FEDERAL 

TELEWORK

Program Measurement 

Continues to Confront 

Data Reliability Issues

Report to the Subcommittee on Oversight 

of Government Management, the Federal 

Workforce, and the District of Columbia,

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

April 2012

GAO-12-519

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-519, a report to the 

Subcommittee on Oversight of Government 

Management, the Federal Workforce, and the 

District of Columbia, Committee on Homeland 

Security and Governmental Affairs, U.S. 

Senate 

April 2012 

FEDERAL TELEWORK 

Program Measurement Continues to Confront Data 

Reliability Issues

Why GAO Did This Study

The Telework Enhancement Act of 

2010 requires OPM to report to 

Congress on the degree of telework 

participation at executive agencies. To

meet this requirement, OPM collects 

information on agency telework 

programs through an annual survey, 

which it refers to as the data call. 

However, concerns exist about the 

reliability of these data. 

GAO was asked to assess OPM’s: 

(1) actions in response to the 

requirements of the act and 

(2) handling of identified data reliability 

issues in the 2011 telework data call. 

To address these objectives GAO

reviewed its previous reports 

addressing telework data reliability, 

and used the Office of Management 

and Budget’s guidance for federal 

surveys to review OPM’s (1) plans to 

collect telework participation data from 

agencies and (2) development of a 

data collection instrument. GAO 

interviewed key OPM officials about its

implementation of the 2011 data call. 

What GAO Recommends

GAO recommends that OPM 

(1) clearly report reliability limitations

with the 2011 telework data call in its 

June 2012 report to Congress and 

(2) continue efforts to improve data 

collection and gather information to

allow for the appropriate qualification of 

year-to-year comparisons and inform

users about the effects of data 

collection changes going forward. OPM 

partially concurred with the first 

recommendation. However, GAO 

believes it should report limitations in 

its annual report. OPM fully concurred 

with the second. OPM provided a

number of technical comments which 

GAO incorporated as appropriate. 

What GAO Found

To prepare for its reporting obligations under the Telework Enhancement Act of 

2010, the Office of Personnel Management (OPM) assembled the Interagency 

Telework Measurement Group, consisting of officials from several federal 

agencies, to assist in revising the telework data call—the survey OPM has used 

since 2002 to collect telework data from executive agencies. This group 

standardized key terms such as telework, employee, and eligibility to promote a 

common reporting methodology among the agencies. The revised telework data 

call also included changes to the time period for which OPM requested agencies 

report telework data, and included more extensive training for respondents. 

Because of changes made to the data call to allow OPM to meet requirements of 

the act and assist agencies in responding to the data call, OPM officials believe 

they will be able to provide to Congress an improved report on telework in June 

2012. However, these changes also mean that OPM officials will not be able to 

use participation and frequency data from the 2011 data call to compare to data 

from previous years and across agencies. OPM officials have noted that this 

could limit OPM’s ability to report agency progress in its first report to Congress.

The ability to compare with previous years is affected by: 

• agencies use of methods of varying reliability to collect telework data, and 

some agencies made changes to their data collection systems for the 2011 

data call. Executive agencies provide telework participation and frequency 

data by relying on estimates, counting telework agreements, or using 

automated time and attendance records. 

• modifications to the data call instrument, including changes to terminology 

and the time period during which telework data was requested. OPM officials 

said they expect these changes will improve the consistency of data. But if 

OPM reports progress based on data collected using changing terminology 

and from different time periods, the agency may reach erroneous 

conclusions.

Participants at the two data call training sessions may not have received the 

same reporting instructions, and uncertainty about whether all agency 

respondents attended training, created a risk that some respondents may be 

unaware of important terms and instructions. While some of the information 

provided at the two training sessions was similar, each session contained some 

new information, usually in response to questions raised at a previous session.

Future data call improvement efforts could result in a trade-off between the 

desire for maintenance of a consistent data series over time for comparison with 

previous data calls and a need to improve data collection. According to OPM, 

agencies will begin piloting automated telework data collection during 2012 and 

2013. OPM expects that this method of data collection will provide it more 

reliable data than other methods. However, these efforts to standardize methods 

for tracking telework data may result in changes to agencies’ methods of data 

collection. The 2011 data call, notwithstanding its limitations, will be useful to 

help OPM identify and understand major changes in reported participation data 

that could occur during a transition to automated data collection. View GAO-12-519. For more information, 

contact Yvonne D. Jones at (202) 512-6806 or 

jonesy@gao.gov. 
Page i GAO-12-519 Federal Telework Programs

Letter 1 

Background 3

OPM Revised the 2011 Telework Data Call to Prepare for Reporting 

under the Telework Enhancement Act of 2010 5

Various Methods of Data Collection and Ongoing Changes to the 

Data Call Make It Difficult to Assure Data Reliability and to 

Make Year-to-Year Comparisons 9

Conclusions 13

Recommendations for Executive Action 14

Agency Comments and Our Evaluation 14

Appendix I Objectives, Scope, and Methodology 16

Appendix II Revisions to OPM’s Telework Data Call to Collect Information to 

Prepare for Reporting under the Telework Enhancement Act of 2010 19

Appendix III Comments from the Office of Personnel Management 21

Appendix IV GAO Contact and Staff Acknowledgments 23

Related GAO Products 24

Table

Table 1: Principles Used to Assess the Data Call 17

Figure

Figure 1: Differences in Time Period of Data Requested and 

Reported between 2010 and 2011 Telework Data Calls 7

Contents
Page ii GAO-12-519 Federal Telework Programs

Abbreviations

EHRI Employee Human Resources Integration 

FAQ frequently asked questions

ITMG Interagency Telework Measurement Group

OMB Office of Management and Budget

OPM Office of Personnel Management

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-519 Federal Telework Programs

