a

GAO

United States General Accounting Office

Report to the Chairman, Committee on 

Government Reform, House of 

Representatives

July 2003 HUMAN CAPITAL

Further Guidance, 

Assistance, and 

Coordination Can 

Improve Federal 

Telework Efforts

GAO-03-679
The statutory framework for federal telework requires agencies to take 

certain actions related to telework, provides agencies with tools for 

supporting telework, and provides both the Office of Personnel Management 

(OPM) and the General Services Administration (GSA) with lead roles and 

shared responsibilities for the federal telework initiative. Both agencies 

offer services and resources to support and encourage telework in the 

federal government. However, these agencies have not fully coordinated 

their telework efforts and have had difficulty in resolving their conflicting 

views on telework-related matters. As a consequence, agencies have not 

received consistent, inclusive, unambiguous support and guidance related to 

telework. 

After we discussed the issues created by the lack of coordination between 

GSA and OPM with both agencies, a GSA official then indicated that GSA 

and OPM expressed a new commitment to coordination. Such a 

commitment reflects a promising start for better assisting federal agencies in 

improved implementation of their telework programs. However, the key to 

success will be sustained efforts by both agencies to work together in 

assisting agencies and providing consistent and straightforward guidance, 

services, and resources on the governmentwide telework initiative. 

GAO identified 25 key practices in telework-related literature and guidelines 

as those that federal agencies should implement in developing telework 

programs and grouped these practices under seven categories. While the 

four selected executive agencies we reviewed—the Department of 

Education (Education), GSA, OPM, and the Department of Veterans Affairs 

(VA)—have taken at least some steps to implement most of the key 

practices, only 7 of the 25 key practices, such as establishing a crossfunctional project team and establishing an agencywide telework policy, had 

been fully implemented by all four agencies. 

Although some telework-related resources from GSA and OPM provide 

federal agencies with information on how to implement several of the key 

practices we identified, agencies may need additional guidance, guidelines, 

and/or individualized technical support to fully implement these practices. 

Telework—work done at a location 

other than a traditional office—has 

gained widespread attention over 

the past decade as a human capital 

flexibility offering various potential 

benefits to employers, employees, 

and society. Using such 

flexibilities as management tools 

can help the federal government 

address its human capital 

challenges. GAO did this study in 

response to a congressional request 

to assess the federal government’s 

progress in implementing telework 

programs and to determine what 

else can be done to give federal 

employees the ability to telework 

under appropriate circumstances. 

GAO makes recommendations to 

the Director, OPM, and the 

Administrator, GSA, regarding 

further guidance and assistance 

they can provide to executive 

agencies in implementing telework 

programs. In joint comments, the 

administrator and director 

generally agreed with our 

recommendations and committed 

to taking steps towards their 

implementation. Both agencies 

disagreed with several findings on 

both their governmentwide and 

internal telework efforts. 

Comments from the Secretary, VA, 

and Director, Human Resources 

Services, Education, also generally 

agreed with our report, but VA 

disagreed with several findings. 

Our characterizations were 

generally accurate, but we made 

changes in response to agencies’ 

comments, as appropriate. 

HUMAN CAPITAL 

Further Guidance, Assistance, and 

Coordination Can Improve Federal 

Telework Efforts 

www.gao.gov/cgi-bin/getrpt?GAO-03-679.

To view the full report, including the scope 

and methodology, click on the link above. 

For more information, contact J. Christopher 

Mihm at (202) 512-6806 or mihmj@gao.gov. 

Highlights of GAO-03-679, a report to the 

Chairman, Committee on Government 

Reform, U.S. House of Representatives 

July 2003 
Page i GAO-03-679 Improving Federal Telework Efforts

Contents

Letter 1

Results in Brief 3

Background 8

Federal Laws and Their Requirements Cover a Gamut of Telework 

Issues 11

Lack of Clarity in OPM Guidance Led to Misleading Telework Data, 

but OPM Has Recently Taken Steps to Address This Issue 15

GSA and OPM Provide Services and Resources to Support 

Governmentwide Telework Implementation, but Their Efforts 

Have Not Been Well Coordinated 17

Selected Federal Agencies Are Not Fully Implementing Key 

Telework Practices 22

Agency Officials Identified Governmentwide Actions That Could Be 

Taken to Encourage Federal Agencies to Increase Telework 

Participation 29

Conclusions 29

Recommendations for Agency Action 30

Agency Comments 31

Appendixes

Appendix I: Scope and Methodology 35

Appendix II: Descriptions of Efforts by the Selected Agencies to 

Implement the 25 Key Practices 37

Program Planning 37

Telework Policy 42

Performance Management 46

Managerial Support 47

Training and Publicizing 49

Technology 50

Program Evaluation 54

Appendix III: Comments from the Department of Education 57

Appendix IV: Comments from the Department of Veterans Affairs 58

GAO Responses to Comments from VA 60

Appendix V: Comments from the General Services Administration and the 

Office of Personnel Management 63

GAO Responses to Comments from GSA and OPM 72
Contents

Page ii GAO-03-679 Improving Federal Telework Efforts

Table Table 1: Summary of Services and Resources Provided or Offered 

by GSA and OPM 18

Figures Figure 1: Key Telework Practices for Implementation of Successful 

Federal Telework Programs 5

Figure 2: Extent to Which Selected Agencies Had Implemented Key 

Telework Practices 24

Abbreviations

CFO Chief Financial Officers

DOE Department of Energy 

DOI Department of the Interior 

EIRO E-Connected Intelligent Remote Operations 

EPA Environmental Protection Agency 

GSA General Services Administration 

IT information technology 

ITAC International Telework Association and Council 

OPM Office of Personnel Management 

MSPB U.S. Merit Systems Protection Board 

VA Department of Veterans Affairs

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

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reproduce this material separately.
Page 1 GAO-03-679 Improving Federal Telework Efforts

United States General Accounting Office

Washington, D.C. 20548

A

July 18, 2003 Letr

The Honorable Tom Davis, Chairman

Committee on Government Reform

House of Representatives

Dear Mr. Chairman:

Telework, also referred to as telecommuting or flexiplace, has gained 

widespread attention over the past decade in both the public and private 

sectors as a human capital flexibility that offers a variety of potential 

benefits to employers, employees, and society.1, 2 The term telework refers 

to work that is performed at an employee’s home or at a work location 

other than a traditional office. Using such readily available flexibilities as 

management tools is critical to addressing the federal government’s human 

capital challenges. In the Office of Personnel Management’s (OPM) 2003 

report to Congress on the status of telework in the federal government, the 

Director of OPM described telework as “an invaluable management tool 

which not only allows employees greater flexibility to balance their 

personal and professional duties, but also allows both management and 

employees to cope with the uncertainties of potential disruptions in the 

workplace, including terrorist threats.”3

 

This report is in response to your request that we assess various aspects of 

the progress federal agencies have made in implementing telecommuting 

initiatives. In this regard, and as agreed with your staff, the objectives of 

this report were to (1) characterize the federal laws and their requirements 

that currently apply to telecommuting within the federal agencies in the 

executive branch, (2) determine what the General Services Administration 

(GSA) and OPM are doing, as lead agencies, to coordinate and promote 

telecommuting in the federal government, (3) determine the extent to 

1

Throughout this report, the terms telework, telecommuting, and flexiplace are used 

interchangeably.

2

For more information on telework in the federal government, see U.S. General Accounting 

Office, Federal Workforce: Agencies’ Policies and Views on Flexiplace in the Federal 

Government, GAO/GGD-97-116 (Washington, D.C.: July 3, 1997) and Telecommuting: 

Overview of Challenges Facing Federal Agencies, GAO-01-1116T (Washington, D.C.: Sept. 6, 

2001).

3

U.S. Office of Personnel Management, Report to the Congress: The Status of Telework in 

the Federal Government (Washington, D.C.: Jan. 2003).
Page 2 GAO-03-679 Improving Federal Telework Efforts

which selected federal agencies are implementing key practices in 

developing telecommuting programs, and (4) identify additional 

governmentwide actions that could be taken to encourage federal agencies 

to increase telecommuting participation.

We took several steps to address these objectives. In order to characterize 

the federal laws and their requirements that currently apply to 

telecommuting within the federal agencies in the executive branch, we 

identified and analyzed the relevant laws and discussed the requirements of 

selected laws with agency officials. To determine what GSA and OPM are 

doing to coordinate and promote telecommuting in the federal government, 

we interviewed GSA and OPM officials regarding their governmentwide 

telework efforts and analyzed documents related to these efforts. We 

determined the extent to which selected federal agencies are implementing 

key practices in developing telecommuting programs by first conducting a 

review of literature and guidelines to identify these practices. Then, we 

interviewed agency officials and analyzed documents related to telework 

implementation at four agencies—the Department of Education 

(Education), the Department of Veterans Affairs (VA), GSA, and OPM. 

These agencies were selected for various reasons, including function, size, 

and reported level of telework participation.4

 This agency selection 

process was not designed to produce findings that could be considered 

representative of telework implementation in the federal government as a 

whole, but rather to provide illustrative examples of the extent to which 

selected individual agencies had used the key practices identified in our 

literature review. To identify additional governmentwide actions that could 

be taken to encourage federal agencies to increase telecommuting 

participation, we interviewed officials and union representatives from the 

four selected agencies, as well as other unions representing federal 

employees. Our review was conducted in accordance with generally 

accepted government auditing standards. (See app. I for additional 

information on our scope and methodology.)

4

Size and level of telework participation were determined from survey data collected by 

OPM for its January 2002 report to Congress, entitled The Status of Telework in the Federal 

Government.
Page 3 GAO-03-679 Improving Federal Telework Efforts

Results in Brief A statutory framework including legislation on a wide range of issues 

related to telework began to emerge from Congress in 1990. Within this 

statutory framework, there are provisions that require agencies to take 

certain actions related to telework, provide agencies with tools for 

supporting telework, and provide both GSA and OPM with lead roles in the 

implementation of telework in the federal government. The most 

significant congressional action related to telework was the enactment of 

Sec. 359 of Pub. L. No. 106-346 in October 2000, which provides the current 

mandate for telework in the executive branch of the federal government by 

requiring each executive agency to establish a policy under which eligible 

employees may participate in telework.5 OPM issued guidance to agencies 

in 2001 related to the implementation of this law. However, until recently, 

OPM had not defined a statement contained in that guidance which told 

agencies that eligible employees who wanted to telework must be allowed 

that opportunity. Without such a definition, we found that the agencies we 

reviewed did not use equivalent interpretations of this statement, resulting 

in their reporting incomparable data to OPM. These data were 

subsequently included in OPM’s 2003 report to Congress on the status of 

telework in the federal government. After we discussed this issue with 

OPM officials, OPM reacted promptly by issuing new telework guidelines 

that defined what it meant by allowing this opportunity. If this new 

definition is properly applied by all agencies in reporting data to OPM, this 

should address the issue we found.

As lead agencies for the governmentwide telework initiative, both GSA and 

OPM offer services and resources to support and encourage telework in the 

federal government. Some of the services and resources are offered jointly 

by both GSA and OPM, while others are offered individually by both 

agencies or uniquely by either GSA or OPM. Although GSA and OPM share 

responsibilities for the governmentwide telework initiative and a GSA 

official recently indicated that GSA and OPM have expressed a new 

commitment to working together, their past efforts were not well 

coordinated. For example, a GSA official told us that agencies had 

expressed concern about conflicting messages they had received from GSA 

and OPM on several topics, including dependent care and emergency 

government office closings. With regard to dependent care, officials from 

both GSA and OPM confirmed that they had different positions on this 

5

Section 359 of Pub. L. No. 106-346, October 23, 2000. Hereafter, this section of the law will 

be referred to as Pub. L. No. 106-346.
Page 4 GAO-03-679 Improving Federal Telework Efforts

issue. GSA’s position is that employees can care for dependents when 

teleworking, as long as it does not interfere with accomplishing tasks, 

while OPM’s position was, until recently, that dependents should not be in 

the home when an employee is teleworking. After we discussed these 

conflicting messages with OPM officials, OPM revised its position on this 

issue in the new telework guidelines it released shortly thereafter. These 

guidelines state that while teleworkers should not generally be engaged in 

caregiving activities when working at home, teenagers or elderly 

dependents might be at home when the employee is teleworking, as long as 

those dependents are independently pursuing their own activities. Because 

such lack of coordination can create confusion for agencies and 

employees, we are recommending that the Administrator, GSA, and the 

Director, OPM, ensure that their offices with responsibilities for the 

governmentwide telework initiative better coordinate efforts to provide 

federal agencies with consistent, inclusive, unambiguous support and 

guidance related to telework.

We identified 25 key practices in telework-related literature and guidelines 

that federal agencies should implement in developing successful telework 

programs. For purposes of analysis, we grouped these practices under 

seven categories. (See fig. 1.)
Page 5 GAO-03-679 Improving Federal Telework Efforts

Figure 1: Key Telework Practices for Implementation of Successful Federal Telework Programs

Program planning

• Designate a telework coordinator. 

• Establish a cross-functional project team, including, for example, information technology (IT), union representatives, and other 

stakeholders. 

• Establish measurable telework program goals. 

• Develop an implementation plan for the telework program. 

• Develop a business case for implementing a telework program. 

• Provide funding to meet the needs of the telework program. 

• Establish a pilot program. 

Telework policy

• Establish an agencywide telework policy. 

• Establish eligibility criteria to ensure that teleworkers are selected on an equitable basis using criteria such as suitability of tasks and 

employee performance. 

• Establish policies or requirements to facilitate communication among teleworkers, managers, and coworkers.

• Develop a telework agreement for use between teleworkers and their managers.

• Develop guidelines on workplace health and safety issues to ensure that teleworkers have safe and adequate places to work off-site.

Performance management

• Ensure that the same performance standards, derived from a modern, effective, credible, and validated performance system, are

used to evaluate both teleworkers and nonteleworkers.

• Establish guidelines to minimize adverse impact on nonteleworkers before employees begin to work at alternate worksites.

Managerial support

• Obtain support from top management for a telework program. 

• Address managerial resistance to telework.

Training and publicizing

• Train all involved, including, at a minimum, managers and teleworkers. 

• Inform workforce about the telework program.

Technology

• Conduct assessment of teleworker and organization technology needs. 

• Develop guidelines about whether organization or employee will provide necessary technology, equipment, and supplies for telework.

• Provide technical support for teleworkers. 

• Address access and security issues related to telework. 

