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Time and Attendance Fraud 

Not Identified for Employees 

on Extended Absence, But 

Matters of Concern Brought 

to EPA’s Attention

Report No. 15-P-0167 June 15, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Spending Taxpayer Dollars
Report Contributors: Angela Bennett

Jean Bloom

Safiya Chambers

Kevin Collins

Lisa McCowan

Leah Nikaidoh

Darren Schorer

Lela Wong

Abbreviations

AWL Alternate Work Location

EPA U.S. Environmental Protection Agency

IGEMS Inspector General Enterprise Management System

OCFO Office of the Chief Financial Officer

OEI Office of Environmental Information

OIG Office of Inspector General

RAC Reasonable Accommodation

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15-P-0167

June 15, 2015

Why We Did This Review

On August 27, 2013, a member 

of the Senate Committee on 

Environment and Public Works 

requested that the 

U.S. Environmental Protection 

Agency (EPA), Office of 

Inspector General (OIG), 

initiate work in connection with 

fraud committed by John C. 

Beale, a former Senior Policy 

Advisor with the EPA’s Office of 

Air and Radiation. One of the 

areas we evaluated was the 

EPA’s time and attendance 

process. This report addresses 

potential time and attendance 

fraud at the EPA in connection 

with employees who received 

salary payments while 

appearing to be on extended

absence from their duties.

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Embracing EPA as a highperforming organization.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150615-15-P-0167.pdf

 

Time and Attendance Fraud Not Identified for 

Employees on Extended Absence, But Matters 

of Concern Brought to EPA’s Attention

 What We Found

Our audit did not identify any instances of 

time and attendance fraud for employees

receiving salary payments while absent from 

their duties for an extended period of time. 

All employees interviewed provided evidence 

of login or had a valid explanation for not 

logging in to the agency’s email system. We did not test for employees absent from 

their duties for less than 4 consecutive weeks; if our sample period was reduced to 

less than 4 consecutive weeks, additional issues may have been identified. 

We identified matters of concern that warrant the agency’s attention. These 

matters pertain to:

 Accuracy of time charges in the PeoplePlus timekeeping system.

 Use of a personal computer to conduct official work.

 Safety of reasonable accommodation employees on fulltime telework. 

We did not fully evaluate these matters because they are outside the scope of this 

audit. However, we are bringing these matters to the agency’s attention due to the 

frequency of occurrences. In our professional judgment, the number of such 

occurrences is significant. We are bringing this to the agency’s attention so that it 

can address the specific issues noted as appropriate.

 Recommendation and Planned Agency Corrective Actions

We recommend that the Deputy Administrator address the concerns regarding the 

accuracy of time charges, use of personal computers for official work, and safety of 

telework space for reasonable accommodation employees. The agency concurred, 

has corrected the timekeeping errors, and is updating its policies and procedures 

to address the remaining matters. 

 Noteworthy Achievements 

In response to our December 2013 early warning report on Beale, the agency 

identified corrective measures taken and planned regarding time and attendance. 

These measures included generating additional payroll reports for management 

review, conducting quarterly reviews and following up on employees who failed to 

enter their time three pay periods during the quarter, removing the group 

approval option in PeoplePlus, and amending the agency’s time and attendance 

policy to eliminate system-generated default pay and mass approval processes. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

We identified concerns over the 

accuracy of time charges, use 

of a personal computer, and 

safety of telework space for

reasonable accommodations.
June 15, 2015

MEMORANDUM

SUBJECT: Time and Attendance Fraud Not Identified for Employees on Extended Absence,

But Matters of Concern Brought to EPA’s Attention 

Report No. 15-P-0167

FROM: Arthur A. Elkins Jr.

TO: A. Stanley Meiburg, Acting Deputy Administrator

This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe problems the 

OIG has identified and corrective actions the OIG recommends. This report represents the opinion of the 

OIG and does not necessarily represent the final EPA position. In accordance with established auditresolution procedures, EPA managers will make final determinations on matters in this report.

Action Required

In response to our discussion document, the agency provided an intended corrective actions plan that 

addresses the recommendation and establishes planned completion dates. Therefore, a response to the 

final report is not required. The agency should track unimplemented corrective actions in the 

Management Audit Tracking System.