United States Government Accountability Office 

Washington, DC 20548

April 19, 2012

The Honorable Daniel K. Akaka

Chairman

The Honorable Ron Johnson

Ranking Member

Subcommittee on Oversight of Government Management, the

 Federal Workforce, and the District of Columbia

Committee on Homeland Security and Governmental Affairs

United States Senate

Congress has encouraged federal agencies to expand their use of 

telework by requiring that executive agencies establish telework policies, 

incorporate those policies into continuity of operations plans, and provide 

interactive telework training to employees and managers. The Office of 

Personnel Management (OPM) has reported telework can enhance the 

productivity and flexibility of federal employees; help recruit and retain a 

qualified workforce; and reduce real estate, overhead, energy, and 

environmental costs. The Telework Enhancement Act of 2010 established 

a statutory framework for implementing a comprehensive federal telework 

program.1

In 2010, OPM set a high-priority performance goal of increasing by 50 

percent the number of eligible federal workers who telework by fiscal year 

2011. To measure agency progress toward this and agency telework 

goals, OPM will use data it collects through an annual survey referred to 

as the data call. However, concerns have existed about the reliability of 

these data. According to OPM, in order to help agencies overcome 

barriers related to telework and raise federal telework participation rates, 

the agency needs reliable, systematically collected agency data.

The act requires executive agencies to establish and to 

implement a policy under which eligible employees may be authorized to 

telework. The act also requires OPM to report annually to Congress on 

the telework programs of each agency, including the level of participation 

in telework in each agency, each agency’s goal for increasing employee 

participation in telework, agency progress during the reporting period 

toward meeting telework goals, and reasons for significant increases or 

decreases from previous year telework participation.

 

1

Pub. L. No. 111-292, 124 Stat. 3165 (Dec. 9, 2010), codified at chapter 65 of title 5, 

United States Code.

 
 

Page 2 GAO-12-519 Federal Telework Programs

Because of the new telework reporting requirements in the act and the 

need for reliable data to assess the agencies’ progress in implementing 

their individual telework programs, you asked us to assess OPM’s:

• actions to respond to the reporting requirements of the Telework 

Enhancement Act of 2010, and

• handling of identified data reliability issues in the 2011 telework data 

call.

To answer these questions, we reviewed relevant reports and guidance 

published by OPM that describe the status of telework programs across 

executive agencies, and previous telework data calls and their 

instructions. We also reviewed our previous reports on telework and the 

reliability of OPM’s telework data. We identified the relevant generally 

accepted survey standards as promulgated by the Office of Management 

and Budget and compared OPM’s design and implementation of the 2011 

telework data call against these standards.

We interviewed the OPM officials responsible for the planning, design, 

implementation, and analysis of the 2011 telework data call. This included 

discussions on the role of the Interagency Telework Measurement Group 

(ITMG), the process for developing the definitions and key terms used in 

the data call, the training and assistance provided to executive agency 

officials responsible for completing the data call, and agency plans to 

address outstanding data reliability issues associated with the data call.2

We conducted this performance audit from June 2011 through April 2012 

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 

We were also able to simulate completion of the web-based data call that 

allowed us to respond to the data call in the same manner as the other 

agency respondents. This simulation gave us the opportunity to 

determine the ease of use of the online data call instrument, and whether 

there were any potential design or functionality issues that could affect 

the validity and reliability of the data.

 

2

The Interagency Telework Measurement Group consisted of officials from OPM, General 

Services Administration, United States Patent and Trademark Office, Department of the 

Navy, Defense Information Systems Agency, National Aeronautics and Space 

Administration, and Department of Energy.
 

Page 3 GAO-12-519 Federal Telework Programs

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The Telework Enhancement Act of 2010, enacted in December 2010, 

requires each executive agency to designate a telework managing officer, 

develop training programs, establish a telework policy, and submit an 

annual report to the Chair and Vice Chair of the Chief Human Capital 

Officers Council on the agency’s efforts to promote telework. Under the 

act, OPM is to play a leading role in helping executive agencies 

implement the new telework provisions, which include setting telework 

goals and establishing qualitative and quantitative measures. The law 

requires OPM to provide policy and guidance for telework in several 

areas, including pay and leave, agency closure, performance 

management, official worksite information, recruitment and retention, and 

accommodations for employees with disabilities. In an annual report to 

Congress, OPM is to assess each agency’s progress toward goals for 

participation and other goals relating to telework, such as emergency 

readiness. The first of these reports under the act is due to Congress in 

June 2012.

Since 2002, OPM has used a telework survey—the data call—to annually 

collect information from the executive agencies in order to provide 

Congress with a report on the status of telework across these agencies.3

However, throughout the past decade, OPM has been concerned about 

the reliability of the telework data it receives from executive agencies 

because, although data reported from agencies have improved, OPM 

continues to consider it an estimate of telework participation and 

frequency.