• Establish standards for equipment in the telework environment.

Program evaluation

• Establish processes, procedures, and/or a tracking system to collect data to evaluate the telework program.

• Identify problems and/or issues with the telework program and make appropriate adjustments.

Source: GAO analysis of telework-related literature and guidelines.
Page 6 GAO-03-679 Improving Federal Telework Efforts

While all four agencies we reviewed have taken at least some steps to 

implement most of the key practices, many practices remain in need of 

attention. Seven of the key practices, such as establishing a crossfunctional project team and establishing an agencywide telework policy, 

had been fully implemented by all four agencies. However, in each of the 

categories, there were practices that some or all of the agencies had not 

implemented or had only partially implemented. For example, none of the 

agencies reviewed have established measurable program goals or fully 

implemented the practice of training all involved. To enable agencies to 

more effectively implement these practices, we are recommending that 

GSA and OPM use their lead roles in the federal telework initiative to assist 

executive agencies in implementing the key telework practices.

In addition to the key practices we identified as being integral to 

developing successful federal telework programs, we asked agency and 

union officials from the four agencies we reviewed to identify 

governmentwide actions that could be taken to encourage federal agencies 

to increase telework participation. Some of the actions they identified are 

closely related to the key practices we identified, such as the need for 

funding of telework programs, the need for training, and the importance of 

obtaining top-level support for telework. Several officials also commented 

on the need for clarification regarding the implementation of the telework 

provisions in Pub. L. No. 106-346.

We provided a draft of this report in June 2003 to the Secretaries of 

Education and VA, the Administrator, GSA, and the Director, OPM. The 

Director of Human Resources Services from Education provided 

comments via e-mail (see app. III for a summary of these comments). In 

addition, we received written comments from the Secretary, VA, and joint 

written comments from the Administrator, GSA, and the Director, OPM, in 

response to a draft of this report (see app. IV and V). Where appropriate, 

we made changes in our report in response to these comments.

Education generally agreed with the contents of the draft report and stated 

that the department was pleased that we recognized its efforts to advance 

telework. VA agreed with our conclusion that there is a need for further 

guidance and assistance from GSA and OPM regarding federal telework 

implementation and suggested two areas where such guidance would be 

helpful. VA disagreed with several of our findings related to the status of 

VA’s implementation of the telework practices we identified. However, 

when we asked for documentation to support the statements that VA made 

in its comments, VA was unable to provide such information. Absent any 
Page 7 GAO-03-679 Improving Federal Telework Efforts

evidence that would support VA’s comments, our assessment remains 

unchanged.

In their combined comments, GSA and OPM agreed to implement our 

recommendation that they use their lead roles in the federal telework 

initiative to assist agencies in implementing the key telework practices we 

identified. In addition, GSA agreed with our recommendation that it work 

with Congress to determine what was meant by the phrase “GSA 

telecommunication center” in Section 314, Division F, title III of Pub. L. No. 

108-7 and whether this provision is in conflict with the provision contained 

in 40 U.S.C. 587(d)(2). GSA stated that it will coordinate internally and 

with the appropriate congressional committees to resolve the conflicting 

language in the statutes and then provide clarification to its customer 

agencies. On the other hand, both GSA and OPM disagreed with several of 

our findings relating to their lead roles in the governmentwide telework 

initiative. For example, GSA and OPM strongly disagreed with our finding 

that they have not fully coordinated their governmentwide telework efforts 

in the past. This contradicts information that was conveyed to us by 

agency officials during our review. However, we have added to the report, 

where appropriate, to reflect the agencies’ new position on the issue of 

coordination. GSA and OPM also said in their comments that they have 

recognized the need to better outline separate and shared responsibilities 

and that a Memorandum of Understanding was among the options they 

were considering to clearly designate each agency’s responsibilities.

OPM also raised a number of issues with our analysis of its internal 

telework program. In its comments, OPM stated “[E]ach comment listed 

was conveyed to GAO during the interview process.” On the contrary, 

OPM’s written comments, for the most part, contain new information 

and/or information that does not correspond with what was conveyed to us 

by OPM officials during our review. Much of this information contradicts 

what was conveyed to us by agency officials during our review. However, 

we have revised the report where appropriate to reflect OPM’s new 

positions on some issues. While GSA did not disagree with our findings 

pertaining to its internal telework program, the agency did note several 

areas where it would like us to revise statements relative to its 

implementation of the key practices we identified. We considered these 

comments and incorporated new language into the report where 

appropriate.
Page 8 GAO-03-679 Improving Federal Telework Efforts

Background Over the last decade, telework has emerged as a management tool in the 

federal government. Congress and the executive branch have shown 

interest in telework, primarily based upon the belief that its use will benefit 

the federal government. Benefits of telework include reducing traffic 

congestion and pollution, improving recruitment and retention of 

employees, increasing productivity, and reducing the need for office space. 

Employees also can realize benefits from teleworking, including reduced 

commuting time; lowered costs in areas such as transportation, parking, 

food, and wardrobe; removal of barriers for those with disabilities who 

want to be part of the workforce; and improvement in the quality of 

worklife and morale accruing from the opportunity to better balance work 

and family demands. Guidance issued by the Federal Emergency 

Management Agency,6

 along with telework-related literature, also suggests 

that telework programs can facilitate emergency preparedness by helping 

agencies to maintain continuity of operations in emergency situations, 

thereby increasing agencies’ effectiveness. In light of the uncertainties 

facing the United States today, telework can be a particularly relevant and 

useful tool. 

The importance of telework to federal employees has been highlighted in 

recent studies. Based on its 2000 Merit Principles Survey, the U.S. Merit 

Systems Protection Board (MSPB) reported that, of all the family-friendly 

programs studied, telework showed the greatest disparity between 

importance and availability, potentially making it the most desired but least 

available family-friendly program. In addition, the MSPB said that, of all 

the work-life programs it asked about in the survey, only telework 

appeared to have a relationship to employees’ intentions regarding leaving 

their employment in the coming year, with those who considered telework 

important being more likely to plan to leave when it is not available (55 

percent) than when it is available (44 percent).7

 According to OPM’s 2002 

Federal Human Capital Survey, almost 74 percent of federal employee 

respondents said that telework was at least somewhat important to them. 

6

The Federal Emergency Management Agency has recently become part of the new 

Department of Homeland Security under the department’s Emergency Preparedness and 

Response Directorate.

7

U.S. Merit Systems Protection Board, Issues of Merit (Washington, D.C.: Dec. 2000), 4.
Page 9 GAO-03-679 Improving Federal Telework Efforts

Despite this level of importance, more than 59 percent of the respondents 

reported that this flexibility was not available to them.8

 

Since 1990, Congress has supported the telework initiative by holding 

hearings and passing a number of laws related to telework, including laws 

that provided for the establishment and funding of the GSA telework 

centers.9

 Most significant was the Department of Transportation and 

Related Agencies Appropriations Act, 2001, Pub. L. No. 106-346, October 

23, 2000. Section 359 of this law provides the current mandate for telework 

in the executive branch of the federal government. This law, which was to 

be implemented in 25 percent increments over 4 years, required each 

federal agency to “establish a policy under which eligible employees of the 

agency may participate in telecommuting to the maximum extent possible 

without diminished employee performance” and instructed OPM to provide 

for the law’s requirements to be met.

Telework has also received significant attention in the executive branch 

since 1990, when the President’s Council on Management Improvement 

approved plans for the implementation of a governmentwide pilot 

flexiplace program. In the executive branch, telework has been proposed 

as a tool to address a number of issues, including establishing a familyfriendly workplace, reducing traffic congestion and pollution, and enabling 

people with disabilities to join the federal workforce. Currently, GSA and 

OPM share responsibilities for the federal government’s telework initiative, 

providing federal agencies with services and resources related to this 

initiative. To this end, both GSA and OPM have included strategies, goals, 

and measures directly related to their efforts to support the 

governmentwide telework initiative in their fiscal year 2003 annual 

performance plans and their related strategic plans. For example, GSA’s 

fiscal year 2003 performance plan includes a goal to increase the 

percentage of federal employees that telework to 5 percent by the end of 

fiscal year 2003 under its performance goal to increase the number of 

8

U.S. Office of Personnel Management, What do Federal Employees Say: Results from the 

2002 Federal Human Capital Survey (Washington, D.C.: Mar. 2003).

9

See Pub. L. No. 102-393, October 6, 1992, and Sections 5 and 6 of title V of Pub. L. No. 104-

52, November 19, 1995. According to House Report No. 102-618, June 25, 1992, that 

accompanied Pub. L. No. 102-393, telework centers make alternative office-like 

environments available to federal employees to perform their office functions at a site 

closer to their homes. These centers are intended to address traffic congestion issues, as 

well as to confer other benefits, including reduced government real estate costs and a better 

work/life balance for federal employees.
Page 10 GAO-03-679 Improving Federal Telework Efforts

agency programs meeting their social and environmental responsibilities in 

areas of GSA’s Office of Governmentwide Policy responsibility. 

Also among efforts in the executive branch was the formation of an 

Interagency Telework Issues Working Group, with participants from 15 

federal agencies. GSA and OPM jointly established and led this group, 

which canvassed agencies to identify policy actions needed to facilitate 

agency use and expansion of telework. A final report, issued in August 

2002, contained a series of recommendations related to such policy 

actions.10

Interest in and implementation of telework programs has also occurred in 

states and foreign countries. Several states piloted telework programs in 

state government agencies in the mid- to late 1990s and have since 

implemented telework in individual agencies or on a statewide basis. For 

example, in Florida, telework became a permanent option for state 

employees in October 1998 after two 3-year pilot studies. In Europe, about 

6 percent of the workforce was teleworking as of 1999 and, in some 

countries, the participation rate for telework was higher. Finland, for 

example, had a telework participation rate of about 17 percent of the 

workforce in 1999. However, only 4 percent of all teleworkers in European 

countries worked for government entities.

According to OPM’s January 2003 report to Congress on the status of 

telework in the federal government, 77 executive agencies reported that, as 

of November 2002, 90,010 of their employees teleworked on either a regular 

or episodic basis,11 which is 5 percent of those agencies’ 1,806,192 

employees.12 The U.S. Department of Labor reported that, in May 2001, 19.8 

million persons, accounting for 15 percent of total employment, usually did 

some work at home as part of their job. However, only 17 percent of these 

10Interagency Telework Issues Working Group, Interagency Governmentwide Policy 

Review on Telework and Telework-Related Issues (Washington, D.C.: Aug. 2002).

11Episodic telework refers to a situation in which a teleworker does not telework on a 

regularly scheduled basis. This type of arrangement is also referred to by a variety of 

names, including “ad hoc,” “intermittent,” “occasional,” and “as needed.”

12U.S. Office of Personnel Management, Report to the Congress: The Status of Telework in 

the Federal Government (Jan. 2003).
Page 11 GAO-03-679 Improving Federal Telework Efforts

workers had a formal arrangement with their employer to be paid for the 

work they did at home.13

Federal Laws and Their 

Requirements Cover a 

Gamut of Telework 

Issues

Legislation related to telework began to emerge from Congress in 1990.14 

Since then, these provisions have typically, but not always, been included 

in a variety of appropriations acts and have covered a wide range of issues 

related to telework. The statutory framework for telework includes 

provisions that require agencies to take certain actions related to telework, 

provide agencies with tools for supporting telework, and provide both GSA 

and OPM with lead roles in the implementation of telework in the federal 

government.

Within this framework, the most significant congressional action was the 

enactment of Section 359 of Pub. L. No. 106-346 in October 2000, which 

provides the current mandate for telecommuting in the executive branch of 

the federal government. This law, for the first time, required each 

executive branch agency to establish a telework policy “under which 

eligible employees of the agency may participate in telecommuting to the 

maximum extent possible without diminished employee performance.”15 It 

also directed OPM to provide that the law’s requirements were applied to 

25 percent of the federal workforce by April 2001 and to an additional 25 

percent of the federal workforce in each subsequent year, until 2004 when 

the law is to be applied to 100 percent of the federal workforce. The 

requirements of this law should also be considered in combination with its 

conference report and guidance that has been issued by OPM. 

13U.S. Department of Labor, Bureau of Labor Statistics, Work at Home in 2001, USDL 02-107 

(Washington, D.C.: Mar. 1, 2002), http://www.bls.gov/news.release/homey.nr0.htm

(downloaded July 1, 2003). Half of those who usually worked at home were wage and salary 

workers who took work home on an unpaid basis. Another 30 percent of those who worked 

at home were self-employed. 

14Congressional committees have also held hearings on telework. The House Education and 

the Workforce Committee, Subcommittee on Oversight and Investigations, held a series of 

hearings in 1999 and 2000 to examine barriers to telework implementation in federal 

agencies. In 2001, the House Government Reform Committee, Subcommittee on 

Technology and Procurement Policy, held two hearings to examine the efforts of federal 

government agencies in creating and promoting telework programs. GAO testified at one of 

these hearings in September 2001. (See GAO-01-1116T.)

15Section 359 of Pub. L. No. 106-346, October 23, 2000.
Page 12 GAO-03-679 Improving Federal Telework Efforts

The conference report accompanying Pub. L. No. 106-346 stated that 

agencies shall “develop criteria to be used in implementing [a 

telecommuting] policy” and “ensure that managerial, logistical, 

organizational, or other barriers to full implementation and successful 

functioning of the policy are removed.”16 Furthermore, it stated that 

agencies “should also provide for adequate administrative, human 

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

also clarified what constitutes eligibility for telework by defining an eligible 

employee as “any satisfactorily performing employee of the agency whose 

job may typically be performed at least one day per week [by 

telecommuting].”

On February 9, 2001, OPM sent a memorandum to department and agency 

heads containing guidance on the requirements of Pub. L. No. 106-346 that 

directed agencies to examine the barriers that inhibit the use of 

telecommuting, act to remove them, and increase participation. This 

memorandum went on to say, “The law recognizes that not all positions are 

appropriate for telecommuting; therefore, each agency must identify 

positions that are appropriate in a manner that focuses on broad objective 

criteria. Once an agency has established eligibility criteria, subject to any 

applicable agency policies or bargaining obligations, employees who meet 

them and want to participate must be allowed that opportunity if they are 

satisfactory performers.” OPM recently clarified this statement in a 

publication entitled, Telework: A Management Priority—A Guide for 

Managers, Supervisors, and Telework Coordinators. This guide, which 

was released on May 8, 2003, indicates that agencies should offer eligible 

employees the opportunity to telework by having supervisors extend the 

option of teleworking to all employees they determine are eligible, using 

established criteria.17

16Section 359 of H.R. Report No. 106-940, October 5, 2000.

