participate. Because telework experiences 

can be influenced by an employee’s supervisor, we then requested from 

the agencies the name of the supervisor for those on our preliminary 

invitation list, and eliminated individuals from the invitation list if someone 

higher on the list worked for the same supervisor. For Education, Labor, 

and SEC, we held two focus groups for teleworkers, each with between 

four and six participants. For GSA, due to scheduling difficulties, we held 

one combined focus group of seven teleworkers from headquarters and 

the field.

To determine how case study agencies establish and monitor telework 

eligibility and compliance with requirements and expectations of telework 

agreements, we reviewed the act, OPM guidance, telework policies, 

telework training materials, blank telework agreements, and collective 

bargaining agreements. We interviewed agency officials responsible for 

telework policy and program implementation, including the Telework 

Managing Officer or the telework coordinator, to discuss telework policy, 

program implementation, internal controls, and OPM guidance on 

telework. We then compared agency policies to act requirements, OPM 

guidance, and Standards for Internal Control in the Federal Government 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-17-247 Federal Telework

to assess compliance. We discussed telework eligibility and notification at 

our focus groups with teleworkers and discussed reasons for denying

telework agreement applications with supervisors. We also interviewed 

OPM officials about OPM’s role in providing telework guidance to federal 

agencies.

To determine how supervisors at case study agencies manage for results 

in a telework environment and hold employees who routinely telework 

accountable for achieving results, we reviewed requirements of the act 

and agency policies, reviewed OPM and agency specific training 

materials on telework and performance management, and discussed 

agency performance management policy with case study agency officials. 

We also asked supervisors participating in our focus groups what 

strategies and resources they use to manage their teleworking 

employees, and what steps they take to help ensure telework does not 

diminish their employees’ performance. We asked participants at our 

teleworkers focus groups about how telework has affected their ability to 

meet performance goals, how their supervisor holds them accountable for 

achieving results while teleworking, and how the agency supports 

telework. We also spoke with representatives from the unions that 

represent employees at the four case study agencies to discuss any 

concerns the unions have heard about telework.

To assess the challenges the four case study agencies and OPM face in 

collecting and reporting telework data, we reviewed our prior work on 

OPM telework data reporting. We also reviewed OPM’s Status of 

Telework in the Federal Government Report to Congress (Fiscal Year 

2013) and OPM’s Status of Telework in the Federal Government Report 

to Congress (Fiscal Years 2014 and 2015). We requested case study 

agencies’ original telework data call submissions to OPM for fiscal years 

2013, 2014, and 2015, and compared these data to what OPM included 

in the final reports to Congress to identify any discrepancies. To report 

data on numbers of teleworkers and the average number of hours 

employees telework per pay period, we analyzed telework data from each 

of the case study agencies. We reviewed the data for outliers, reviewed 

agency documentation on how the agencies enter and maintain telework 

data, and interviewed agency officials. We determined these data to be 

reliable for the purposes of reporting reported telework hours and the 

number of individuals teleworking for a 9-month period between 

September 2015 and June 2016. We interviewed OPM and case study 

agency officials about the steps they take to collect, validate, and report 

telework data, and any challenges they may face in doing so. We also 

asked teleworkers in our focus groups how they record their telework 
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-17-247 Federal Telework

hours. In addition, we asked supervisors what challenges they may face 

to ensuring these telework hours are recorded and reported accurately.

We conducted this performance audit from November 2015 to February 

2017 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.
Appendix II: Comments from the Department 

of Education

Page 50 GAO-17-247 Federal Telework

Appendix II: Comments from the Department 

of Education
Appendix II: Comments from the Department 

of Education

Page 51 GAO-17-247 Federal Telework
Appendix II: Comments from the Department 

of Education

Page 52 GAO-17-247 Federal Telework

Appendix III: Comments from the General 

Services Administration
Appendix IV: Comments from the Security and 

Exchange Commission

Page 53 GAO-17-247 Federal Telework

Appendix IV: Comments from the Securities

and Exchange Commission
Appendix IV: Comments from the Security and 

Exchange Commission

Page 54 GAO-17-247 Federal Telework
Appendix V: Comments from the Office of 

Personnel Management

Page 55 GAO-17-247 Federal Telework

Appendix V: Comments from the Office of 

Personnel Management
Appendix V: Comments from the Office of 

Personnel Management

Page 56 GAO-17-247 Federal Telework
Appendix V: Comments from the Office of 

Personnel Management

Page 57 GAO-17-247 Federal Telework
Appendix I: Objectives, Scope, and

Methodology

Page 58 GAO-17-247 Federal Telework

Yvonne D. Jones, 202-512-6806 or jonesy@gao.gov

In addition to the contact named above, Chelsa Gurkin (Assistant 

Director), Miranda Cohen, Ann Czapiewski, Karin Fangman, Cheryl L. 

Jones, Danielle Novak, Steven R. Putansu, and Stewart W. Small made 

key contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments

GAO Contact 

Staff 

Acknowledgments 

(100416)
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