OPM conducts this data call to determine the extent to which agency 

employees are teleworking and to gauge agency progress in various 

aspects of their telework programs, such as participation, policy, eligibility, 

cost savings, and technology, as well as to provide examples of barriers 

agencies face to implementing telework programs.

4

 

3

OPM, Report to Congress: Status of Telework in the Federal Government, 2010 

(Washington, D.C.: Feb. 2011).

In its 2003 and 2007 telework reports to Congress, OPM 

4

OPM considers automated data collection through time and attendance to be a more 

reliable method of collecting telework data and the number of agencies collecting data this 

way has increased over the years. 

Background
 

Page 4 GAO-12-519 Federal Telework Programs

raised concerns about the ability of agencies to track employee 

participation in their telework programs.5 In its 2008 report, OPM 

identified weaknesses in the methodology most agencies used to collect 

and report telework participation data and OPM stated that 

inconsistencies within data systems and inaccuracies triggered by handcounting telework agreements could affect data reliability.6 OPM cautions 

that existing measures of telework participation are a barrier to measuring 

any increase in telework as the measures vary widely in validity and 

reliability and limit the capability of any federal body to track the actual 

level and frequency of telework participation.7

At the request of Congress, we have previously reported on telework 

programs across the federal government and have made 

recommendations related to the reliability of agency-reported data. In a 

2005 report, we reviewed the telework data for five federal agencies and 

found they had reported the total number of employees who were eligible 

to telework, but had included individuals who were, in fact, excluded from 

participation based on various criteria such as employee performance, 

thereby raising concerns about the reliability of the telework data reported 

by these agencies. In addition, none of the agencies could report the 

actual number of employees who teleworked or how often they did so 

because none had fully implemented the capability to track this through 

their time and attendance systems.8 Our 2007 testimony reiterated our 

concern that agencies were measuring employee participation in telework 

based on their potential to telework rather than their actual usage.9

 

5

OPM, Report to Congress, Status of Telework in the Federal Government, 2003

(Washington, D.C.: 2003) and OPM, Report to Congress, Status of Telework in the 

Federal Government, 2007 (Washington, D.C.: Dec. 2007).

6

OPM, Report to Congress, Status of Telework in the Federal Government, 2008 

(Washington, D.C.: Dec. 2008).

7

OPM, Congressional Budget Justification, Performance Budget Fiscal Year 2012 

(Washington, D.C.: Feb. 2011). 

8

GAO, Agency Telework Methodologies: Departments of Commerce, Justice, State, the 

Small Business Administration, and the Securities and Exchange Commission, 

GAO-05-1055R (Washington, D.C.: Sept. 27, 2005).

9

GAO, Human Capital: Telework Programs Need Clear Goals and Reliable Data, 

GAO-08-261T (Washington, D.C.: Nov. 7, 2007).
 

Page 5 GAO-12-519 Federal Telework Programs

More recently, we reported that since the 2004 data call, OPM asked 

agencies if they had integrated telework into agency emergency and 

continuity of operations plans, but agencies had no guidance as to what 

constitutes incorporating telework into continuity and emergency 

planning. This lack of a definition or description raised concerns about the 

reliability of reports on this matter.10

In response to the Telework Enhancement Act of 2010, OPM revised the 

2011 data call and provided instructions to executive agency respondents 

that incorporated common definitions and standards to use in providing 

OPM with their agency data. The revisions and additions to the 2011 data 

call were developed in consultation with an Interagency Telework 

Measurement Group (ITMG), which OPM formed in January 2011. (See 

app. II for a comparison of definitional and instructional changes from the 

2010 and 2011 telework data calls.) The OPM official designated with 

leading the ITMG said 10 agency officials from 7 agencies were selected 

for the group because of their knowledge of federal telework programs. 

According to the OPM official, the ITMG provided expertise in telework 

program implementation, policy, and methodology development, work/life 

balance programs, and expertise in research methods, such as surveys. 

The ITMG met on biweekly from January 2011 until July 2011 and 

resumed biweekly meetings in September 2011 with the goal of 

addressing three primary topics:

• Definitions of key terms, such as telework, eligibility, and employee, to 

use in the 2011 data call. ITMG interpreted some requirements of the 

act and developed additional instructions to encourage common 

reporting methodology across the agencies. For example, according 

to OPM officials, ITMG clarified the definition of eligibility in light of 

agencies’ concerns that the act did not specifically define the 

categories of employees that should be eligible to participate in their 

agencies’ telework programs, and therefore notified about their 

eligibility to telework. The group instructed respondents to ensure they 

excluded military and contract personnel as employees when 

reporting their telework data. The group also clarified that respondents 

 

10GAO, Emergency Preparedness: Agencies Need Coordinated Guidance on 

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

(Washington, D.C.: July 22, 2011).

OPM Revised the 2011 

Telework Data Call to 

Prepare for Reporting 

under the Telework 

Enhancement Act of 

2010 
 

Page 6 GAO-12-519 Federal Telework Programs

should include full-time, part-time and intermittent employees when 

responding to questions about telework participation and frequency.

• Revision and/or addition of data call questions. For example, OPM 

officials stated that in collaboration with the ITMG, they clarified the 

definition of telework to specifically state that telework includes what is 

generally referred to as remote work, but excludes mobile work and 

work done on official travel.11 OPM officials added a new question to 

capture the number of mobile workers. This addressed a reliability 

problem from the previous data call when some agencies included 

mobile work in reporting telework.