17U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for 

Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003), 2, 25.
Page 13 GAO-03-679 Improving Federal Telework Efforts

Congress also passed other laws that require agencies to take certain 

actions related to telework. One such provision requires executive 

agencies to consider whether needs for additional space can be met using 

alternative workplace arrangements, such as telework.18 Another recent 

provision, contained in the fiscal year 2003 appropriations for the 

Departments of Commerce, Justice, and State, the Judiciary, and the Small 

Business Administration, makes $100,000 available to each of the 

departments and agencies covered by this provision only for the 

implementation of telecommuting programs. These departments and 

agencies are required to provide the committees on appropriations with a 

report on the status of their telecommuting programs every 6 months and 

to designate a “Telework Coordinator” to oversee the implementation of 

telecommuting programs.19

In addition to these provisions, another provision directs executive 

agencies to make a minimum of $50,000 available annually for the 

necessary expenses to carry out telecommuting programs, which would 

permit employees of 20 specified federal departments and agencies, 

including Education, GSA, OPM, VA, the Department of the Interior (DOI), 

and the Department of Energy (DOE), to perform all or a portion of their 

duties at GSA telework centers.20 However, a provision has been included 

in the appropriations acts for DOI and related agencies since fiscal year 

2001 prohibiting several departments and agencies, including DOI and 

DOE, from using appropriated funds for the use of “GSA 

telecommunication centers.”21 GSA officials believe that the provisions 

contained in these appropriations laws were intended to apply to GSA 

telework centers. However, this remains unclear, because these statutes 

pertain to “GSA telecommunication centers,” which is not a title by which 

the GSA telework centers are known. At least in some instances, though, 

this provision has not been applied to the telework centers. OPM’s January 

2003 report to Congress identified two of the agencies prohibited from 

1840 U.S.C. 587(c)(2).

19Section 623, Division B, title VI of Pub. L. No. 108-7, February 20, 2003.

2040 U.S.C. 587(d)(2).

21See Section 323 of Pub. L. No. 106-291, October 11, 2000; Section 319 of Pub. L. No. 107-63, 

November 5, 2001; and Section 314, Division F, title III of Pub. L. No. 108-7, February 20, 

2003. A similar provision was also included in Section 324 of title III of the Appendix to Pub. 

L. No. 106-113, November 29, 1999.
Page 14 GAO-03-679 Improving Federal Telework Efforts

using funds as described by this provision—DOI and DOE—as having 

provided funds for telework center usage fees in fiscal year 2002.

Generally, when statutory provisions in separate laws are in conflict, as 

may be the case with the laws detailed above, the requirements of the most 

recently passed law supercede the requirements of the earlier law. In this 

case, the provision prohibiting the use of funds for “GSA 

telecommunication centers” would take precedence over the provision that 

requires specified agencies to make $50,000 available annually for use of 

the GSA telework centers, but only for those departments or agencies that 

are common to both provisions. However, because of the lack of a 

definition or explanation for “GSA telecommunication centers” in the 

appropriations law and the fact that the legislative history does not provide 

any insight, it is not clear whether the provisions are in conflict. Given that 

both of these provisions refer to one or more types of GSA operations, GSA 

should work with Congress to determine what was meant by the phrase 

“GSA telecommunication centers” and then issue guidance to the relevant 

agencies to clarify these provisions and explain the impact of these laws on 

agencies’ telework programs. 

Congress has also provided agencies with several tools to support 

telework. For example, federal agencies were authorized to spend money 

for installation of telephone lines, related equipment, and monthly charges 

for federal teleworkers through legislation that was originally enacted in 

1990 and made permanent in 1995.22 In 1992, Congress established the first 

federal telework centers, which were to be maintained by GSA.23 Since 

then, Congress has passed several laws to continue funding the centers, 

change the formula for funding the centers, and add new telework center 

locations.24

22Section 620 of Pub. L. No. 104-52, November 19, 1995, 31 U.S.C. 1348 note.

23Pub. L. No. 102-393, October 6, 1992.

24See, for example, Pub. L. No. 103-123, October 26, 1993; Sections 5 and 6 of title V of Pub. L. 

No. 104-52, November 19, 1995; Section 407 of Pub. L. No. 104-208, September 30, 1996; and 

Section 411 of Pub. L. No. 105-277, October 21, 1998.
Page 15 GAO-03-679 Improving Federal Telework Efforts

The legislative framework for telework also contains provisions that 

provide both GSA and OPM with lead roles in the implementation of 

telework in the federal government. As stated above, Pub. L. No. 106-346 

directs OPM to provide that the requirements of the law are applied as 

specified with regard to the federal workforce. In addition, $500,000 of the 

money appropriated for OPM’s salaries and expenses for fiscal year 2003 is 

intended to be used by OPM to provide a telecommuting training program 

to educate managers in executive branch agencies, where less than 2 

percent of employees telework, about the benefits and logistics of 

telework.25 According to OPM’s comments on a draft of this report, the 

agency plans to conduct focus groups for managers in four locations across 

the country this summer to identify reasons why some managers resist 

permitting telework. OPM plans to use the focus group data to tailor 

agency telework training. OPM indicated that it plans to train agencies’ 

human resources directors and telework coordinators and provide them 

promotional telework materials. Congress has also provided GSA with a 

lead role in the federal government’s telework initiative, giving the agency 

responsibility for maintaining the federal telework centers and the 

authority to provide guidance, assistance, and oversight regarding the 

establishment and operation of telework and other distributive work 

arrangements.26

Lack of Clarity in OPM 

Guidance Led to 

Misleading Telework 

Data, but OPM Has 

Recently Taken Steps 

to Address This Issue

Until recently, OPM had not defined a statement contained in its February 

2001 guidance regarding the implementation of Pub. L. No. 106-346, which 

told agencies that employees who wanted to participate in teleworking 

must be allowed that opportunity. Without such a definition, we found that 

the agencies we reviewed did not use equivalent interpretations of this 

statement, resulting in their reporting incomparable data to OPM. These 

data were subsequently included in OPM’s 2003 report to Congress on the 

status of telework in the federal government. After we discussed this issue 

with OPM officials, OPM reacted promptly by issuing new guidelines that 

defined what it meant by allowing this opportunity.

Our discussions with officials at the four agencies we reviewed and 

analysis of data in OPM’s January 2003 report to Congress revealed that, 

without a definition from OPM regarding what constituted being allowed 

25H.R. Report No. 108-10, February 13, 2003, p. 1352.

26Pub. L. No. 102-393, October 6, 1992; 40 U.S.C. 587(b)(1) and (c)(3).
Page 16 GAO-03-679 Improving Federal Telework Efforts

the opportunity to telework, agencies had not always used equivalent 

interpretations of this statement in reporting their data. For example, 

telework program officials at both GSA and OPM told us that, for their 

internal programs, they considered eligible employees to have been 

allowed the opportunity to telework if they chose to apply for telework or 

discuss the option of teleworking with their managers, regardless of 

whether they were actually approved for telework. In keeping with this 

interpretation, these two agencies reported, in response to OPM’s 2002 

governmentwide telework survey, that essentially the same number of 

employees who were eligible for telework had also been given that 

opportunity. On the other hand, Education and VA reported significant 

differences between the number of employees who were eligible for 

telework and those who were given the opportunity to telework, which 

demonstrated that they were using different interpretations of opportunity 

than GSA and OPM. Because these agencies were not applying equivalent 

interpretations of the term “opportunity,” the data that they provided in 

response to OPM’s survey and that OPM included in its report to Congress 

were not comparable across agencies. Moreover, OPM’s 2003 report to 

Congress showed these data as the number of eligible employees “offered” 

telework, although OPM had not made it clear, in either the survey or in its 

previously issued guidance, that agencies should interpret allowing the 

opportunity to mean directly offering eligible employees the option to 

telework. Furthermore, characterizing all agencies’ data in this manner is 

misleading because, as shown above, some agencies did not use that 

interpretation in reporting the data.

We met with OPM officials in late April 2003 and informed them that the 

lack of a written definition of what OPM meant when it asked agencies to 

report how many eligible employees had been allowed the opportunity to 

telework had resulted in incomparable telework data. To its credit, OPM 

reacted promptly by defining the statement in a set of frequently asked 

questions that were distributed at its quarterly telework coordinators’ 

meeting on May 6, 2003, and in a new telework guide for managers, 

supervisors, and telework coordinators that was released 2 days later.27 

Both the frequently asked questions and the guide indicate that agencies 

should offer eligible employees the opportunity to telework by having 

supervisors extend the option of teleworking to all employees they 

determine are eligible, using established criteria. To ensure that the 

27U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for 

Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).
Page 17 GAO-03-679 Improving Federal Telework Efforts

information contained in the guide reaches all federal telework 

coordinators, an OPM official said that a hard copy of this guide would be 

mailed to each coordinator. In addition, the guide has been posted at

www.telework.gov. 

OPM also further clarified the statement about allowing eligible employees 

an opportunity to telework by including a definition in the draft survey it 

plans to send to agencies in the fall to obtain data for its January 2004 

status report to Congress. Immediately following our meeting with OPM 

officials, this draft survey was distributed at OPM’s May 2003 quarterly 

telework coordinators meeting. As in last year’s survey, respondents would 

be asked for the number of eligible employees given the opportunity to 

telework. However, the following additional wording has been proposed 

for that question: “How many eligible employees are given the opportunity 

to telework, i.e. are actively asked if they wish to telework or are able to 

telework because their supervisor informed them they could telework on 

some basis?” If this new definition is properly applied by all agencies in 

reporting data to OPM, this should address the issue we found. Also 

included in the draft survey are two new proposed questions related to 

allowing employees the opportunity to telework. These questions ask how 

employees were presented with the option to telework and how many 

turned it down. 

The steps taken by OPM in response to our findings show a ready 

willingness to address issues that are hindering telework implementation. 

Continued efforts by OPM to publicize these new telework guidelines will 

help to ensure that telework coordinators in federal agencies have a clear 

understanding of the information they need to fully implement their own 

telework programs.

GSA and OPM Provide 

Services and 

Resources to Support 

Governmentwide 

Telework 

Implementation, but 

Their Efforts Have Not 

Been Well Coordinated

As discussed earlier, the legislative framework for telework has provided 

both GSA and OPM with lead roles in the implementation of telework in the 

federal government, providing each agency with responsibilities for the 

telework initiative. Given these responsibilities, GSA and OPM provide 

federal agencies with a range of services and resources related to this 

initiative. Table 1 summarizes their efforts in this regard.
Page 18 GAO-03-679 Improving Federal Telework Efforts

Table 1: Summary of Services and Resources Provided or Offered by GSA and OPM

Source: GAO analysis of testimonial evidence and/or information and documentation collected.

As shown in table 1, some of the services and resources are offered jointly 

by both agencies, while others are offered individually by both agencies or 

uniquely by either GSA or OPM. For example, each of these agencies 

independently provides consulting, marketing, and training services, but 

only OPM has undertaken an outreach effort to meet face to face with 

agencies’ telework coordinators and GSA has sole responsibility for federal 

telework centers. 

Services and resources provided jointly by GSA and OPM GSA and OPM

Run a Web site (www.telework.gov), which was designed to provide 

information and guidance

X

Established and led the Interagency Telework Issues Working Group, 

which canvassed agencies to examine existing policies and produced 

a report with a series of recommendations in August 2002

X

Services and resources provided individually by GSA and/or OPM GSA OPM

Provides guidelines for agencies implementing telework programs X X

Conducts telework-related research and produces reports on telework 

issues

X X

Conducts and participates in seminars X X

Develops telework training materials X X

Provides customer support and consulting X X

Provides general promotion, advocacy, and outreach (promotion of 

telework policy through publications, speaking engagements, 

brochures, conferences, etc.)

X X

Is responsible for federal telework centers, including managing and 

encouraging other agencies to use the centers

X

Offered agencies a free 60-day trial period of the telework centers from 

March through June 2002

X

Established and maintains a mailing list server for telework 

coordinators

X

Developed a list of agencies’ telework coordinators X

Has an agency outreach initiative to assess program barriers and 

successes at federal agencies

X

Hosts quarterly telework coordinators’ meetings X
Page 19 GAO-03-679 Improving Federal Telework Efforts

In addition, although a GSA official told us that GSA has been promoting its 

E-Connected Intelligent Remote Operations (EIRO) feature as a mobile 

solution for government agencies, we found that this feature was not 

functioning for a period of at least 5 months in 2003. According to its Web 

site,28 EIRO was supposed to have launched in March 2001 and was 

intended to offer services and products from GSA Federal Supply 

Schedules29 for mobile government work, including telework. The EIRO 

Web site also states that customers seeking mobile solutions could identify 

providers that are highlighted as EIRO contractors by the EIRO logo at 

“GSA Advantage!”, GSA’s online shopping and ordering system; however, a 

GSA official told us that this function was never operational. Also, 

although this official told us that EIRO had launched on schedule, from a 

period of at least January 2003 through May 2003, we observed that this 

feature was not functional. We asked numerous GSA officials about the 

status of this feature, but they were all unaware of the problems we were 

experiencing. In fact, one official told us that GSA had been promoting 

EIRO to federal agencies as if it were a functioning feature. Ultimately, a 

GSA official told us that changes to the agency’s Web portals must have 

disabled the EIRO feature and assured us that GSA is pursuing solutions to 

get it back online.

Although GSA and OPM share responsibilities for the governmentwide 

telework initiative and a GSA official recently indicated that GSA and OPM 

have expressed a new commitment to working together, their past efforts 

did not always demonstrate coordination. According to officials at both 

agencies, GSA and OPM have not developed a Memorandum of 

Understanding or other formal agreement regarding their responsibilities 

for the federal government’s telework initiative or regarding which agency 

will provide specific services, resources, and guidance. Therefore, these 

agencies have not established a delineation of their respective roles. In 

comments on a draft of this report, GSA and OPM said that they have 

recognized the need to better outline separate and shared responsibilities 

and that a Memorandum of Understanding was among the options they 

were considering to clearly designate each agency’s responsibilities.

28www.eiro.gsa.gov.