This report will be available at http://www.epa.gov/oig.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.20460

THE INSPECTOR GENERAL
Time and Attendance Fraud Not Identified 15-P-0167

for Employees on Extended Absence, 

But Matters of Concern Brought to EPA’s Attention

Table of Contents

Purpose ..................................................................................................................... 1

Background ............................................................................................................... 1

Responsible Offices.................................................................................................. 1

Other OIG Audits....................................................................................................... 2

Noteworthy Achievements ....................................................................................... 2

Scope and Methodology........................................................................................... 3

Results of Review ..................................................................................................... 4

Time and Attendance Fraud Not Identified for Employees on 

 Extended Absence....................................................................................... 4

Additional Matters of Concern ................................................................................. 4

Accuracy of Time Charges in PeoplePlus........................................................... 5

Use of Personal Computer to Conduct Official Work .......................................... 5

Safety of Employees on Reasonable Accommodation Telework ........................ 6

Recommendation...................................................................................................... 7

Agency Comments and OIG Evaluation .................................................................. 8

Status of Recommendations and Potential Monetary Benefits ............................. 9

Appendices

A Prior OIG Reports Related to Time and Attendance ..................................... 10

B Sampling Methodology ................................................................................... 11

C Agency Response to Discussion Draft .......................................................... 12

D Distribution ...................................................................................................... 15
15-P-0167 1

Purpose

We conducted this audit to identify potential time and attendance fraud at the 

U.S. Environmental Protection Agency (EPA) in connection with employees who 

received salary payments while on extended absence from their duties. 

Background

On September 27, 2013, John C. Beale, a former Senior Policy Advisor with the 

EPA’s Office of Air and Radiation, pleaded guilty to a federal charge stemming 

from a long-running scheme in which he defrauded the government in salary 

payments and other costs. From January 2000 to April 2013, Beale was absent from 

his duties at the EPA for about 21⁄2 years but continued to receive his salary and 

benefits. On December 11, 2013, the EPA Office of Inspector General (OIG) issued 

an Early Warning Report: Internal Controls and Management Actions Concerning 

John C. Beale Pay Issues. The OIG report disclosed that one of the factors that 

facilitated Beale’s fraud was the agency’s lack of adequate controls over 

timekeeping. As a result, we initiated this audit to identify similar potential time 

and attendance fraud. 

The EPA uses PeoplePlus as its official payroll system for reporting employee 

time and attendance. Employees are required to prepare biweekly time cards in 

PeoplePlus and attest to the accuracy of the data on the time cards. If employees 

cannot input their time, the timekeeper or approving official may prepare their 

time cards. Supervisors and managers are responsible for approving an 

employee’s time once it has been attested or verified.

Employees must have an EPA-issued Active Directory Local Area Network user 

identification to log into the agency’s computer network. Log-in authentication 

methods vary depending on the system. Access to PeoplePlus is authenticated 

through Novell Identity Vault and access to the agency’s email system Outlook is 

through Active Directory. The agency’s Active Directory database tracks all 

Outlook authentication, except for access through mobile phones, for 

approximately 6 months. 

Responsible Offices

The EPA’s Office of the Chief Financial Officer (OCFO) is responsible for 

formulating and providing time and attendance reporting policies. In addition, 

OCFO is responsible for the PeoplePlus system, including:

 Enforcing internal control policies and standards.

 Monitoring records to confirm that appropriate individuals are entering, 

attesting, submitting, verifying and approving time worked.

 Providing systems administration.

 Coordinating training. 
15-P-0167 2

The Office of Human Resources within the Office of Administration and 

Resources Management is responsible for providing policies and guidance on 

employment, pay and leave administration, and employee conduct. The Office of 

Human Resources also maintains data on employment and pay status.

The Office of Environmental Information (OEI) is responsible for maintaining the 

Active Directory database. OEI is also the agency’s focal point for collecting, 

managing, providing and safeguarding environmental information. This includes 

establishing policies for the agency’s information security and records 

management and overseeing the implementation of these policies.

Other OIG Audits 

The OIG recently issued audit reports related to other aspects of time and 

attendance. These reports pertain to EPA employees on administrative leave, OIG 

compliance with its internal time and attendance reporting requirements, and OIG 

compliance with overtime polices. These reports are discussed in Appendix A.