• Revision and development of data collection instruments, in addition 

to the data call, to collect telework information. For example, ITMG 

worked to revise telework-related items in the Federal Employee 

Viewpoint Survey, an OPM data collection instrument that gauges 

employees’ perceptions of their agency. In the 2011 survey three out 

of 84 questions focused on telework. In the past, OPM has found this 

survey to provide complementary employee views on telework. The 

ITMG also assisted in developing focus groups of telework managing 

officers and telework coordinators to identify issues, challenges and 

strategies associated with implementing telework programs at the 

agency level, such as successful telework implementation strategies, 

as well as barriers to telework.

According to an OPM official, these revisions also included questions that

may enable them to better understand the differences between telework 

programs across executive agencies, including differences in training on 

telework, use of technology, and how agencies responded to the 

requirements of the act. This official said such information will help inform 

the development of telework programs.

OPM also made changes to the 2011 data call time period for which 

employee telework participation and frequency was to be reported. This 

change was made to allow agencies time to develop telework policies in 

accordance with the act and to allow OPM time to meet its reporting 

obligation under the act (see fig. 1). In previous data calls, OPM asked 

 

11OPM defines mobile work as work characterized by routine and regular travel to conduct 

work in customer or other worksites as opposed to a single authorized alternative worksite 

(i.e., site audits). 
 

Page 7 GAO-12-519 Federal Telework Programs

agencies for telework data during the calendar year (12 months), if 

available. OPM reduced the time period for the 2011 data call to 4 weeks, 

as it decided this was the best methodology to meet its reporting 

requirements under the act. Agencies were to select a 4 week period 

during September and October on which to report. In addition to the 

change in time period for requested telework data, the 2011 data call 

asked for more detail on employee telework participation, frequency of 

employee telework participation, and additional information on telework 

policy and program implementation, and telework goals as required by 

the act.

Figure 1: Differences in Time Period of Data Requested and Reported between 2010 and 2011 Telework Data Calls

Note: From April 2010 through January 2011, OPM verified, analyzed, and drafted its 2010 report to 

Congress on telework. From January 2012 through May 2012, OPM will be verifying, analyzing, and 

drafting its report to be submitted to Congress in June 2012. 

OPM officials believe the information they obtained from the 2011 data 

call will enable the agency to satisfy some of the act’s reporting 

requirements, but for this report to Congress, OPM cannot fulfill other 
 

Page 8 GAO-12-519 Federal Telework Programs

requirements. OPM officials stated that it is not feasible for OPM to 

measure agencies’ progress against their Telework Enhancement Act of 

2010 goals, since these goals were established in June 2011, and the 

time period for agencies’ actual participation data was 

September/October 2011—just 3 to 4 months after agencies established 

their goals. However according to OPM officials, based on the information 

collected, OPM will be able to report the percentage and frequency of 

telework at individual agencies.

To communicate changes to the 2011 data call, OPM officials increased 

their training efforts to aid executive agency officials in developing a 

common understanding of terms, key concepts, and the objectives of the 

data call. According to OPM officials, in July 2011, OPM officials 

responsible for the data call met with agency respondents to provide an 

introduction and overview to the 2011 data call. The meeting covered the 

new requirements under the act, and the planned timeframe for agency 

reporting and OPM processing and analysis of the data collected through 

the data call. OPM could not require agency officials to attend. 

Nonetheless, OPM reminded agency officials responsible for the data 

call, that it was important that they attend both September and October 

training sessions being offered by OPM. The September training session 

covered the data call questions and incorporated specific content of the 

near final data call. The October training session reviewed specific 

instructions on how to enter information into the online data call form, in 

addition to reviewing instructions and questions from respondents. While 

some of the information provided at the two training sessions was similar, 

each session contained some new information usually in response to 

questions raised at a previous session. OPM staff also maintained and 

disseminated via email a list of the most frequently asked questions 

posed by data call respondents.
 

Page 9 GAO-12-519 Federal Telework Programs

The act requires OPM to report, among other things, year-to-year 

executive agency progress on the number of employees who telework. To 

accomplish this, OPM needs reliable baseline data on telework 

participation to be able to make year-to-year comparisons. However, 

OPM officials expressed continuing concerns over the reliability of 

quantitative participation and frequency data submitted by the agencies 

through the 2011 telework data call. OPM officials explained that 2011 is 

a transition year for telework programs across executive agencies, and 

some agencies made changes to their policies to bring their telework 

programs into compliance with the requirements of the act. For example, 

some agencies were implementing new data collection systems while 

collecting data on telework. These agencies first needed to create and 

implement new policies, and then consider and establish processes 

related to the collection of telework data to report to OPM. OPM officials 

responsible for preparing the report to Congress stated that because of 

these changes, it would not be appropriate to compare the 2011 data to 

data collected in prior years.

OPM will not be able to make comparisons to prior years due to the 

previously discussed modifications to the data call, such as changes to 

definitions. Definitional changes, including the change to specifically 

exclude mobile workers, could result in agencies interpreting and 

reporting telework participation and frequency of telework differently than 

they did in the past. While these changes should improve the consistency 

of data going forward, according to OPM officials there is no way that 

OPM can assure that all agencies would provide comparable responses 

to the same data call questions. Moreover, OPM officials have said that 

key terms and definitions for the 2012 data call may continue to evolve. If 

OPM reports agency telework progress based on data collected using 

definitions revised year to year, OPM may reach erroneous conclusions, 

although OPM officials have said they are taking steps to try and prevent 

this possibility.