29GSA’s Federal Supply Schedules are contracts that allow federal customers to acquire 

services and products directly from commercial suppliers.
Page 20 GAO-03-679 Improving Federal Telework Efforts

Despite the fact that GSA and OPM hold quarterly partnership meetings to 

discuss telework-related issues in the federal government, officials from 

both agencies told us that very little coordination has occurred at these 

meetings. Rather, the meetings have actually served as a means to raise 

differences of opinion that have been identified by either agency, but the 

resolution of those differences has proven to be difficult. In addition, 

according to the GSA and OPM officials, these meetings are used to present 

updates on the status of the two agencies’ independent governmentwide 

telework efforts, not to collaborate on these efforts. On occasion, officials 

from each agency have asked officials from the other agency to provide 

comments on their independent draft guidelines or other information. 

In addition, a GSA official told us that agencies had expressed concern 

about conflicting messages they had received from GSA and OPM on 

several topics, including dependent care and emergency government office 

closings. For example, officials from both GSA and OPM confirmed that 

they had different positions with regard to dependent care. GSA’s position 

is that employees can care for dependents when teleworking, as long as it 

does not interfere with accomplishing tasks, while OPM’s position was, 

until recently, that dependents should not be in the home when an 

employee is teleworking. An OPM official told us that the agency held this 

position because having dependents in the home while teleworking could 

foster managerial resistance to telework. In its recently released telework 

guide for managers, supervisors, and telework coordinators, OPM revised 

its position on this issue, stating that a teenager or elderly dependent might 

be at home while the employee teleworks if those dependents are 

independently pursuing their own activities. It also said that teleworkers 

should not generally be engaged in caregiving activities while working and 

that dependent care arrangements should not typically change because the 

employee is teleworking.

Also, despite the fact that both GSA and OPM shared responsibility for 

developing the governmentwide telework information Web site 

(www.telework.gov), a GSA official told us that OPM, which hosts the joint 

Web site, independently changed the layout and content of the site in late 

2002 without consulting with or informing GSA about the changes. The 

GSA official also said that GSA subsequently met with OPM and the 

contractor that redesigned the site to try to resolve some of GSA’s 

concerns. According to the official, the contractor ultimately agreed with 

GSA and recommended that OPM make changes to the site, because it 

looked too much like an OPM site and not like the telework site for the 

entire federal government. While an OPM official confirmed this 
Page 21 GAO-03-679 Improving Federal Telework Efforts

information, she said that OPM has rejected these changes because of 

“internal Web design policies.” In their combined comments on a draft of 

this report, however, GSA and OPM indicated that there was no 

disagreement regarding the Web site and that “both agencies continue to 

actively and successfully collaborate on www.telework.gov.”

Furthermore, a GSA official told us that GSA had asked OPM to place a link 

to the Interagency Telework Issues Working Group report on the 

governmentwide telework Web site, but OPM had refused to do so, despite 

the fact that the working group was jointly formed by both agencies. An 

OPM official told us that OPM has been hesitant to post this report because 

many of its recommendations were directed at OPM and could not be 

readily implemented. In their combined comments on a draft of this report, 

however, GSA and OPM said that the two agencies had jointly determined it 

would be inappropriate to post the “pre-decisional” Interagency Telework 

Issues Working Group report on the federal telework information Web site 

until they had had the opportunity to analyze its findings, address issues 

contained therein, and fully consider all recommendations. GSA, though, 

has already independently posted this report on its own Web site with a 

disclaimer, stating: “This final report does not in any way, specific or 

implied, represent the official views, positions, or policies of the U.S. 

Government, OPM, GSA, nor any of the agencies participating on the 

Working Group. This report is currently under review by both OPM and 

GSA.” Given that GSA and OPM co-led this group with participation from 

15 federal agencies to identify policy actions needed to facilitate agency 

use and expansion of telework and then make recommendations, we 

believe that the report should be posted on www.telework.gov, with the 

same or a similar disclaimer, in the interests of transparency.

After we discussed the issues created by the lack of coordination between 

GSA and OPM with both agencies, a GSA official indicated that GSA and 

OPM expressed a new commitment to coordination, especially with regard 

to the governmentwide telework Web site. Such a commitment reflects a 

promising start for better assisting federal agencies in improved 

implementation of their telework programs. However, the key to success 

will be sustained efforts by both agencies to work together in assisting 

agencies and providing consistent and straightforward guidance, services, 

and resources on the governmentwide telework initiative. Conflicts that 

have arisen from the lack of coordination in the past underscore the need 

for GSA and OPM to work together to reach a formal agreement 

establishing a delineation of their respective roles regarding the 

governmentwide telework initiative in areas where their respective 
Page 22 GAO-03-679 Improving Federal Telework Efforts

responsibilities are not clear. In areas where the responsibility is clearly 

aligned with the mission of a particular agency, that agency should be 

responsible for providing official guidance related to telework. However, 

the agencies should consult with each other and attempt to reach 

consensus in providing that guidance. Care should be taken to avoid 

situations in which agencies are either left without needed guidance or 

provided with conflicting guidance because GSA and OPM cannot reach 

agreement.

Selected Federal 

Agencies Are Not Fully 

Implementing Key 

Telework Practices

We identified 25 key practices in telework-related literature and other 

sources as those that federal agencies should implement in developing 

their individual telework programs.30 For the purposes of analysis, we 

grouped the key practices into the following seven categories: program 

planning, telework policy, performance management, managerial support, 

training and publicizing, technology, and program evaluation. Based on our 

interviews with agency officials at four selected agencies—Education, 

GSA, OPM, and VA—and review of program documentation and other 

information related to those agencies, we then determined the extent to 

which the agencies had implemented each of the practices that were 

identified in developing their telework programs.

While all four agencies we reviewed have taken at least some steps to 

implement most of the key practices, we found that only 7 of the 25 key 

practices had been fully implemented by all four agencies. Our analysis 

also revealed that almost half of the key practices had not been fully 

implemented by at least three of the four agencies, demonstrating a need 

for these agencies to focus greater attention on the remaining key practices 

to develop successful telework programs. Although some telework-related 

resources from GSA and OPM, including GSA’s telework implementation 

manual and OPM’s recently released telework guide for managers, 

supervisors, and telework coordinators, already provide federal agencies 

with information on how to implement several of the key practices we 

30The 25 key practices identified for telework programs are also closely aligned with 6 key 

practices we have identified in our earlier work for effectively using human capital 

flexibilities. See U.S. General Accounting Office, Human Capital: Effective Use of 

Flexibilities Can Assist Agencies in Managing Their Workforces, GAO-03-2 (Washington, 

D.C.: Dec. 6, 2002) and Managing for Results: Building on the Momentum for Strategic 

Human Capital Reform, GAO-02-528T (Washington, D.C.: Mar. 18, 2002).
Page 23 GAO-03-679 Improving Federal Telework Efforts

identified, agencies may need additional guidance, guidelines, and/or 

individualized technical support to fully implement these practices. 

Regular attention to the practices we identified can help to foster program 

growth and remove barriers to telework participation. Figure 2 illustrates 

the extent to which the agencies reviewed had implemented each of the 

practices.
Page 24 GAO-03-679 Improving Federal Telework Efforts

Figure 2: Extent to Which Selected Agencies Had Implemented Key Telework Practices

Categories and practices 

Program planning 

Designate a telework coordinator. 

Establish a cross-functional project team, including, for example, IT, union representatives, and other stakeholders.

Establish measurable telework program goals. 

Develop an implementation plan for the telework program. 

Develop a business case for implementing a telework program. 

Provide funding to meet the needs of the telework program. 

Establish a pilot program. 

Telework policy 

Establish an agencywide telework policy. 

Establish eligibility criteria to ensure that teleworkers are selected on an equitable basis using criteria such as suitability of tasks and 

employee performance. 

Establish policies or requirements to facilitate communication among teleworkers, managers, and coworkers. 

Develop a telework agreement for use between teleworkers and their managers. 

Develop guidelines on workplace health and safety issues to ensure that teleworkers have safe and adequate places to work off-site. 

Performance management 

Ensure that the same performance standards, derived from a modern, effective, credible, and validated performance system, are used to 

evaluate both teleworkers and nonteleworkers. 

Establish guidelines to minimize adverse impact on nonteleworkers before employees begin to work at alternate worksites. 

Managerial support 

Obtain support from top management for a telework program. 

Address managerial resistance to telework. 

Training and publicizing 

Train all involved, including, at a minimum, managers and teleworkers. 

Inform workforce about the telework program. 

Technology 

Conduct assessment of teleworker and organization technology needs. 

Develop guidelines about whether organization or employee will provide necessary technology, equipment, and supplies for telework. 

Provide technical support for teleworkers. 

Address access and security issues related to telework. 

Establish standards for equipment in the telework environment. 

Program evaluation 

Establish processes, procedures, and/or a tracking system to collect data to evaluate the telework program. 

Identify problems and/or issues with the telework program and make appropriate adjustments. 

Education 

GSA 

OPM 

VA

Source: GAO analysis of testimonial evidence and/or information and documentation collected.

Agency has fully implemented this practice

Agency has taken some steps to implement this practice

Agency has not taken any steps to implement this practice

Could not assess
Page 25 GAO-03-679 Improving Federal Telework Efforts

Importantly, the table above is intended to provide an overall summary of 

the history and status of the telework programs at the respective agencies. 

For some of the practices that are historical in nature, such as developing 

an implementation plan and establishing a pilot program, we recognize that 

agencies with existing telework programs cannot, and should not, attempt 

to implement these practices at this point. However, existing programs 

that did not initially implement some of the more developmental practices 

can still be successful with sustained attention to the other practices we 

identified. Below is a summary of the practices contained in each category 

and an overview of what we found for each practice. Appendix II also 

includes a detailed discussion of the steps each agency has taken to 

implement the practices.

Program Planning In planning for an effective telework program, agencies need to take 

several important steps. Agencies should designate a telework 

coordinator, establish a cross-functional project team, establish 

measurable telework program goals, develop an implementation plan for 

the telework program, develop a business case for implementing a 

telework program, provide funding to meet the needs of the telework 

program, and establish a pilot program. As shown in figure 2, our analysis 

of the telework programs at the four agencies reviewed revealed that only 

two of the seven practices in the program planning category—designating a 

telework coordinator and establishing a cross-functional project team—

have been fully implemented by all of these agencies. The remaining five 

practices, including establishing measurable program goals and providing 

funding to meet the needs of the telework program, still need to be 

implemented by some or all of the agencies.

Telework Policy According to Pub. L. No. 106-346, agencies must establish a telework policy 

that allows eligible employees to participate in telework. Telework-related 

literature suggests that, in addition to or within an agencywide telework 

policy, agencies should establish eligibility criteria to ensure that 

teleworkers are selected on an equitable basis using criteria such as 

suitability of tasks and employee performance; establish policies or 

requirements to facilitate communication among teleworkers, managers, 

and coworkers; develop a telework agreement for use between teleworkers 

and their managers; and develop guidelines on workplace health and safety 

issues to ensure that teleworkers have safe and adequate places to work 

off-site. As shown in figure 2, our analysis indicates that two of the five 

practices in this category, including establishing an agencywide telework 
Page 26 GAO-03-679 Improving Federal Telework Efforts

policy, have been fully implemented by all of the agencies. The remaining 

three practices, including establishing eligibility criteria to ensure that 

teleworkers are selected on an equitable basis, still need additional 

attention to be fully implemented by some or all of the agencies we 

reviewed. 

Performance Management Our recent work identified key practices that high-performing 

organizations need to employ to develop effective performance 

management systems. Such a system should be designed, implemented, 

and continually assessed by how well it helps the employees help the 

organization achieve results and pursue its mission.31 Using standards 

derived from a modern, effective, credible, and validated performance 

system, telework-related literature suggests that agencies need to take 

steps to ensure that the same performance standards are used to evaluate 

both teleworkers and nonteleworkers. In addition, agencies need to 

establish guidelines to minimize adverse impacts that telework can have on 

nonteleworkers before employees begin to work at alternate worksites. 

Figure 2 shows that two of the four agencies we reviewed have taken some 

steps to implement the practice of setting the same performance standards 

for teleworkers and nonteleworkers and three of the four agencies had 

fully implemented the practice of establishing guidelines to minimize 

adverse impacts of telework on nonteleworkers.

Managerial Support Telework-related literature has shown that it is critical to obtain support 

from top management and to address managerial resistance in establishing 

an effective telework program. As our earlier work has shown, and others 

recognize, changes in an organization’s culture, such as the acceptance of 

flexibilities like telework by managers throughout the organization, are 

highly dependent on top management’s support for and commitment to 

31U.S. General Accounting Office, Results-Oriented Cultures: Creating a Clear Linkage 

between Individual Performance and Organizational Success, GAO-03-488 (Washington, 

D.C.: Mar. 14, 2003).
Page 27 GAO-03-679 Improving Federal Telework Efforts

those changes.32 In addition, our 1997 report on agencies’ policies and 

views on telework in the federal government identified managerial 

resistance as the largest barrier to implementing telework.33 This 

resistance can be attributed to several factors, including general resistance 

to change, since telework requires managers to shift from managing by 

observation to managing by results. However, as shown in figure 2, both of 

these practices still need attention by most of the agencies we reviewed.

Training and Publicizing Because telework involves new ways of working, as well as supervising, 

telework-related literature suggests that both employees and supervisors 

should receive training to ensure a common understanding of the program. 

The Interagency Telework Issues Working Group report highlighted the 

need for telework training in its report. In addition, the report states that 

telework training should consist of two key components. One of these 

components should address policy issues and include general information, 

such as policy updates and an orientation to telework, while the other 

component should focus on telework program activities, including such 

topics as information technology (IT) applications, performance 

management, and time management. Telework-related literature also 

suggests that it is important to inform the workforce about the telework 

program. Despite their importance, figure 2 illustrates that both of these 

practices still need attention by some or all of the agencies we reviewed.

Technology OPM’s January 2003 report to Congress on the status of telework in the 

federal government identified data security and IT issues as the two most 

frequently cited barriers to telework, as reported by federal agencies. In 

32See, for example, the following GAO products: Human Capital: Effective Use of 

Flexibilities Can Assist Agencies in Managing Their Workforces, GAO-03-2 (Washington, 

D.C.: Dec. 6, 2002); A Model of Strategic Human Capital Management—Exposure Draft, 

GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); Managing for Results: Next Steps To 

Improve the Federal Government’s Management and Performance, GAO-O2-439T

(Washington, D.C.: Feb. 15, 2002); and Human Capital: Practices That Empowered and 

Involved Employees, GAO-01-1070 (Washington, D.C.: Sept. 14, 2001). Also see Booz Allen 

Hamilton, Analysis of Home-Based Telework Technology Barriers: Final Report on 

Technology Barriers to Home-Based Telework (Washington, D.C.: Apr. 5, 2002) and U.S. 