Noteworthy Achievements 

In response to our December 2013 early warning report on Beale, the agency 

identified corrective measures taken and planned regarding time and attendance.1

These corrective measures include:

 Generating reports each pay period to identify and follow up on instances 

where the employee’s time was not entered by the employee or his/her 

timekeeper, or were not approved by his/her supervisor or approver.

 Conducting quarterly reviews and following up on employees who failed 

to enter their time three pay periods during the quarter, and those instances 

where the time was approved by someone other than the employees’ direct 

supervisors more than three times during the quarter.

 Removing the group approval option from PeoplePlus and requiring 

managers to approve each time card individually.

 Amending the agency’s time and attendance policy to eliminate systemgenerated default pay and mass approval processes. The revised policy 

was implemented in June 2014 with the migration to the EPA’s new 

payroll service provider—the Interior Business Center—which is a 

division of the U.S. Department of the Interior. 

The OIG has not audited the above corrective measures reported by the agency; 

therefore, we are unable to provide, and we do not provide, any conclusions or 

opinions regarding the effectiveness of these corrective measures. 

 

1 Report of Evaluation and Corrective Actions, dated December 5, 2013, issued by former Deputy Administrator 

Bob Perciasepe to the OIG.
15-P-0167 3

Scope and Methodology

We conducted this audit from November 5, 2013, to March 20, 2015, in 

accordance with generally accepted government auditing standards issued by the 

Comptroller General of the United States. 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 objective. 

We believe that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objective.

To assess the risk of employees receiving salary payments while absent from their 

duties, we evaluated the agency’s time and attendance policies. We also discussed 

the controls for time card review and approval with agency officials. Based on our 

evaluation and discussion, the controls over time and attendance vary depending 

on the time card approver. The approvers are usually at the supervisor or manager 

level. Each approver would have at least one alternate approver and a timekeeper. 

The EPA estimated that it has more than 3,300 supervisors, managers and 

timekeepers. Because of the large number of control points and lack of 

consistency among time card approvers, testing of the individual controls would 

be cost prohibitive and ineffective for projecting results. As a result, we decided 

to base our conclusions on substantive testing rather than trying to test the varying 

internal controls; we designed a substantive test to cover the maximum assumed 

control risk.

We selected two sample periods for testing—November 2013 and May 2014. Each 

sample period represents two consecutive pay periods, or 4 weeks. For each sample 

period, we compared employees who received salary payments to those who 

logged into the agency’s email system—Outlook—at least once. We identified the 

employees receiving salary payments from the agency’s accounting system—

Compass Data Warehouse. To identify the employees who logged into Outlook, we 

used the Active Directory login data and computer user identification provided by 

OEI. Based on the comparison, we identified the initial exceptions for follow-up. 

We then used a multi-phased process to identify and eliminate any false exceptions

(i.e., exceptions that could be justified or explained). We interviewed 

approximately 54 percent of the remaining employees to determine whether they 

could provide evidence that they logged into the agency’s systems, or an 

explanation for not logging in. Details of our sampling methodology are in 

Appendix B.

The purpose of this audit was to identify potential time and attendance fraud at the 

EPA where employees may have received salary payments while on extended 

absence from their duties. We did not audit the agency’s overall time and 

attendance system or payroll system and the related controls. As a result, we are 

unable to provide, and we do not provide, any conclusions or opinions regarding 

the agency’s internal controls over time and attendance and payroll. 
15-P-0167 4

Results of Review

Time and Attendance Fraud Not Identified for Employees on 

Extended Absence

Our audit did not identify any instances of time and attendance fraud for employees 

receiving salary payments while absent from their duties for an extended period of 

time. All employees interviewed provided evidence of login or had a valid 

explanation for not logging into the agency’s email system. 

We interviewed 63 employees, of which 11 did not log into the network during our 

sample periods. One of the 11 employees chose to not log into the system unless 

necessary and he did not access the network during one of our sample periods. The 

remaining 10 employees were on extended sick leave, on temporary duty through 

Intergovernmental Personnel Action, or unable to access the system. 

The remaining 52 employees were false positives. Five of the employees came up 

as exceptions because their user names changed, and we confirmed that the 

employees had logged into the network under their prior user names. Data obtained 

during interviews show that the remaining 47 employees also logged into the 

network and accessed Outlook. 