Another reason why comparisons to prior data calls would be invalid is 

because of the changes OPM made to the time period when agencies 

reported telework data. Maintaining consistent data series over time 

necessitates using consistent data collection procedures for ongoing data 

collections. OPM said that changing the reporting period from 1 calendar 

year to 4 weeks may result in greater data consistency because in 

previous data calls, agencies may have reported data from different time 

periods within a calendar year. Now all agencies will report data from a 

narrower and more similar time frame. However, there are no available 

studies to support that the new time period is representative or “typical” of 

Various Methods of 

Data Collection and 

Ongoing Changes to 

the Data Call Make It 

Difficult to Assure 

Data Reliability and to 

Make Year-to-Year 

Comparisons
 

Page 10 GAO-12-519 Federal Telework Programs

other months in total or of the experience of particular agencies. OPM 

officials said that they will need to indicate this in their report to Congress.

While OPM made changes to the 2011 data call to allow it to meet some 

of its reporting requirements under the act and better assist agencies in 

responding to the data call, our analysis found the 2011 data call did not 

fully meet some generally accepted survey standards. According to these 

standards, to be valid, survey questions must adequately represent the 

concept or behavior in question and consistently predict outcomes. 

Moreover, questions must be designed and asked so that each recipient 

will understand and answer the same question in the same way. But for 

the 2011 data call, there can be no assurance that all respondents were 

aware of associated definitions and instructions provided by the training 

sessions and the frequently asked questions (FAQ). Although OPM 

invested more in providing training in preparation for the 2011 data call 

than in previous data calls and it disseminated training slides to all 

invitees of its final training session, attendance lists were not recoverable 

for all training sessions so there can be no assurance that all respondents 

received training or reviewed the slides. Consequently, some data call 

respondents may not have been aware of the definitions and instructions 

provided in the training sessions or in the FAQ.

Additionally, some of the information provided in the training sessions 

was inconsistent. For example, OPM officials said that during the last 

training session they instructed respondents to report an employee 

“telework day” if the employee teleworked for any portion of a work day.12

However, this clarification of “telework day” was not given in either the 

July overview meeting or in the other training session, and not clearly 

included in the instructions in the survey instrument or distributed in the 

FAQ. This information may have been important to agencies reporting on 

situational telework through automated systems intended to capture more 

precise data. OPM officials also explained that responses to certain 

questions should reference the same time period, and this information 

was not available in the data call instructions.13

 

12Under this definition, if an employee teleworked 2 hours, it should be reported as a 

“telework day”. Therefore, a “telework day” is not related to the number of hours of 

telework but rather the number of work days during which any telework occurred.

During one training 

13In the October training session, OPM explained that questions asking about the total 

number of agency employees and the total number of employees who teleworked (for 

participation data) should come from the same time period. However, the data call 

questions asking for these two totals are not drawn from the same time period. 
 

Page 11 GAO-12-519 Federal Telework Programs

session, an OPM official said she instructed those participants who 

determined employee participation by counting telework agreements to 

limit the agreements counted to those in effect after the agency 

implemented its telework program under the act; however, this 

information was not available in the online data call instructions. 

Uncertainty about whether data call respondents attended both the 

September and October training sessions, and variations in training 

sessions, could cause agencies to have different understandings of data 

call concepts and terms. OPM recognizes that the existing measures of 

federal telework participation vary in validity and reliability, which affects 

agencies’ ability to report accurate data, and it is taking steps to verify 

data submitted by respondents to provide a more accurate picture of 

telework in the federal government based on current definitions and 

collection methodologies. However, as a result of issues raised above, 

respondents may have provided inconsistent or inaccurate data on topics 

required by the act.

OPM officials anticipate that telework data will be more reliable next year 

because of the expected governmentwide implementation of automated 

data collection based on time and attendance records. As we have 

reported, OPM has concluded from research that the most reliable 

telework data are collected through time and attendance tracking 

systems.14

In an effort to collect more uniform data across agencies, OPM officials 

are standardizing definitions and data elements for use in automated time 

and attendance systems. For example, OPM has identified routine 

Data collected through automated systems eliminate the need 

to track telework data by counting telework agreements or relying on 

estimates. Since 2003, OPM has consistently expressed concerns about 

the methods agencies use to collect telework data. In its previous

telework reports to Congress, OPM has advocated for the development of 

an automated data collection system. OPM officials noted that OPM does 

not control what telework data responding agencies maintain, or their 

methods of data collection. Executive agencies provide telework 

participation and frequency data using a variety of methods, such as 

relying on estimates, counting telework agreements, and using automated 

time and attendance records to track telework participation.

 

14GAO, Human Capital: Further Guidance, Assistance, and Coordination Can Improve 

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

Page 12 GAO-12-519 Federal Telework Programs

telework hours in a pay period as a data element for automated data 

collection and provided a standardized definition that will be used by all 

agencies using the Enterprise Human Resources Integration (EHRI) 

system.15

Because of the eventual planned move to automation, OPM may not be 

able to use 2011 data as a baseline. With the planned change to the 

method of data collection, it may not be possible to compare the 2011 

data to future data. The 2011 data call requested data for a 2-month 

period, and some data call respondents relied upon estimates. Planned 

automation can provide a more uniform and accurate method for 

collecting telework data, however it may make comparisons using the 

2011 telework data as a baseline difficult. However, OPM officials believe 

the 2011 data will provide an improved report of telework status because 

of standardized definitions and the more uniform time period of data 

collection. According to OPM officials, some executive agencies will need 

time to become comfortable with automated reporting systems and, 

during a period of transition to a new system, there could be initial 

reliability issues. However, these officials said that the 2011 data, 

notwithstanding its limitations, will be useful in identifying and 

understanding any major agency changes in reported participation that 

could occur during a transition to automated data collection. Such 

OPM has introduced a timeline for modifying the existing EHRI 

system to allow OPM to collect telework data from executive agencies. 