Environmental Protection Agency, Telecommuting/Telework Programs: Implementing 

Commuter Benefits under the Commuter Choice Leadership Initiative (Washington, D.C.: 

Sept. 2001).

33GAO/GGD-97-116.
Page 28 GAO-03-679 Improving Federal Telework Efforts

addressing technology barriers, telework-related literature suggests that 

agencies should conduct an assessment of teleworker and organization 

technology needs; develop guidelines about whether the organization or 

employee will provide necessary technology, equipment, and supplies for 

telework; provide technical support for teleworkers; address access and 

security issues related to telework; and establish standards for equipment 

in the telework environment. Generally, as shown in figure 2, the four 

agencies we reviewed did better in this category than in any other. One of 

the agencies—Education—has fully implemented all of the technology 

practices and the other three agencies each have only one practice out of 

the five that had not been fully implemented. However, given the rapidly 

changing nature of technology and the fact that, in OPM’s 2002 telework 

survey, many agencies governmentwide identified data security and IT as 

barriers to growth in their telework programs, federal agencies should 

provide specific and ongoing attention to these technology practices.

Program Evaluation Telework-related literature recommends that agencies develop program 

evaluation tools and use such tools from the very inception of the program 

to identify problems or issues with the program and to develop an action 

plan to guide any necessary changes for telework or for the organization. 

The literature also emphasizes the need for tracking systems that can help 

to accurately ascertain the status of telework implementation in the 

agencies and, subsequently, the federal government. Such a tracking 

system should include, at the very least, a formal head count of regular and 

episodic teleworkers, as well as nonteleworkers. To this end, the 

Interagency Telework Issues Working Group report recommended that 

OPM require all federal agencies to establish a system for collecting the 

information that OPM requests for its annual report to Congress on the 

status of telework in the federal government. It further recommended that 

OPM provide agencies with the necessary specifications, guidance, and 

technical assistance to establish these systems.

Despite the fact that accurate data are absolutely integral to assessing the 

status of a telework program and identifying areas that require additional 

attention, figure 2 shows that none of the agencies we reviewed have fully 

implemented the practice of establishing processes, procedures, and/or a 

tracking system to evaluate their telework programs. In addition, all of the 

four agencies still need to take at least some steps to fully implement the 

practice of identifying problems and/or issues with their telework 

programs and making appropriate adjustments.
Page 29 GAO-03-679 Improving Federal Telework Efforts

Agency Officials 

Identified 

Governmentwide 

Actions That Could Be 

Taken to Encourage 

Federal Agencies to 

Increase Telework 

Participation

In addition to the key practices we identified as being integral to 

developing successful federal telework programs, we asked agency 

program officials and union representatives at GSA, Education, OPM, and 

VA for their views on what governmentwide actions could be taken to 

increase telework participation in federal agencies. We also spoke with 

officials representing federal employees governmentwide, such as the 

National Treasury Employees Union and the National Federation of 

Federal Employees, to obtain their views on potential governmentwide 

actions. In addition, OPM’s November 2002 telework survey asked 

agencies about what OPM’s governmentwide telework initiative could do to 

assist agencies in fully implementing telework policies. 

Some agency and union officials identified governmentwide actions that 

are closely related to the key practices we identified, such as the need for 

funding of telework programs, the need for training, and the importance of 

obtaining top-level support for telework. In addition, several officials 

identified the need for GSA and OPM to provide more guidance or 

information about telework and the need for clarification regarding the 

implementation of the telework provisions in Pub. L. No. 106-346. In 

particular, agency officials identified a need for additional guidance related 

to their data reporting and collection methods for OPM. Two agency 

officials stated that OPM has changed the data that it requests from 

agencies from year to year, which has made it difficult for them to establish 

systems to collect the necessary data.

Conclusions Telework has received significant attention in Congress and the executive 

branch and is an increasingly popular flexibility among federal employees. 

Not only is telework an important flexibility from the perspective of 

employees, but it has also become a critical management tool for coping 

with potential disruptions to the workplace, including terrorism. However, 

the federal government’s telework initiative needs further development to 

become an effective human capital flexibility. 

Congress’ most significant demonstration of support for telework was the 

enactment of Section 359 of Pub. L. No. 106-346. In guidance related to that 

law, OPM told agencies that eligible employees who wanted to telework 

must be allowed that opportunity, but did not provide a definition for what 

constituted such an opportunity. Although the lack of a definition for that 

statement resulted in the reporting of incomparable telework data to 

Congress, OPM promptly released publications defining the previously 
Page 30 GAO-03-679 Improving Federal Telework Efforts

ambiguous statement following a discussion in which we highlighted this 

issue for OPM officials.

On the other hand, the relationship between two other provisions—one 

that requires specified agencies to set aside $50,000 each year for the use of 

GSA telework centers and one that prohibits some of the same agencies 

and several others from spending funds on GSA telecommunication 

centers—remains in need of clarification. Although GSA telework centers 

are not known by the term “GSA telecommunication centers,” GSA officials 

believe that this term does in fact refer to GSA telework centers. Despite 

this belief, it has not been made clear to all applicable agencies that the 

provision prohibiting certain agencies from spending appropriated funds 

on GSA telecommunication centers applies to GSA telework centers. This 

was supported by the fact that two of the relevant agencies used 

appropriated funds for GSA telework centers in fiscal year 2002, even 

though the provision prohibiting them from spending appropriated funds 

on GSA telecommunication centers was in effect.

Although GSA and OPM are lead agencies for the governmentwide 

telework initiative, they have not fully coordinated their efforts in leading 

the governmentwide telework initiative and have had difficulty in resolving 

their conflicting views on telework-related matters. This lack of 

coordination created confusion for federal agencies in implementing their 

individual telework programs. Both GSA and OPM officials recently 

indicated a willingness to work together to resolve this issue, but sustained 

attention and actions that result in actual solutions will still be needed.

In addition, the key telework practices we identified are integral to the 

success of the telework initiative in the federal government and need to be 

considered individually by each federal agency within the context of its 

own mission, programs, and telework programs. However, as our work at 

four agencies has shown, agencies face numerous difficulties in 

implementing their individual agency programs. Regular attention by 

agencies to the key practices is important to foster program growth and 

remove barriers to telework participation.

Recommendations for 

Agency Action

We recommend that the Administrator, GSA, work with Congress to 

determine what was meant by the phrase “GSA telecommunication center” 

in Section 314, Division F, title III of Pub. L. No. 108-7 and whether this 

provision is in conflict with the provision contained in 40 U.S.C. 587(d)(2). 

Once these determinations are made, GSA should issue guidance to the 
Page 31 GAO-03-679 Improving Federal Telework Efforts

relevant agencies to clarify these provisions and explain the impact of 

these laws on agencies’ telework programs. 

We also recommend that the Administrator, GSA, and the Director, OPM, 

ensure that the offices in their agencies with responsibilities for the 

governmentwide telework initiative improve coordination of their efforts 

to provide federal agencies with consistent, inclusive, unambiguous 

support and guidance related to telework. To do so, they should clearly 

delineate their responsibilities for this initiative and work together to 

resolve existing areas of difference. The Memorandum of Understanding 

that the agencies are considering could be very helpful in making progress 

on this key issue.

Furthermore, to enable agencies to more effectively implement the key 

practices that we identified as those that should be used for successful 

implementation of federal telework programs, we recommend that the 

Administrator, GSA, and the Director, OPM, use their lead roles in the 

federal telework initiative to assist agencies in implementing these 

practices. Using the key telework practices, GSA and OPM should identify 

areas where more information about implementation of the practices may 

be needed and provide agencies with the additional guidance, guidelines, 

and/or individualized technical support necessary to assist them in 

implementing those practices that are still in need of attention. 

Additionally, OPM agreed with a recommendation included in our recent 

report for OPM to serve as a clearinghouse in sharing and distributing 

information about the broad range of human capital flexibilities available 

to federal agencies.34 In implementing that recommendation, OPM should 

include information about telework, because it is such a flexibility. To 

provide agencies with the capabilities to effectively implement telework, 

both GSA and OPM should continue to monitor agencies’ telework 

programs and align their efforts with areas that are still in need of 

attention.

Agency Comments We provided a draft of this report in June 2003 to the Secretaries of 

Education and VA, the Administrator, GSA, and the Director, OPM. The 

Director of Human Resources Services from Education provided 

comments via e-mail (see app. III for a summary of these comments). In 

34U.S. General Accounting Office, Human Capital: OPM Can Better Assist Agencies in 

Using Personnel Flexibilities, GAO-03-428 (Washington, D.C.: May 9, 2003).
Page 32 GAO-03-679 Improving Federal Telework Efforts

addition, we received written comments from the Secretary, VA, and joint 

written comments from the Administrator, GSA, and the Director, OPM, in 

response to a draft of this report (see app. IV and V). Where appropriate, 

we made changes in our report in response to these comments.

In its comments, Education generally agreed with the contents of the draft 

report and stated that the department was pleased that we recognized its 

efforts to advance telework. Additionally, the comments stated that the 

department’s “most significant comment” was, as our draft noted, the need 

for a clear, unambiguous, and universally accepted definition for what it 

means to allow employees the opportunity to telework. 

VA agreed with our conclusion that there is a need for further guidance and 

assistance from GSA and OPM regarding federal telework implementation 

and suggested two areas where such guidance would be helpful. 

Specifically, VA indicated that OPM needs to redefine participant eligibility 

criteria and that OPM and GSA should provide guidance on how to 

effectively use telework in emergency situations. In addition, VA expressed 

concern that the draft report, which stated that we used participation rate 

as one of the criteria used in our selection of agencies, did not recognize 

that VA’s mission is a significant factor accounting for its limited telework 

participation rate. VA also disagreed with several of our findings related to 

the status of VA’s implementation of the telework practices we identified. 

However, when we asked for documentation to support the statements that 

VA made in its comments, VA was unable to provide such information. 

Absent any evidence that would support VA’s comments, our assessment 

remains unchanged.

In their combined comments, GSA and OPM agreed that telework is an 

important tool for federal agencies and stated that they would encourage 

and champion telework as a key human capital flexibility and do everything 

possible to facilitate its acceptance and use. The agencies also agreed to 

implement our recommendation that they use their lead roles in the federal 

telework initiative to assist agencies in implementing the key telework 

practices we identified. In this regard, GSA and OPM stated that they will 

provide agencies with a checklist of the practices we identified and 

recommend that agencies do a self-assessment of their telework programs 

using our analytical framework. Both GSA and OPM will then offer to help 

agencies to improve in the identified areas of deficiency. OPM will also 

include the key telework practices that we identified in telework training, 

which, as we had noted in the draft report, is being developed for launch on 

its Web-based training site during fiscal year 2003.
Page 33 GAO-03-679 Improving Federal Telework Efforts

In addition, GSA agreed with our recommendation that it work with 

Congress to determine what was meant by the phrase “GSA 

telecommunication center” in Section 314, Division F, title III of Pub. L. No. 

108-7 and whether this provision is in conflict with the provision contained 

in 40 U.S.C. 587(d)(2). GSA stated that it will coordinate internally and 

with the appropriate congressional committees to resolve the conflicting 

language in the statutes and then provide clarification to its customer 

agencies. 

On the other hand, both GSA and OPM disagreed with several of our 

findings relating to their lead roles in the governmentwide telework 

initiative. For example, GSA and OPM strongly disagreed with our finding 

that they have not fully coordinated their governmentwide telework efforts 

in the past. This contradicts information that was conveyed to us by 

agency officials during our review. However, we have added to the report, 

where appropriate, to reflect the agencies’ new position on the issue of 

coordination. Interestingly, despite the fact that GSA and OPM disagreed 

with our finding relating to coordination, the agencies also said in their 

comments that they have recognized the need to better outline separate 

and shared responsibilities and that a Memorandum of Understanding was 

among the options they were considering to clearly designate each agency’s 

responsibilities.

OPM also raised a number of issues with our analysis of its internal 

telework program. In its comments, OPM stated “[E]ach comment listed 

was conveyed to GAO during the interview process.” On the contrary, 

OPM’s comments, for the most part, contain new information and/or 

information that does not correspond with what was conveyed to us by 

OPM officials during our review. Much of this information contradicts 

what was conveyed to us by agency officials during our review. However, 

we have changed the report where appropriate to reflect OPM’s new 

positions on some issues. 

GSA did not disagree with our findings pertaining to its internal telework 

program. However, the agency did note several areas where it would like us 

to revise statements relative to its implementation of the key practices we 

identified. We considered these comments and incorporated new language 

into the report where appropriate.
Page 34 GAO-03-679 Improving Federal Telework Efforts

As agreed with your office, unless you announce the contents of this report 

earlier, we plan no further distribution until 30 days after its issue date. At 

that time, we will send copies to the Secretary of Education, the 

Administrator of GSA, the Director of OPM, and the Secretary of VA. We 

will also provide copies of this report to other interested congressional 

parties and make copies available to others upon request. In addition, the 

report will be available at no charge on the GAO Web site at 

http://www.gao.gov.

If you have any questions about this report, please contact me or Boris 

Kachura on (202) 512-6806. Key contributors to this report were Joyce 

Corry, Ellen Grady, Tiffany Tanner, and V. Bruce Goddard.

Sincerely yours, 

J. Christopher Mihm

Director, Strategic Issues
Page 35 GAO-03-679 Improving Federal Telework Efforts

Appendix I

Scope and Methodology AAppenednxidexiIs

The objectives of this report were to

• characterize the federal laws and their requirements that currently apply 

to telecommuting within the federal agencies in the executive branch; 

• determine what the General Services Administration (GSA) and the 

Office of Personnel Management (OPM) are doing, as lead agencies, to 

coordinate and promote telecommuting in the federal government;

• determine what selected federal agencies are doing to implement key 

practices in developing telecommuting programs; and 

• identify additional governmentwide actions that could be taken to 

encourage federal agencies to increase telecommuting participation.

To address these objectives, we gathered information from a variety of 

sources using several different data collection techniques and analyzed this 

information. In order to characterize the federal laws and their 

requirements that currently apply to telecommuting within the federal 

agencies in the executive branch, we identified and analyzed the relevant 

laws and discussed the requirements of selected laws with agency officials. 