We did not test for employees who were absent from their duties for less than 4

consecutive weeks; if our sample period was reduced to less than 4 consecutive 

weeks, additional issues may have been identified. 

Additional Matters of Concern

We identified additional matters of concern that warrant the agency’s attention. 

These matters pertain to the:

 Accuracy of time charges in PeoplePlus.

 Use of a personal computer to conduct official work.

 Safety of reasonable accommodation (RAC) employees on fulltime telework. 

We did not fully evaluate these matters because they are outside the scope of this 

audit. However, we are bringing these matters to the agency’s attention due to the 

frequency of occurrences. In our professional judgment, the number of such 

occurrences (11 percent, or seven occurrences of the total sample size of 63) is 

significant. We are bringing this to the agency’s attention so that it can address the 

specific issues noted as appropriate.
15-P-0167 5

Accuracy of Time Charges in PeoplePlus

Of the 63 employees interviewed, we identified three with a time card error. The 

three employees were on extended leave. However, the approved time cards 

showed the employees working regular hours, resulting in an overstatement of the 

employees’ leave balances. In all three cases, the time cards were prepared by 

someone other than the employee. 

One of the errors was detected by the employee upon her return from extended 

sick leave. The error was for the pay period ended May 17, 2014. The employee 

initiated a request for correction and the leave balance was corrected during the pay 

period ended September 6, 2014. The remaining two errors—one each in Region 5 

and Region 9—were for the pay period ended November 30, 2013. The OIG 

notified agency officials in December 2014 and January 2015, respectively, and 

management officials took actions to correct the errors. In addition, Region 9 

management issued new standard operating procedures to ensure similar errors 

would be detected and prevented in the future. The new standard operating 

procedures outline steps for the timekeeper to verify time card entries and monitor 

employee corrections.

Use of Personal Computer to Conduct Official Work 

One of the interviewed employees chose to use his personal computer and tablet to 

conduct official work. The employee did not use his EPA-issued computer even 

when working in the office; the employee connected to the EPA network using his 

personal computer and/or tablet. His work, including any documents downloaded 

from the network, were stored in his personal computer and/or tablet. The 

employee emailed his work products to his supervisor from his personal devices

using a personal email account. To meet records management requirements, the 

employee copied the emails to his work email account. 

According to the agency’s Information Security – Interim Access Control 

Procedures V3.2, dated July 13, 2012, all non-EPA mobile devices are prohibited 

from connecting to an EPA network unless the device has been approved, scanned 

and inspected. Mobile devices include portable computing and communications 

devices with information storage capability, such as notebook/tablet/laptop 

computers and personal digital assistants. The EPA’s Mobile Computing Policy: 

6.1 Mobile Computing Requirements states that EPA employees or other users who 

are granted permission to use the EPA’s network must use government-furnished 

information management and technology solutions to access the EPA’s network 

outside of the EPA’s secured physical location, and states that no waivers will be 

accepted from the requirements of this policy. 

Based on our review of the two policies, there appears to be a conflict regarding the 

use of personal computers for conducting EPA work. The Information Security 

Procedures appear to allow the use of a non-EPA device as long as the non-EPA 

device has been properly approved, scanned and encrypted. However, the Mobile 
15-P-0167 6

Computing Policy requires employees to use government-furnished devices when 

working remotely. 

The agency explained that the two policies do not conflict. Both policies allow the 

employee to either use EPA-furnished equipment to directly access the EPA 

network, or use non-EPA equipment to connect to the resources on the EPA 

network through an EPA technology solution (such as the EPA’s remote access 

solution). Employees are not allowed to directly access the EPA network using 

personal devices. The agency stated that the Access Control Procedure is in the 

process of being revised to mirror the language of the Mobile Computing Policy.

Safety of Employees on Reasonable Accommodation Telework

Of the 63 employees interviewed, the EPA had approved seven employees for 

fulltime RAC telework. We conducted interviews with these employees at their 

residences in the same manner and for the same purpose as those conducted with 

non-RAC employees at their EPA offices. 

For three of the seven employees, we observed potentially unsafe conditions within 

the employee’s work space and general work environment. We observed extremely 

cluttered and poorly lit work spaces, and pathways to the workspaces filled with 

boxes and miscellaneous items that made movement difficult and potentially 

unsafe. We believe the conditions observed put the employees at risk of injury and 

the agency at risk for potential liability claims if injury occurs. We discussed our 

concerns with the employees’ supervisors, and they were unaware of the potentially 

unsafe conditions. 