According OPM, agencies will begin piloting these automated data 

collection systems for the 2012 telework data call. OPM began to discuss 

automated governmentwide data collection with the ITMG in July 2011. 

According to OPM’s timeline, OPM began to communicate internal 

requirements for automated telework data collection to telework 

managing officers in March 2012, but an OPM official has stated they do 

not expect full automation of telework data until 2013. This official also 

noted that different agencies have varying abilities to implement this new 

type of data collection and reporting mechanism, and considering 

different levels of comfort with new systems, it will take time to adjust to 

this method. However, continuous improvement efforts sometimes result 

in a trade-off between the desire for data consistency and a need to 

improve data collection and maintenance of a consistent data series over 

time.

 

15According to the OPM website, the EHRI system offers a standardized approach for 

human resources record conversion, storage, access, sharing, and archiving. 
 

Page 13 GAO-12-519 Federal Telework Programs

changes could alert OPM to possible transition related issues in agencies’ 

conversion to automated governmentwide data call collection efforts in 

2012 and 2013. In addition, for those agencies already responding on the 

basis of time and attendance reporting, major changes in agency 

responses provide OPM the opportunity to confirm with agencies that the 

uniform definitions are being consistently applied.

The Telework Enhancement Act of 2010 requires OPM to collect telework 

data and report annually to Congress, which emphasizes the need for 

telework data to be valid and reliable. OPM revised the 2011 telework 

data call in order to allow it to meet some of the act’s reporting 

requirements and assist agencies in responding to the data call. This 

revision resulted in changes to terminology, as well as changes in the 

collection time period of requested telework data. OPM provided greater 

assistance to agencies through training on changes to the 2011 data call 

to improve accuracy of agency reporting of telework participation and 

frequency for the data call reporting period of September and October 

2011. However, agencies use various methods, which OPM does not 

control, to report, collect, and maintain telework data, and this could affect 

the reliability of the telework data submitted. In addition, variation in 

training sessions and OPM’s uncertainty as to whether all respondents 

attended training, could lead to respondents’ potential misunderstanding 

of important terms and instructions. The validity and reliability of the 

reported 2011 telework data for some of the responding agencies may be 

questionable, and therefore agency telework participation and frequency 

data will not likely be comparable with previous data calls because of 

differences in definitions used, time periods of reporting, and individual 

agency tracking methods.

With the revised 2011 data call, OPM establishes a baseline it could use 

to conduct a limited crosscheck of data collected through a 

governmentwide automated telework data collection system, which OPM 

plans to implement over the course of 2012 and 2013. OPM expects that 

automated data collection will provide it increasingly more reliable data on 

which to report progress. However, these efforts to improve future 

automated data collection may result in changes to agencies’ methods of 

data collection and a trade-off between the desire for consistency with 

previous data calls for comparison purposes and a need to improve 

overall data collection.

Conclusions
 

Page 14 GAO-12-519 Federal Telework Programs

To improve OPM’s annual reporting of telework to Congress, we 

recommend that the OPM Director take the following two actions:

• Ensure that the reliability limitations related to the 2011 telework data 

call are clearly reported in its June 2012 report to Congress by fully 

describing how existing measures of telework participation vary widely 

in validity and reliability and limit the capability of OPM to reliably 

report the actual level and frequency of telework participation.

• Continue efforts to improve data collection and gather information that 

allows for the appropriate qualification of year-to-year comparisons 

and informs users about the effects of data collection changes going 

forward.

We provided a draft of this report to the Director of OPM for review and 

comment. The Associate Director of OPM provided written comments, 

which we have reprinted in appendix III. In summary, OPM partially 

concurred with our first recommendation and fully concurred with the 

second. OPM highlighted a number of actions the agency has under way 

or plans to undertake in response. For the first recommendation, OPM 

noted that inadequate methods of data collection exist at the agency level 

and OPM continues to address this data reliability issue through training 

on evaluation and measurement. While this is an important step in 

addressing data reliability issues, OPM should ensure that telework data 

reliability limitations are clearly reported in their annual reports to 

Congress. For the second recommendation, OPM noted its continued 

plans to automate collection of telework data, and to regularly meet with 

telework managing officers and telework coordinators to keep them 

updated on changes to telework policy and data collection. OPM also 

provided a number of technical comments, which we incorporated as 

appropriate.

We are sending copies of this report to the Chairman and Ranking 

Member of the Subcommittee on the Federal Workforce, U.S. Postal

Service and Labor Policy, Committee on Oversight and Government 

Reform, House of Representatives; and the Director of OPM. In addition, 

this report will be available at no charge on the GAO website at 

www.gao.gov. If you have any questions about this report, please contact 

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

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 15 GAO-12-519 Federal Telework Programs

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributions to this report are listed in appendix IV.