To determine what GSA and OPM are doing to coordinate and promote 

telecommuting in the federal government, we interviewed GSA and OPM 

officials regarding their governmentwide telework efforts and analyzed 

relevant documents related to these efforts. 

We took several steps to determine what selected executive agencies are 

doing to implement key practices in developing telecommuting programs. 

First, we conducted a review of literature and guidelines related to 

telework in the federal government to identify the key practices that 

executive agencies should implement in developing telework programs. 

These guidelines and this literature were obtained from both government 

and nongovernment sources including studies and reports issued by 

interest groups, associations, consulting firms, GSA, OPM, and other 

federal government agencies. A practice was considered to be “key” if it 

was recommended in three or more sources as a practice that 

organizations should use in implementing a telework program. 

After identifying the key telework practices, we conducted semi-structured 

interviews of selected telework program officials and other relevant agency 

officials and analyzed documents related to telework implementation at 

four agencies—the Department of Education (Education), GSA, OPM, and 
Appendix I

Scope and Methodology

Page 36 GAO-03-679 Improving Federal Telework Efforts

the Department of Veterans Affairs (VA). These agencies were selected 

from the 24 executive agencies covered by the Chief Financial Officers 

(CFO) Act of 1990 for various reasons, including function, size, and 

reported level of telework participation.35 GSA and OPM were selected 

because of their lead roles in the governmentwide telework initiative. In 

addition, OPM was reported to have the highest telework utilization rate 

among the CFO Act agencies. Education was included because its reported 

utilization rate was the second highest among the CFO Act agencies. VA 

was selected based on its distinction as the second largest CFO Act agency 

combined with its having the lowest reported telework utilization rate 

among the CFO Act agencies.36 This agency selection process was not 

designed to produce findings that could be considered representative of 

telework implementation in the federal government as a whole, but rather 

to provide illustrative examples of the extent to which selected individual 

agencies with varied sizes, reported utilization rates, and missions had 

implemented the key practices identified in our literature review. 

We interviewed officials and union representatives from the four selected 

agencies to obtain their views on additional governmentwide actions that 

could be taken to encourage federal agencies to increase telecommuting 

participation. In addition, we contacted other unions representing federal 

employees, including the National Treasury Employees Union, the 

American Federation of Government Employees, and the National 

Federation of Federal Employees, to solicit their views on such additional 

actions. (Officials for the American Federation of Government Employees 

did not respond to our request.) Our work was conducted from May 2002 

through May 2003 in accordance with generally accepted government 

auditing standards.

35Size and level of telework participation were determined from survey data collected by 

OPM for its January 2002 Report to Congress, entitled The Status of Telework in the Federal 

Government.

36In its comments, VA noted that a “significant number of VA employees are engaged in 

direct patient care and benefit service delivery to veterans, which precludes large-scale 

participation in telework,” which it considers to be a significant factor accounting for its 

limited telework participation rate.
Page 37 GAO-03-679 Improving Federal Telework Efforts

Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices ApendxiI

We identified 25 key practices in telework-related literature and other 

sources as those that agencies should implement in developing their 

telework programs. This appendix contains descriptions of how the four 

agencies reviewed—the Department of Education (Education), the General 

Services Administration (GSA), the Office of Personnel Management 

(OPM), and the Department of Veterans Affairs (VA)—are implementing 

each practice. Although attention to each of these practices is integral to 

the success of the federal telework initiative, the four agencies we 

reviewed have not fully implemented many of them. Regular attention to 

the practices can help to foster program growth and remove barriers to 

telework participation.

Program Planning

Designating a Telework 

Coordinator

Telework resources provided by both GSA and OPM in their roles as lead 

agencies for the federal telework initiative state that, in implementing their 

telework programs, federal agencies need to designate agency telework 

coordinators and contacts.37 All four of the agencies in our study have a 

designated telework coordinator. At Education, the coordinator works on 

the agency’s telework program full time. At the other three agencies, the 

telework coordinator has other responsibilities in addition to telework.

Establishing a CrossFunctional Project Team, 

Including, for Example, IT, 

Union Representatives, and 

Other Stakeholders

Our 2002 report on the effective use of flexibilities identified stakeholder 

input as a key practice for effectively using human capital flexibilities, such 

as telework.38 According to this report, agency leaders, managers, 

employees, and employee unions need to work together to develop policies 

and procedures, because such involvement helps in reaching agreement on 

the need for change, the direction and scope that change will take, and how 

progress will be assessed. Stakeholder input should also be used to ensure 

that the policies surrounding the use of flexibilities are clear and the 

37In the fiscal year 2003 appropriations for the Departments of Commerce, Justice, and 

State, the Judiciary, and the Small Business Administration, these departments and agencies 

are required, amongst other things, to designate a telework coordinator to oversee the 

implementation of their telecommuting programs. See Section 623, Division B, title VI of 

Pub. L. No. 108-7, February 20, 2003. 

38GAO-03-2, 32.
Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices

Page 38 GAO-03-679 Improving Federal Telework Efforts

procedures to implement them are uncomplicated. Telework-related 

literature suggests that stakeholder involvement should be obtained by 

establishing a committee with members from human resources, 

information management, risk management, facilities management, and 

senior management, as well as employee and union representatives. All 

four of the agencies we reviewed established cross-functional project 

teams in implementing their telework programs.

Establishing Measurable 

Telework Program Goals

According to the International Telework Association and Council’s (ITAC) 

e-Work Guide, research conducted by the American Management 

Association in 2000 indicated that “68 percent of ‘highly successful’ 

telework programs felt it was ‘critical’ to develop clear and reasonable 

program objectives for their program” and another 27 percent considered it 

to be helpful.39 None of the four agencies we examined have taken any 

steps to implement this practice.

In comments on a draft of this report, both OPM and VA said they had 

established measurable telework program goals. However, neither agency 

was able to provide documentation of such goals. Therefore, our 

assessments of these agencies on this practice remain unchanged.

Developing an 

Implementation Plan for the 

Telework Program

Guidelines issued by OPM in its capacity as a leader of the governmentwide 

telework initiative suggest that agencies should establish a strategic plan 

with definitive timelines to accomplish implementation of telework 

including an evaluation tool. The ITAC e-Work Guide states that such a 

plan should include, at a minimum, objectives and how their achievements 

will be measured; definitions and policy details; a business case, including 

start-up and ongoing costs; a technology plan; and an implementation 

plan.40 Two of the agencies reviewed, Education and OPM, have fully 

implemented this practice in their internal telework programs, while VA 

has not taken any steps to implement this practice. However, in comments 

on a draft of this report, VA said that it had developed an implementation 

plan for the telework program. When we requested documentation of such 

a plan, VA responded that, in fact, it did not establish an implementation 

39International Telework Association and Council, e-Work Guide: How to Make Telework 

Work for Your Organization (Washington, D.C.: 2000), 3.

40International Telework Association and Council, e-Work Guide, 22.
Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices

Page 39 GAO-03-679 Improving Federal Telework Efforts

plan for its current telework policy. Therefore, our assessment of VA on 

this practice remains unchanged. During our review, GSA’s telework 

coordinator told us that there was not a written implementation plan for 

the telework program when it was first started. However, in comments on 

a draft of this report, GSA indicated that it had an implementation plan that 

was utilized 10 years ago when the program was first developed, but this 

plan was not kept in the files, because it was no longer in use. Therefore, 

we were unable to assess GSA’s implementation of this practice, and have 

modified the report accordingly.

Developing a Business Case 

for Implementing a 

Telework Program

ITAC’s e-Work Guide states that “successful telework programs reside in 

organizations that understand why they support telework, address the 

relevant issues, minimize business risk and make the investment when it 

supports their objectives.”41 To achieve such success, the guide 

recommends that organizations develop business cases for implementing 

telework programs. The April 2002 report issued by Booz Allen Hamilton 

on home-based telework technology barriers also recommends that 

agencies develop business cases for implementing telework in their 

organizations, because such an approach has proven effective in engaging 

management on the benefits of telework to an organization.42 Through 

business case analysis, organizations have been able to identify cost 

reductions in the post-telework office environment that offset additional 

costs incurred in implementing telework and the most attractive approach 

to telework implementation. Of the four agencies we reviewed, Education 

was the only agency to have taken some steps to implement this practice. 

A program official at this agency said that she has developed a PowerPoint 

presentation of a business case for implementing a telework program at 

Education. However, she has never actually given this presentation to 

anyone at Education.

Providing Funding to Meet 

the Needs of the Telework 

Program

Telework-related literature suggests that agencies should incorporate 

requirements for home-based telework into their IT capital planning and 

budgeting processes and provide for consistent allocation of the resources 

necessary to establish telework arrangements, such as the equipment and 

technology needed for remote access to agency networks. However, 

41International Telework Association and Council, e-Work Guide, 15.

42Booz Allen Hamilton, ES-8 and V-2.
Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices

Page 40 GAO-03-679 Improving Federal Telework Efforts

providing funding to meet the needs of the telework program is a practice 

that the four agencies have only partially implemented.

Under the provisions of 40 U.S.C. 587(d)(2), the only legislated funding for 

telework programs that applies to the executive agencies that we reviewed, 

specified agencies are to make at least $50,000 of the funds appropriated 

for salaries and expenses available each fiscal year for their employees’ use 

of GSA telework centers.43 However, the agencies covered under this 

legislation are not required to spend the money made available. While this 

provision pertains to all four of the agencies in our study, neither VA nor 

OPM actually spent at least $50,000 for telework center use in fiscal year 

2002. In contrast, both Education and GSA spent more than this minimum 

set aside.44

Although VA’s telework policy states that the agency’s telework 

assignments may be established at community-based telework centers 

when determined to be consistent with the agency’s mission, a program 

official said that VA generally does not choose to support use of the 

centers. In fiscal year 2002, VA spent only $6,800 for two users at one 

telework center. OPM’s expenditures for telework center use in that year 

were about $36,400. At Education, the telework program requests at least a 

10 percent increase in funds to be made available each year over those 

requested the preceding year. For example, for fiscal year 2002, $82,000 

was requested and approved, while for fiscal year 2003, $125,000 was 

requested and approved. An Education program official said that the 2003 

request was much greater than the 2002 request because, in 2002, the 

agency actually spent over $87,000 for use of the centers and the demand 

was far greater than she had anticipated or could fund. The expenditures 

for telework center use at GSA in 2002 were about $97,000.

In addition to the funds made available for employees to work at telework 

centers, each of the four agencies pays the salaries of telework 

coordinators. In its comments on our draft report, GSA said that it did not 

have a central telework fund. Instead, it said that individual organizations 

43Section 623, Division B, title VI of Pub. L. No. 108-7 also provides $100,000 to the 

Departments of Commerce, Justice, and State, the Judiciary, and the Small Business 

Administration for the implementation of telecommuting programs. 

44Expenditures for fiscal year 2002 telework center use at the four agencies were included in 

OPM’s January 2003 report to Congress, entitled The Status of Telework in the Federal 

Government. OPM used data gathered by GSA for reporting these expenditures.
Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices

Page 41 GAO-03-679 Improving Federal Telework Efforts

within GSA provided their own funding for telework. We had considered 

this information in our assessment of GSA’s level of implementation of this 

practice. OPM said in its comments that the agency funds staff time to 

provide oversight and evaluation for the telework program, as well as 

outreach and program promotion, but it is not clear whether such funding 

would go beyond the already cited salary payment for OPM’s part-time 

telework coordinator or would even be related to OPM’s internal telework 

program as opposed to OPM’s governmentwide efforts. In addition, OPM 

stated that it had identified resources to accommodate “every employee 

(who is otherwise eligible and wants to telecommute) with appropriate 

computer equipment, technology support, and remote connections.” 

However, OPM did not provide documentation of this funding. Also, an IT 

official at OPM said that there were times that the agency has been short on 

the older computers it loans to teleworkers. He said that the people who 

absolutely need to telework get computers immediately, if they require one, 

but that people who would like to telework, but do not have a “need” to do 

so, have had to wait to begin teleworking until computers became 

available. According to this IT official, managers usually make the decision 

about whether telework is a “need,” although employees will sometimes 

decide for themselves that it is not necessary for them to telework. Given 

these considerations, we did not change our assessment that GSA and OPM 

had taken some steps to implement this practice. 

Beyond these situations, the four agencies have not directly allocated other 

funds to meet the functional needs of their telework programs. Moreover, 

both Education and VA cited funding as a major barrier to their agencies’ 

telework programs in their responses to OPM’s November 2002 telework 

survey. Education’s response also characterized telework as an unfunded 

mandate that agencies had to support with funds from their appropriations 

for salaries and expenses.
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Establishing a Pilot Program Booz Allen Hamilton’s April 2002 report on barriers to home-based 

telework stated that well-structured pilot programs have led to successful 

telework programs. Guidelines issued by Commuter Connections, a 

program coordinated through the Metropolitan Washington Council of 

Governments, suggests that a telework pilot program may be the best way 

to prove the concept and test the integration plan by demonstrating effects 

on performance and productivity, evaluating policies and procedures, 

testing remote access and technology support, identifying resource 

requirements, evaluating new workplace concepts, testing training 

effectiveness, and evaluating manager-team-remote worker relationships.45 

Of the four agencies we reviewed, only Education had a pilot related to the 

implementation of its agencywide telework program. Although GSA and 

OPM did not have individual pilot programs for their internal telework 

programs, both agencies were involved in the year-long governmentwide 

telework pilot program that was implemented in 1990.

In comments on a draft of this report, VA said that it had two pilot 

programs. However, when we requested documentation of a pilot relating 

to implementation of its current program, VA responded that, in fact, it did 

not conduct a pilot program for its current telework policy. Therefore, we 

did not change our assessment of VA on this practice.

Telework Policy

Establishing an Agencywide 

Telework Policy

OPM’s January 2003 report to Congress stated that of the 77 reporting 

agencies, 63 reported having approved and implemented their telework 

policies, 9 were in the process of policy development, 3 were in the 

implementation stages, and 2 reported no policies or policy development 

activity. All 4 of the agencies in our study have implemented telework 

policies and, according to agency officials at all of these agencies, they 

have given some consideration to updating their policies to reflect changes 

within the agency and more recent trends in telework. At VA, a program 

official provided us with a draft for an updated policy, which was 

developed to modernize the agency’s policy and expand the eligible 

45Commuter Connections, A Practical Approach to Implementing Telework Programs

(Washington, D.C.: 2002), 81.
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population at VA. According to this official, the draft policy was going 

through the approval process at that time. Program officials at all 4 of the 

agencies told us that revisions to their policies would involve obtaining 

union input on those revisions. Telework program officials at GSA and 

OPM said that reaching such agreement with the unions can take a year or 

more.