The supervisors provided us with the employees’ approved telework agreements 

and the self-certification safety checklists on file. The supervisors also indicated 

that they had never conducted site visits to the employees’ residences. The safety 

checklist is designed to assess the overall safety of the alternate work location 

(AWL) and must be completed by the employee and given to the employee’s

supervisor with the telework application. The form states that signing the form does 

not guarantee that the AWL is hazard free, but does verify that the employee has 

made a reasonably careful inspection for potential hazards. The form also states 

that the employees are responsible for informing their supervisors of any changes 

to their AWL which could impact on health and safety of the employee and others.

Based on the OIG’s observations during the interviews, we believe that the

employees are in potential noncompliance with some or all of the following 

checklist items shown in Table 1.
15-P-0167 7

Table 1: Potential noncompliance items based on OIG observations

Checklist 

item no. Checklist description

13. Are aisles, doorways and corners free of obstructions to permit visibility 

and movement?

17. Are the phone lines, electrical cords, and extension wires safely secured?

19. Is there adequate electrical lighting to accomplish work assignments?

Source: EPA Flexiplace Policy, Employee Self-Certification Safety Checklist. 

Our review of the safety checklists for the three employees showed that the 

employees had marked “yes” to each of the items in Table 1. Since the supervisors 

were unaware of the potentially unsafe conditions, we can assume that the 

employees did not provide notification of changes to their AWL, as agreed to by 

signing the form.

We reviewed the agency’s telework policy to determine whether telework 

requirements—including the employee self-certification safety checklist—are

applicable to employees on RAC telework. Our review showed no specific 

reference to RAC telework.

The agency clarified that all governing telework policies and procedures apply to 

employees who telework as a RAC, unless these policies and procedures are 

modified by virtue of the disability/accommodation. The agency stated that any 

policy change involving employees who telework as a RAC would need to be a 

collaborative effort between the Office of Human Resources and the Office of 

Civil Rights and subject to bargaining requirements pursuant to collective 

bargaining agreements. The agency has been working with the American 

Federation of Government Employees—the EPA’s largest union—on an 

agreement that will confirm that employees teleworking as a RAC are required to 

meet telework recertification requirements, including annual safety checklist 

recertification.

Recommendation

We recommend that the Deputy Administrator:

1. Address the specific matters of concern noted in this report pertaining to:

 Accuracy of time charges in PeoplePlus.

 Use of a personal computer to conduct official work.

 Safety of the work space for employees on RAC telework. 
15-P-0167 8

Agency Comments and OIG Evaluation

A discussion document was provided to the agency for comment on March 20, 

2015. The agency provided us its initial response on April 9, 2015, and we held a 

final exit conference with agency officials on April 23, 2015. The agency 

followed up with a formal response on May 4, 2015. 

The agency concurred with our recommendation and has corrected the 

timekeeping errors identified. The agency is currently updating its network access 

control procedures and evaluating its telework policies to address our concerns 

regarding the use of personal computers for official work and the safety of RAC

employees. 

The agency’s full response to our discussion draft is in Appendix C of this report. 
15-P-0167 9

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 7 Address the specific matters of concern noted in this 

report pertaining to:

 Accuracy of time charges in PeoplePlus.

 Use of a personal computer to conduct 

official work.

 Safety of the work space for employees on 

RAC telework. 

O Deputy Administrator 4/30/16

1 O = Recommendation is open with agreed-to corrective actions pending. 

 C = Recommendation is closed with all agreed-to actions completed. 

 U = Recommendation is unresolved with resolution efforts in progress.
15-P-0167 10

Appendix A

Prior OIG Reports Related to

Time and Attendance

In addition to the Beale report, the OIG recently issued three other reports related to time and 

attendance, as follows.

Early Warning Report: Some EPA Employees Found to Be on Paid Administrative 

Leave for Years (15-N-0025), issued November 19, 2014

This report identified eight employees who had recorded significant amounts of administrative 

leave. We issued the report to provide the information to the EPA Administrator.

No recommendations were made.

http://www.epa.gov/oig/reports/2014/20141119-15-N-0025.pdf. 