Yvonne D. Jones

Director, Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 16 GAO-12-519 Federal Telework Programs

This report (1) describes the Office of Personnel Management’s (OPM) 

actions to respond to the requirements of the Telework Enhancement Act 

of 2010 and (2) assesses how OPM is handling and addressing identified 

data reliability issues in the 2011 telework data call.

To address these two objectives, we reviewed relevant reports and 

guidance published by OPM that describe the status of telework 

programs across executive agencies and previous telework data calls and 

their instructions. We also reviewed previous GAO reports on telework 

and the reliability of OPM’s telework data. Lastly, we interviewed the OPM 

officials responsible for the planning, design, implementation, and 

analysis of the 2011 telework data call. This included discussions on the 

role of the Interagency Telework Measurement Group (ITMG), the 

process for developing the definitions and key terms used in the data call, 

the training and assistance provided to executive agency officials 

responsible for completing the data call, and agency plans to address 

outstanding data reliability issues associated with the data call. We 

conducted additional analysis to answer selected objectives as described 

below.

To assess the extent to which the 2011 telework data call met generally 

accepted survey methodology, GAO internal experts in survey research 

identified principles from the Office of Management and Budget’s (OMB) 

Standards and Guidelines for Statistical Surveys relevant to assessing 

the 2011 telework data call.1 We also used relevant aspects of GAO’s 

guide to Developing and Using Questionnaires.

2

 

1

OMB, Standards and Guidelines for Statistical Surveys (Washington, D.C.: Sept. 2006). 

See 

Using the OMB 

principles, two analysts independently reviewed the data call, supporting 

documentation, and clarifying information provided in interviews to assess 

the extent to which the data call methodology met research practices. The 

initial rate of agreement across 15 rated practices, including those rated 

as having insufficient information to judge, was 12 of 15, or 80 percent 

agreement. The rating for the three practices on which there was initial 

disagreement were reconciled by the two analysts conducting the review 

and the reconciled rating was then reviewed by a third analyst with survey 

www.whitehouse.gov/omb (last accessed Nov. 10, 2011). 

2

GAO, Developing and Using Questionnaires, GAO/PEMD-10.1.7 (Washington, D.C.: Oct. 

1993). 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 17 GAO-12-519 Federal Telework Programs

expertise. The third analyst did not recommend any changes to the 

reconciled ratings.

We also simulated completion of the Web-based data call, accessing and 

responding to the data call in the same manner as executive agency 

respondents.

Table 1 outlines the generally accepted survey research principles, 

derived from OMB’s guidelines, which we used in our assessment. This is 

not an exhaustive list of all OMB guidelines.3

Table 1: Principles Used to Assess the Data Call

When we completed this 

review in April of 2012, OPM had not yet completed analyzing and 

reporting on the results of telework data call. Based on this, we could not 

yet assess whether the data call met all of the OMB principles related to 

data analysis and reporting. Some OMB principles, such as those related 

to sample design, were not appropriate to apply to the telework data call. 

These principles were therefore excluded as not relevant to our review.

Development of Concepts, 

Methods, and Design

1. The survey had a clear rationale

2. Potential users were consulted to identify their requirements and expectations

3. A review of existing, surveys, studies, and reports, or other literature informed the survey

4. The scope of survey data items are defined and justified

5. To ensure data remain consistent over time, key variable and survey procedures remained

consistent

6. A clear, logical, and easy-to-follow flow of questions from a respondents’ point of view

7. The questionnaire was pretested and all components of the final survey system were field 

tested

Collection of data 1. The sample frame was appropriate

2. The respondents were provided appropriate informational materials

3. Questions are clearly written

4. The questionnaire design minimized respondent burden and maximized data quality

5. Response maximization efforts were appropriate

6. Agency staff developed proper protocols for handling respondent questions to help ensure 

data quality

7. Protocols to monitor data collection activities were developed

Processing and editing of data 1. Appropriate checks and edits on the data collection system mitigated errors

Source: GAO and OMB, Standards and Guidelines for Statistical Surveys (Washington, D.C.: Sept. 2006).

 

3

OMB standards and guidelines are also not designed to be completely exhaustive of all 

efforts that an agency may undertake to ensure the quality of its data. OMB encourages 

agencies to develop additional standards focused on their specific activities.
Appendix I: Objectives, Scope, and 

Methodology

Page 18 GAO-12-519 Federal Telework Programs

We conducted this performance audit from June 2011 through April 2012 

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: Revisions to OPM’s Telework Data 

Call to Collect Information to Prepare for 

Reporting under the Telework Enhancement 

Act of 2010 

Page 19 GAO-12-519 Federal Telework Programs

2010 Telework data call 2011 Telework data call

Instructions Time period: Based on the agency’s calendar year 

(Jan. 1 to Dec. 31, 2009).

Time period: Based on the months of Sept. and Oct. 2011.a

Participation: agencies invited to participate in data 

call.

 

Participation: agencies required to submit telework data to 

OPM. 

Reporting deadline: March 2010 Reporting deadline: Dec. 2011

Definitions Telework:

“Telework refers to any arrangement in which an 

employee regularly performs officially assigned duties

at home or other work sites geographically 

convenient to the residence of the employee.”

Telework:

“Telework is a work arrangement that allows an employee to 

perform work, during any part of regular, paid hours, at an 

approved alternative worksite (e.g., home, telework center). 