Establishing Eligibility 

Criteria to Ensure That 

Teleworkers Are Selected 

on an Equitable Basis Using 

Criteria Such as Suitability 

of Tasks and Employee 

Performance

Several telework-related sources have emphasized the need for eligibility 

criteria to ensure that teleworkers are selected on an equitable basis. Most 

of these sources advise that these criteria should be based on the suitability 

of both the tasks and the employee for telework. According to the 

Interagency Telework Issues Working Group report, criteria for 

determining the suitability of the employee should be based on objective 

criteria that are equitable, reasonable, and clearly stated and not on general 

personal characteristics that are assessed using subjective measures, such 

as being organized, conscientious, highly disciplined, and a self-starter. 

The report went on to say that using such criteria can lead to subjective 

supervisory assessments, which can inaccurately or inappropriately 

impede telework participation. To address this concern, the report 

recommended that OPM establish a policy that all federal employees are 

potentially eligible to participate in telework, unless excluded by their 

agency based on objective criteria that are supportive of the intent of the 

telework requirements in Public Law 106-346. The group also 

recommended that OPM require each individual agency to identify and 

define, in its telework policy, positions excluded from telework 

arrangements, based strictly on tasks performed in the excluded positions.

Education has included eligibility criteria in its policy that are similar to 

those that the Interagency Telework Issues Working Group cautioned 

against using. Education’s policy states that an employee who is suitable to 

telework should exhibit self-starter characteristics, good organizational 

skills, and the ability to function independently. Education and OPM also 

require that teleworkers are performing at or above a specified rating level 

such as “fully successful.” In addition, OPM’s telework policy states that 

employees approved for telework should be able to manage workloads 

with minimum supervision and that generally, telework is not appropriate 

for new employees such as those who need to be in the office to learn the 

organization and those who require on-the-job training. GSA’s policy does 

not include eligibility criteria, but states that criteria for selecting 

occupations and employees for telework are not hard and fast rules. 

However, the policy also refers to a separate GSA Office of Human 
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Resources document for selection factors particularly relevant to telework. 

A GSA program official said that she had been trying to locate that 

document for a while, but to date has not been able to do so. VA’s current 

policy includes eligibility criteria based solely on position classifications. 

However, a VA program official acknowledged that there is variation in the 

application of eligibility requirements among parts of that agency, given the 

subjective nature of the approval process. She added that the proposed 

revisions to VA’s current policy would require supervisors to give reasons 

for denial on the application form, which she hoped would provide needed 

information to help assess equitable treatment. Because none of the four 

agencies have yet taken steps to ascertain whether teleworkers are being 

selected on an equitable basis, these agencies cannot ensure that their 

eligibility criteria are being applied equitably.

Establishing Policies or 

Requirements to Facilitate 

Communication Among 

Teleworkers, Managers, and 

Coworkers

Although telework-related sources suggest that establishing policies or 

requirements to facilitate communication among teleworkers, managers, 

and coworkers is helpful in addressing managerial concerns about 

telework, teleworker isolation, and morale issues that may arise with 

nonteleworkers, two of the four agencies, Education and OPM, have fully 

implemented this practice. Education’s telework policy states that 

supervisors should ensure that efforts are made to include teleworkers as 

part of the team in order to reduce employee isolation and communication 

problems, and to facilitate integration of the employee with those in the 

office. As a means of accomplishing this, the policy recommends that 

teleworkers plan to work from the office at least 1 day per week in order to 

be available for meetings or anything that needs to be handled face-to-face 

and on days when staff meetings are scheduled. The policy also suggests 

that developing fixed times during the day for supervisor/employee 

telephone conversations may be helpful to ensure ongoing communication. 

OPM’s policy also includes language about the importance of 

communication and recommends that employees plan to be in the office at 

least 1 day per week. In addition, OPM’s policy states that the telework 

agreement must include means of communication with the employee when 

telecommuting (phone, fax, e-mail, etc.). OPM’s alternate worksite 

agreement includes an area specifically addressing assignments and 

communication. It says that the information provided in the designated 

space “should include work assignments, agreements on checking voice 

mail and email or contacting the supervisor as well as the requirement for 

employees to come into the office as needed.” While program officials at 

GSA and VA acknowledged that communication was an important issue, 
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the telework policies at these agencies did not establish means of 

facilitating communication. 

Developing a Telework 

Agreement for Use between 

Teleworkers and Their 

Managers

Telework-related literature recommends that agencies develop a telework 

agreement to be signed by both teleworkers and their supervisors. 

According to ITAC’s e-Work Guide, such an agreement should establish job 

duties and expectations, performance standards, and measurable 

outcomes and deliverables. All four agencies reviewed have developed 

telework agreements, but have different requirements for their use. For 

example, GSA does not require the use of these agreements for ad hoc 

telework arrangements. In contrast, OPM’s telework policy states that 

“employees must sign a work agreement with their supervisor.” Despite 

this requirement, an OPM program official told us that this does not always 

happen in practice and she does not require them to do so. However, she 

does accept e-mail agreements between employees and supervisors when 

she receives them. 

Developing Guidelines on 

Workplace Health and 

Safety Issues to Ensure That 

Teleworkers Have Safe and 

Adequate Places to Work 

Off-Site

Telework-related literature describes several means for employers to 

ensure that teleworkers have safe and adequate alternate workplaces. 

These include specifically addressing health and safety issues related to 

telework in policies, including health and safety issues in telework training, 

having teleworkers fill out a safety checklist, and performing on-site 

inspections with adequate notice to the teleworker. Three of the four 

agencies we reviewed, Education, GSA, and OPM, have developed safety 

checklists, which are to be completed along with the telework agreement, 

to ensure that teleworkers have certified the safety of their alternate 

workplaces. However, Education is the only agency that requires all 

teleworkers to complete and sign such a checklist before they begin 

teleworking. GSA includes a safety checklist with the telework agreement, 

but episodic teleworkers are not required to complete an agreement or, 

therefore, a checklist. OPM’s telework policy recommends that the 

telework agreement include a safety checklist, but such a checklist is not 

required. According to a program official from VA, the agency’s current 

policy does not contain health and safety guidelines, but the revised draft 

policy, which is currently going through the agency’s approval process, 

includes a safety checklist.
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Performance 

Management

Ensuring That the Same 

Performance Standards, 

Derived from a Modern, 

Effective, and Credible 

Performance System, Are 

Used to Evaluate Both 

Teleworkers and 

Nonteleworkers

Although none of the agencies have fully implemented the practice of 

ensuring that the same performance standards are used to evaluate both 

teleworkers and nonteleworkers, Education and OPM have taken some 

steps to implement this practice. Education’s telework policy states that 

employees participating in the telework program shall be treated equally 

with other employees in decisions that affect conditions of employment for 

awards, promotions, and/or any other condition of employment. A 

program official at OPM said that work performed by teleworkers is 

supposed to be evaluated using the same performance standards used for 

nonteleworkers and that managers are supposed to communicate this. 

Although such a statement was not included in OPM’s telework policy, the 

policy does state that the employees’ current performance standards will 

be used to govern all telecommuting assignments as well as those in the 

telecommuters’ current traditional federal offices. A GSA program official 

told us that the agency incorporated this concept into its telework policy 

and reiterated it in counseling sessions with managers and staff. We did 

not find any support of this in GSA’s policy, although it did indicate that 

“[t]ime spent and quality of products will be measured by correlation with 

previous and similar efforts.” VA’s current telework policy does not contain 

any statements related to using the same performance standards for both 

teleworkers and nonteleworkers. In comments on a draft of this report, VA 

stated that the department consistently advises supervisors and managers 

that performance standards for teleworkers and nonteleworkers should be 

the same. However, VA could not provide us with any information to 

support this comment. In fact, VA responded that it provides such advice 

“on an as-requested basis,” which does not constitute “consistently 

advising.” Therefore, our assessment of VA on this practice remains 

unchanged.

Establishing Guidelines to 

Minimize Adverse Impact on 

Nonteleworkers Before 

Employees Begin to Work at 

Alternate Worksites

Telework-related literature suggests that performance and morale issues 

can arise if guidelines are not established to address and minimize adverse 

impacts of telework on nonteleworkers. The literature describes several 

issues that can contribute to such issues among nonteleworkers, including 

eligibility criteria that are perceived as unfair and cause nonteleworkers to 

feel left out or discriminated against, teleworkers that allow their in-office 
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responsibilities to fall on the shoulders of nonteleworkers, and reduced 

communication between the teleworker and nonteleworker. To mitigate 

these situations, care should be taken to establish fair and equitable 

eligibility criteria and means of distributing work.

Three of the four agencies, Education, OPM, and VA, have fully 

implemented this practice by including specific guidelines in their policies. 

Education’s telework policy states that telework should not affect the 

performance of other employees and that it shall not put a burden on staff 

remaining in the office. It also says that an equitable distribution of work 

must be maintained and methods should be instituted to ensure that 

employees working in the office do not have to handle the teleworker’s 

work. OPM’s policy says that supervisors should consider the effect of 

telework on all employees in the work unit, especially if it means there are 

fewer employees in the office to handle customer requests. At VA, 

supervisors are charged with ensuring that participating and 

nonparticipating employees are treated equitably. According to a program 

official at GSA, the agency’s policy sets out guidelines for effective use of 

telework, including that a unit should use whatever systems it deems 

necessary to ensure that there is a balance of work between those 

teleworking and those in the office. However, we did not see any support 

of this in GSA’s policy.

Managerial Support

Obtaining Support from Top 

Management for a Telework 

Program

Although program officials from all four agencies recognized support from 

top management as being critical to the success of a program such as 

telework, a program official at OPM was the only one to state, 

unequivocally, that telework has the full support of that agency’s top 

management. She said that the agency’s director leads by example, since 

she and various members of her staff telework. The director has also 

demonstrated support by sending e-mails encouraging telework in 

response to certain events, such as Green Day. A GSA program official 

believes support for telework from that agency’s top management has 

varied by administration. However, she said that, although the current 

administrator has not made a statement specifically supporting telework, 

he has made several overtures in support of the program, including 

teleworking occasionally himself, supporting GSA’s promotional free trial 

offer for use of the telework centers, and attending meetings related to 
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telework. Officials at the other two agencies cited lack of support from top 

management as a challenge in implementing the telework program. An 

Education program official also specifically discussed the difficulties that 

frequently changing administrations and leadership can create because of 

having to repeatedly work to overcome the barriers that new top managers 

bring to the agency.

Addressing Managerial 

Resistance to Telework

Our 1997 report identified managerial resistance as the largest barrier to 

implementing telework, attributing it to several factors, including general 

resistance to change, since telework requires managers to shift from 

managing by observation to managing by results.46 Officials from three of 

the four agencies that we spoke with—Education, GSA, and VA—also cited 

this as a challenge that they face and identified it as a barrier to telework in 

their responses to OPM’s November 2002 telework survey. Current and 

former program officials at OPM stated that managers at that agency do not 

exhibit signs of managerial resistance to telework and thus this practice 

has been fully implemented. A former program official directly linked the 

presence of top management support for telework at OPM to the 

prevention of managerial resistance, because managers were told that they 

have to allow telework and that they must give a business case for rejecting 

an employee’s request to telework.

Program officials at two of the agencies presented some ideas for 

addressing managerial resistance. A VA program official would like to 

bring in outside consultants to hold an information forum or educational 

briefings for supervisors and managers, which would tie telework to the 

shift from the industrial age to the information age and walk managers 

through the process of approving a telework arrangement. VA’s draft 

Telework Proposal form, included in its revised draft telework policy, will 

help to address managerial resistance, if it is implemented in its current 

form, by requiring that supervisors provide a written reason if a telework 

application is not approved. In its response to OPM’s 2002 telework survey, 

VA also said that it is using initiatives to gain top management support to 

overcome barriers that include managerial resistance. According to a 

program official, GSA has considered handling the approval process for 

telework agreements by committee instead of by individual supervisors as 

46GAO/GGD-97-116, 14.
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a means of alleviating managerial resistance, but this has not yet happened 

because of managerial resistance to such a change.

Training and 

Publicizing

Training All Involved, 

Including, at a Minimum, 

Managers and Teleworkers

Three of the four agencies that we reviewed provide some telework 

training. At Education, training for teleworkers is mandatory before they 

can begin to telework. Training is available at monthly training sessions, by 

telephone, or by requesting the telework coordinator’s training slides. 

These training opportunities are also available, but optional, for managers 

and nonteleworkers. GSA’s telework policy states that new program 

participants, including employees and immediate supervisors, must receive 

training except for those participating in episodic arrangements. However, 

a program official said that while GSA trained all employees when its 

telework program was first implemented, currently the agency only does 

occasional briefings on the telework program, usually in town hall 

meetings or on an as-needed basis with individuals. 

A former program official at OPM told us that all managers were required 

to attend telework briefings when the program first started in 2001. These 

sessions addressed performance management, office coverage and work 

unit issues, equipment issues, providing business reasons for denials, and 

handling Privacy Act implications. Other employees were offered the 

opportunity to attend briefings about the roles and responsibilities of a 

teleworker, but they were not required to attend. However, a current OPM 

program official told us that the agency does not currently offer telework 

training, that there has been no discussion of offering such training, and 

that she does not see a need for it at this time. 

Although a program official at VA believes training is very important and is 

critically needed for supervisors and new employees, she said that 

telework training has never been done at the agency. She noted that VA has 

considered developing an interactive training program for supervisors, but 

it is waiting for the release of an Internet training package that OPM’s office 

with responsibility for the governmentwide telework initiative has 

developed before making any decisions. It is anticipated that this training 

for managers and teleworkers will be available to all federal government 

employees from OPM during fiscal year 2003 at no charge on
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www.golearn.gov—an OPM-provided on-line learning center. The 

availability of such training may help to address any disparity in the 

provision of telework training among agencies.

Informing the Workforce 

about the Telework 

Program

Telework-related literature suggests that it is important to inform the 

workforce about opportunities to telework. Two of the agencies, GSA and 

OPM, have fully implemented this practice for their internal telework 

programs, using means such as intranet sites, newsletters, posters, and 

brochures to disseminate information about the telework program. At 

Education, a program official told us that she stopped actively marketing 

the telework program in response to pressure from top management. 