EPA OIG Not Fully Compliant With OIG Policy on Time and Attendance Reporting

(15-B-0074), issued February 4, 2015

The audit noted that the OIG did not always comply with its policy for using its Inspector 

General Enterprise Management System (IGEMS) as the official internal system for recording 

time and attendance in both its planning and timesheet modules. As a result, some employees 

did not submit or have approved planned or actual timesheets in IGEMS when required under 

OIG policy. This occurred because the policy needed clarity and OIG employees did not 

appear to view IGEMS time and attendance recording as a high priority. We recommended 

that the Deputy Inspector General require employees and management to correct the instances 

of noncompliance identified and review future IGEMS records for appropriateness, and review 

pertinent policy. The Deputy Inspector General agreed with our recommendations and 

provided corrective actions and planned completion dates to address all recommendations.

http://www.epa.gov/oig/reports/2015/20150204-15-B-0074.pdf.

EPA OIG Not Fully Compliant With Overtime Policies (15-B-0075), issued February 4, 

2015

The audit disclosed that the OIG did not always use EPA Form 2560-7, Request for 

Authorization of Overtime Work, for overtime requests and authorization as required by EPA 

Pay Administration Manual 3155. Also, the OIG did not always comply with its own policy 

on the use of the planned timesheet for advance approval of overtime. This occurred because 

OIG management did not provide sufficient oversight, and OIG policies were not clear. We 

also noted the OIG did not retain EPA authorization forms supporting overtime requests. We 

recommended that the Deputy Inspector General revise OIG policy as needed and emphasize 

EPA policy to staff. The Deputy Inspector General agreed with our recommendations and 

provided corrective actions and planned completion dates to address all recommendations.

http://www.epa.gov/oig/reports/2015/20150204-15-B-0075.pdf
15-P-0167 11

Appendix B

Sampling Methodology

The purpose of our sample testing was to identify employees who potentially received salary 

payments while absent from their duties for an extended period of time. We held numerous 

discussions with representatives from OEI, OCFO, and the Office of Administration and 

Resources Management to determine the availability of data and potential testing methodologies. 

Based on these discussions, we developed the most feasible test to address our purpose. We 

shared our methodology with the agency and addressed its concerns. We also solicited ideas 

from the agency for alternative testing methodologies, but the agency provided no suggestions. 

The agency agreed with our general sampling methodology.

We selected two sample periods for testing—November 2013 and May 2014. Each sample 

period represented two consecutive pay periods, or 4 weeks. For each sample period, we 

compared payroll to computer login records to identify employees who received salary payments 

but had not logged into the agency’s email system (Outlook) at least once. We based the test on 

the assumptions that if employees are logged into the agency’s email system, there is some 

assurance that the employees are present to perform their duties.

For the sample periods November 2013 and May 2014, the number of employees receiving 

salary payments totaled 16,116 and 15,355, respectively, according to the agency’s Compass 

Data Warehouse accounting system. We used the Active Directory login data and computer user 

names provided by OEI to identify employees who logged into the email system. Anyone who 

received a salary payment but had not logged into the system at least once during the sample 

period was identified as an exception. Initially, we identified 528 exceptions. We used a multiphased process to identify and eliminate “false exceptions” (i.e., any exceptions that could be 

readily justified or explained). We reviewed time cards, personnel records, and additional 

information provided by the agency. Examples of a justified basis for the eliminations included:

 Employees who were on payroll but charged zero hours.

 Employees who were on leave most of the time.

 Special government employees who were hired on an as-needed basis and not issued a 

government computer for logging into the EPA’s systems regularly.

 Employees who mistakenly came up in the initial exceptions due to computer user name 

changes.

 Employees who had an employment status change during the sample periods.

 Employees who were double counted because they were exceptions for both sample periods.