This definition of telework includes what is generally referred 

to as remote work but does not include any part of work done 

while on official travel or mobile work. See the following 

clarifications on remote and mobile work as telework.” 

Employee:

Not defined.

Employee:

Employee refers to federal civilian employees excluding 

military personnel and contractors. Employee may also 

include full-time, part-time, and/or intermittent employees.

Eligibility:

Agencies have the discretion to determine the 

telework eligibility requirements for their employees. 

For reporting purposes, in this Call for data, ALL 

employees are considered eligible EXCEPT those 

employees whose:

• positions require, on a daily basis (every work 

day), direct handling of secure materials, or onsite activity that cannot possibly be handled 

remotely or at an alternate worksite; 

• most recent federal government performance 

rating of record (or its equivalent) is below fully 

successful or conduct has resulted in disciplinary 

action within the last year.

Eligibility:

An employee is eligible to participate in telework if all of the 

following parameters are true:

• The employee has not been officially disciplined for being 

absent without permission for more than 5 days in any 

calendar year.

• The employee has not been officially disciplined for 

violations of subpart G of the Standards of Ethical 

Conduct for Employees of the Executive Branch.

• Teleworking does not diminish the employee’s 

performance or agency operations.

• Participation and performance complies with the 

requirements and expectations of his/her telework 

agreement.

• The employee’s official duties do not require on a FULL 

daily basis (ALL DAY, every work day):

• direct handling of secure materials 

determined to be inappropriate for telework 

by the agency head; or

• on-site activity that cannot be handled 

remotely or at an alternate worksite.

• The employee and/or the employee’s position are not 

disqualified based on additional criteria established by 

the organization.

Appendix II: Revisions to OPM’s Telework Data 

Call to Collect Information to Prepare for 

Reporting under the Telework Enhancement Act of 

2010 
Appendix II: Revisions to OPM’s Telework Data 

Call to Collect Information to Prepare for 

Reporting under the Telework Enhancement 

Act of 2010 

Page 20 GAO-12-519 Federal Telework Programs

2010 Telework data call 2011 Telework data call

Types of telework:

None provided

Types of telework:

• Routine: telework that occurs as part of an ongoing, 

regular schedule, and

• Situational: telework that is approved on a case-by-case 

basis, where the hours worked were not part of a 

previously approved, ongoing and regular telework 

schedule (e.g., telework as a result of special work 

assignments or doctor appointment.)b

Source: OPM. 

 

Notes: This table is intended to illustrate the differences between the 2010 and 2011 data calls. OPM 

made changes to the 2011 data call in response to the Telework Enhancement Act of 2010. 

a

Under the Telework Enhancement Act of 2010, agencies were required to establish telework policies 

by June 2011. 

b

Situational telework is sometimes also referred to as episodic, intermittent, unscheduled or ad-hoc 

telework. 
Appendix III: Comments from the Office of 

Personnel Management

Page 21 GAO-12-519 Federal Telework Programs

Appendix III: Comments from the Office of 

Personnel Management
Appendix III: Comments from the Office of 

Personnel Management

Page 22 GAO-12-519 Federal Telework Programs
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 23 GAO-12-519 Federal Telework Programs

Yvonne D. Jones, (202) 512-6806 or jonesy@gao.gov 

In addition to the contact named above, William Doherty, Assistant 

Director, and Keith O’Brien, analyst-in-charge, led the development of this 

report. Virginia Chanley, Patricia Donahue, Robert Gebhart, Jill Lacey, 

and Joseph Santiago made significant contributions to this report. Karin 

Fangman provided legal counsel. Shirley Hwang, Jessica Nierenberg, 

and Kathleen Padulchick verified the information in the report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 24 GAO-12-519 Federal Telework Programs

Emergency Preparedness: Agencies Need Coordinated Guidance on 

Incorporating Telework into Emergency and Continuity Planning. 

GAO-11-628. Washington, D.C.: July 22, 2011.

Human Capital: Telework Programs Need Clear Goals and Reliable Data. 

GAO-08-261T. Washington, D.C.: November 6, 2007.

Human Capital: Greater Focus on Results in Telework Programs Needed. 

GAO-07-1002T. Washington, D.C.: June 12, 2007.

Agency Telework Methodologies: Departments of Commerce, Justice, 

State, the Small Business Administration, and the Securities and 

Exchange Commission. GAO-05-1055R. Washington, D.C.: September 

27, 2005.

Human Capital: Key Practices to Increasing Federal Telework. 

GAO-04-950T. Washington, D.C.: July 8, 2004.

Human Capital: Further Guidance, Assistance, and Coordination Can 

Improve Federal Telework Efforts. GAO-03-679. Washington, D.C.: 

July 18, 2003.

Related GAO Products

(450930)
The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO’s commitment to good government is reflected in its core values of 

accountability, integrity, and reliability.

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO’s website (www.gao.gov). Each weekday afternoon, 

GAO posts on its website newly released reports, testimony, and 

correspondence. To have GAO e-mail you a list of newly posted products, 

go to www.gao.gov and select “E-mail Updates.”

The price of each GAO publication reflects GAO’s actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO’s website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact:

Website: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548

GAO’s Mission

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Phone

Connect with GAO

To Report Fraud, 

Waste, and Abuse in 

Federal Programs

Congressional 

Relations

Public Affairs

Please Print on Recycled Paper.