As a result of these justifications, we eliminated 412 exceptions from further review, reducing 

the exceptions requiring follow-up to 116. Based on employee availabilities and further risk 

assessment, we interviewed 63 employees, or 54 percent of our remaining 116 exceptions. We 

conducted the interviews to determine whether the employees actually logged into the agency’s 

email system and to identify explanations for those who did not log in. 
15-P-0167 12

Appendix C

Agency Response to Discussion Draft

May 4, 2015

MEMORANDUM

SUBJECT: EPA Comments on Discussion Draft, “No Instances of Time and Attendance 

Fraud Identified, But Other Matters of Concern Brought to EPA’s Attention,” 

dated March 20, 2015

FROM: Stefan Silzer, Director /signed/

Office of Financial Management

TO: Robert Adachi, Director

Forensic Audits

Office of Audits

Thank you for the opportunity to review the subject Discussion Draft. Below is a summary of the 

agency’s comments regarding the factual accuracy of the information, conclusions, and 

recommendations contained therein.

AGENCY’S COMMENTS ON DISCUSSION DRAFT LANGUAGE

OIG Issue: “Safety of Employees on Reasonable Accommodation Telework” 

Agency Comments:

 All governing telework policies and procedures apply to employees that telework as a 

reasonable accommodation unless these policies and procedures are modified by virtue of 

the disability/accommodation. 

 The safety checklist represents the employee’s signed certification that they have 

inspected their alternative work location (AWL) for potential hazards and that it is a safe 

space; however, this certification states that signing the form “does not guarantee that the 

AWL is hazard free.” The certification requires employees to inform their supervisors of 

any changes to their AWL which could impact their health and safety.

 Any policy change involving employees that telework as a reasonable accommodation 

would need to be a collaborative effort between OHR and OCR (who handles agency RA 

matters) and are subject to bargaining requirements pursuant to collective bargaining 

agreements. 

 The Agency has been working with AFGE, EPA’s largest Union on an agreement that 

will confirm that employees teleworking as a reasonable accommodation are required to 
15-P-0167 13

meet telework recertification requirements, including annual safety checklist 

recertification. 

AGENCY’S RESPONSE TO RECOMMENDATIONS

The agency concurs with the Discussion Draft recommendation. 

Agreements

.

No. Recommendation High-Level Intended 

Corrective Action(s)

Estimated Completion 

by Quarter and FY

1 Address the specific 

matters of concern noted in 

this report pertaining to:

 Accuracy of time 

charges in PeoplePlus 

 Use of a personal 

computer to conduct 

official work 

 Safety of the work space 

for employees on RAC 

telework

1.1 The discussion draft 

identified 3 employees with 

timecard errors. Corrections to 

these timecards have been 

made by the employees and 

approved by their supervisors. 

Complete

1.2 A revised access control 

procedure is currently 

undergoing Agency wide 

review and is expected to be 

signed by the CIO later this 

year. The new access control 

procedure states that “users 

shall connect non-EPA owned 

mobile devices only to 

authorized EPA information 

management and technology 

solutions.” 

September 30, 2015

1.3 The agency will evaluate 

its telework policies and 

procedures related to 

reasonable accommodations 

and modify them, as needed, 

to ensure the safety of the 

work space for employees on 

RAC telework. Note that 

changes to RAC/ telework 

may be subject to the 

collective bargaining 

agreements.

April 30, 2016
15-P-0167 14

cc: David Bloom

 Renee Wynn

 Donna Vizian

 Kevin Minoli

 John Reeder 

 Jeanne Conklin

 John Showman 

 Meshell Jones-Peeler

 Richard Gray

 Leo Gueriguian

 Harrell Watkins 

 Liza Hearn

 Patricia Hilton

 Judi Maguire

 Iesha Alexander

 Brandon McDowell

 Janice Kern

 Lorna Washington

 
15-P-0167 15

Appendix D 

Distribution 

Office of the Administrator 

Deputy Administrator 

Chief of Staff 

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs

Chief Information Officer, Office of Environmental Information

Assistant Administrator for Administration and Resources Management 

Regional Administrator, Region 3

Regional Administrator, Region 5

Regional Administrator, Region 9

Principal Deputy Assistant Administrator for Administration and Resources Management

Assistant Administrator and Principal Deputy Assistant Administrator for 

Environmental Information

Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

Deputy Director, Office of Policy and Resource Management, Office of Administration and 

Resources Management 

Audit Follow-Up Coordinator, Office of Administration and Resources Management 

Audit Follow-Up Coordinator, Office of the Chief Financial Officer 

Audit Follow-Up Coordinator, Office of Environmental Information

Audit Follow-Up Coordinator, Region 3

Audit Follow-Up Coordinator, Region 5

Audit Follow-Up Coordinator, Region 9