However, Education’s internal Web site has information on telework, 

including forms for participation and e-mail links. Education also 

publicizes information about telework training opportunities in its internal 

weekly newsletter. A program official from VA indicated that she would 

like to do more to market the program, but is limited by budgetary 

constraints. Currently the only means of publicizing VA’s telework program 

is through its intranet site, which includes a copy of the telework policy, 

helpful hints for supervisors and employees, information about telecenters, 

telework questions and answers, and guidance about what would make a 

good teleworker. However, the program official acknowledged that this 

form of communication has a drawback in that only those employees with 

access to computers can retrieve this information.

Technology

Conducting an Assessment 

of Teleworker and 

Organization Technology 

Needs

Since teleworkers often require the use of IT equipment to access files, 

internal networks, and e-mail, the Environmental Protection Agency (EPA) 

suggests that agencies assess both their own and their employees’ 

technology needs for telework with a mind toward providing employees 

with access to equipment similar to what they have in the office.47 In 

addition, ITAC’s e-Work Guide reports that research conducted by the 

American Management Association found that 73 percent of “highly 

47Environmental Protection Agency, Telecommuting/Telework Programs: Implementing 

Commuter Benefits Under the Commuter Choice Leadership Initiative (Washington, D.C.: 

Sept. 2001), 8.
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successful” telework programs regarded it as “critical” to do an analysis 

and review of the organization’s technology base and its compatibility with 

teleworker requirements. According to Booz Allen Hamilton’s report on 

technology barriers to home-based telework, the technologies acquired in 

response to such assessments, including document management systems, 

collaboration tools, and performance measurement systems, can result in 

benefits for both teleworkers and those in the office environment as well. 

Two of the four agencies we reviewed, Education and OPM, have fully 

implemented this practice and GSA has partially implemented the practice. 

According to an IT official at Education, the department did an engineering 

analysis to determine both current and future infrastructure needs for 

telework. In addition, a program official from Education told us that each 

applicant for telework must complete a technology assessment worksheet. 

OPM conducted a technology assessment as part of its program planning. 

As part of this effort, OPM’s IT staff chose the technologies to be used for 

remote access and decided that government-issued equipment was 

preferred to personal equipment for security purposes. OPM’s IT 

department also distributes virus software to employees who use their 

personal computers for telework. GSA has not conducted an agencywide 

assessment of teleworker and organization technology needs. According 

to a GSA program official, this is done on a case-by-case basis at the 

organization level because each organization is responsible for its own 

budget and for providing its workers with the appropriate tools for doing 

the job. According to another GSA official, GSA’s Office of 

Governmentwide Policy is conducting a pilot with laptops and docking 

stations to minimize the agency’s costs of maintaining two workstations for 

teleworkers. According to an IT official, VA has not conducted an 

assessment of technology needs with respect to teleworkers. As it 

currently stands, the process at VA is handled individually between the 

supervisor and employees.

Developing Guidelines 

about Whether the 

Organization or Employee 

Will Provide Necessary 

Technology, Equipment, and 

Supplies for Telework

Guidelines issued by GSA for the governmentwide telework initiative 

indicate that, while agencies are permitted, but not required, to provide 

teleworkers with equipment for use at alternate worksites, each agency 

must establish its own policies on the provision and installation of 

equipment for telework. All of the agencies we reviewed have established 

policies in this regard, stating that the agency will make decisions about 

providing equipment for telework on a case-by-case basis in light of funding 

and other considerations, such as the work to be performed at the alternate 

site, the type of equipment and software that is needed, and the availability 
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of equipment. For those agencies that allow employees to use personal 

equipment for telework, one program official acknowledged that such a 

policy can result in a “digital divide” between those employees who have 

the option of using or acquiring personal equipment for telework when the 

agency is not able to provide them with equipment and those who do not 

have such equipment available to them. 

Providing Technical Support 

for Teleworkers

According to the Interagency Telework Issues Working Group report, 

establishing technical support for both government-owned and personal 

equipment used to perform official duties for remote users, especially for 

teleworkers, is a relatively new issue for agencies. Some concerns 

associated with this issue focus on the availability and consistency of such 

support for teleworkers. To address these concerns, the report 

recommends that GSA establish a policy requiring that telework 

arrangements are covered in each agency’s IT technical support policies 

and that agencies refer to relevant sources of information on technical 

support in their telework policies. 

All four of the agencies reviewed have fully implemented this practice. 

According to an IT official at Education, the same technical assistance is 

available to all Education employees, whether they are in the office or 

teleworking. There is no special technical support for teleworkers. A 

program official from Education also said that customer service center 

staff can provide technical support for nongovernment-owned equipment, 

but this support is limited to whatever help can be provided over the 

telephone. An IT official at GSA said that the agency has two levels of 

technical support for users. The first level of technical support for all 

users, regardless of where they are working, is from their own unit’s 

support staff. The second level of support for remote access users, 

including teleworkers, is the Remote Access Team in the Chief Information 

Officer’s office. This level of support is called upon when the first level 

cannot resolve the problem. According to an IT official at OPM, the agency 

has a telework group that manages the servers, the virtual private network, 

and communication software. There is a separate phone number for 

people to call with computer problems associated with personal or agencyprovided computers encountered while teleworking. At VA, teleworkers 

have remote access to the same technical support as office-based workers. 
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Addressing Access and 

Security Issues Related to 

Telework

The Interagency Telework Issues Working Group report states that remote 

access is a key component of telework programs, because “low-tech” 

solutions, such as floppy disks, are inadequate for most situations. It goes 

on to say that remote access solutions, especially the speed of the 

connection, are necessary to maintain productivity in a telework 

arrangement. However, both the Interagency report and Booz Allen 

Hamilton’s report on technology barriers to home-based telework 

identified concerns among managers about security and the protection of 

agency information when systems are accessed remotely. Although the 

Booz Allen Hamilton report stated that the need to provide information 

security was not seen by any of the organizations they analyzed as a reason 

to inhibit home-based telework, OPM’s January 2003 report to Congress on 

the status of telework in the federal government identified data security as 

the most frequently cited barrier to telework. All four of the agencies we 

reviewed said they had addressed access and security issues related to 

telework by using remote access systems with adequate safeguards.

Establishing Standards for 

Equipment in the Telework 

Environment

Booz Allen Hamilton’s report on technology barriers to home-based 

telework recommends that federal organizations specifically define 

technical requirements, or standards, for the home environment to ensure 

that sufficient systems and support services are available to teleworkers. 

According to the report, such requirements should also be included in the 

longer-term IT and capital planning processes at each agency. Three of the 

four agencies we reviewed, Education, GSA, and VA, have fully 

implemented this practice and OPM has taken some steps to implement 

this practice. 

According to IT officials at both Education and GSA, these agencies use the 

same standards for equipment in both the home and office environments. 

Neither agency has established separate standards for equipment in the 

telework environment. If an employee wants to use his own equipment at 

home, the equipment would have to meet the network standards. 

According to a program official at Education, the department’s Web site 

identifies the minimum technology requirements and is regularly updated 

with the latest information on viruses, security issues, and other 

information. According to an IT official at VA, the department has 

established a standard for its IT equipment, whether at a VA locale or not. 

This official reported that all IT investments and procurements are required 

to undergo review and concurrence from VA’s Enterprise Architecture 

Service. In addition, the draft policy includes a security checklist, 
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including security requirements for equipment, which must be completed, 

reviewed, and certified by the Information Security Officer before a 

telework arrangement can begin. 

OPM has taken some steps to implement this practice. In comments on a 

draft of this report, OPM stated that it has a standard platform for 

connectivity and has established a protocol for requesting necessary 

equipment and connectivity. However, an IT official from OPM reported 

that, while OPM has a target standard machine, this standard has not been 

fully applied. In addition, this IT official also told us that OPM does not 

really have a standard for employee-provided equipment and that 

employees are only made aware of the need to upgrade to the standard 

when they raise an issue about their current equipment.

Program Evaluation

Establishing Processes, 

Procedures, and/or a 

Tracking System to Collect 

Data to Evaluate the 

Telework Program

Even though the four agencies we studied have processes and procedures 

to collect data on their telework programs, none of them currently does a 

survey specifically related to telework or has a tracking system that 

provides accurate participation rates and other information about 

teleworkers and the program. Such lack of information not only impedes 

the agencies in identifying problems or issues related to their telework 

programs, it also prevents these agencies from providing OPM, and 

subsequently Congress, with complete and accurate data.

Education’s process to collect data provides some useful information, but it 

is not complete. To compile information on telework at Education, a 

database was developed, which uses information from telework 

agreements and the department’s payroll system. Using this database, 

Education can produce reports on a number of topics, including the 

number of teleworkers, whether they telework on a regularly scheduled or 

ad hoc basis, what regions or offices they work for, who their supervisors 

are, and their grade levels. However, an Education program official 

acknowledged that although this system is designed to track telework 

agreements, some agreements are not accounted for, such as informal 

agreements that are unbeknownst to her or agreements that have not gone 

through the whole process. Furthermore, because it tracks agreements 

and not actual usage, the system cannot measure telework utilization. VA 

currently does not have a database for telework and uses decentralized 
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data collection methods, but a program official indicated that the agency 

plans to implement telework tracking via the time and attendance system. 

Although this official said that she hopes this new tracking system will 

address data inconsistency issues within the agency, she could not provide 

a time frame for its implementation.

OPM tracks its teleworkers by counting telework agreements and recently 

developed a database to keep track of these agreements, although a 

program official acknowledged that informal e-mailed telework 

agreements that are sometimes used at OPM might not all be included in 

the database because she did not receive them. As stated above, systems 

that rely on agreements to track telework participation do not actually 

provide information about utilization rates. At OPM this weakness is 

compounded by the fact that the agency does not ensure that telework 

agreements are used in all cases. GSA does not have an agencywide 

tracking system. Coordinators for individual units at GSA calculate 

telework data from telework agreements once a year in order to provide 

the information GSA submits for OPM’s annual governmentwide telework 

survey. However, no documentation is required for intermittent telework 

arrangements at GSA, and, as a result, a program official acknowledged 

that the number of these types of arrangements reported to OPM for its 

2002 telework survey was a rough estimate. She also said that the survey 

instruments and reporting mechanisms used by OPM’s governmentwide 

telework initiative for its annual report on telework in the federal 

government were a challenge in this area because of changes in the data 

requested from year to year, which made it difficult to determine the kind 

of system an agency needed to develop to best track the requested data.

Identifying Problems and/or 

Issues with the Telework 

Program and Making 

Appropriate Adjustments 

ITAC’s e-Work Guide recommends that organizations choose an evaluation 

design that 1) allows the clearest judgment of the program’s effectiveness 

and 2) uses the evaluation results to develop an action plan to guide any 

necessary changes for telework or for the organization. It states that 

organizations should use reliable and valid measures of all outcomes and 

processes, including benchmarking and follow-up assessment 

questionnaires, interviews, behavioral observations and ratings, or 

organizational data, because the quality of measurement is extremely 

important to enabling one to draw the proper conclusions regarding the 

effectiveness of telework and whether or not it has met the original 

objectives. 
Appendix II

Descriptions of Efforts by the Selected 

Agencies to Implement the 25 Key Practices

Page 56 GAO-03-679 Improving Federal Telework Efforts

Despite the importance of using data to evaluate and improve telework 

programs, none of the four agencies we reviewed had fully implemented 

this practice. A program official at Education told us she had collected 

data on the telework program and used these data to identify some 

potential problem areas. For example, she identified offices that had low 

telework program participation rates and an office that had teleworkers 

working only on an as-needed schedule and no one working on a fixed 

schedule. She used this information to target marketing efforts until she 

was told to stop actively marketing the program. In addition, a private 

contractor conducted a survey about Education’s telework program in 

1999. Although the survey’s response rate was very low due, in part, to 

technology incompatibilities across the department and a lack of support 

by union officials, the survey yielded four recommendations, none of which 

have been fully implemented. According to a GSA program official, GSA 

does not collect data to identify problems or make adjustments to its 

telework program. 

An OPM program official stated that she does not use the telework data she 

collects to identify issues with the program. Rather, she relies on 

employees to bring problems to her attention and responds accordingly. At 

VA, a program official identified an issue with the data collected for OPM’s 

2003 report to Congress on the status of telework. She believed the data 

collected within VA was inconsistent and needed to be reexamined. For 

example, 102,000 positions were identified as being eligible for telework for 

the January 2003 report, as opposed to 80,000 that had been identified for 

the January 2002 report. Since the program official thinks VA’s true eligible 

population is between 55,000 and 75,000 employees, she asked the local 

human resources representatives to reexamine the numbers they reported.
Page 57 GAO-03-679 Improving Federal Telework Efforts

Appendix III

Comments from the Department of Education ApendxiI

The Director of Human Resources Services from the Department of 

Education provided comments on a draft of this report via e-mail. In these 

comments, Education generally agreed with the contents of the draft report 

and stated that the department was pleased that we recognized its efforts 

to advance telework. Additionally, the comments stated that the 

department’s “most significant comment” was, as our draft noted, the need 

for a clear, unambiguous, and universally accepted definition for what it 

means to allow employees the opportunity to telework. 
Page 58 GAO-03-679 Improving Federal Telework Efforts

Appendix IV

Comments from the Department of Veterans 

Affairs ApendxiIV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 1.

See comment 2.

See comment 1.
Appendix IV

Comments from the Department of Veterans 

Affairs

Page 59 GAO-03-679 Improving Federal Telework Efforts

See comment 3c.

See comment 3f.

See comment 3a.

See comment 3d.

See comment 3b.

See comment 3e.

See comment 3g.
Appendix IV

Comments from the Department of Veterans 

Affairs

Page 60 GAO-03-679 Improving Federal Telework Efforts

GAO Responses to 

Comments from VA

1. VA agreed with our conclusion that there is a need for further guidance 

and assistance from GSA and OPM regarding federal telework 

implementation and suggested two areas where such guidance would 

be helpful. Specifically, VA indicated that OPM needs to redefine 

participant eligibility criteria and that OPM and GSA should provide 

guidance on how to effectively use telework in emergency situations. 

2. VA expressed concern that the draft report, which stated that we used 

participation rate as one of the criteria used in our selection of 

agencies, did not recognize what VA considers to be a significant factor 

accounting for its limited telework participation rate. In this regard, VA 

stated that a “significant number of VA employees are engaged in direct 

patient care and benefit service delivery to veterans, which precludes 

large-scale participation in telework.” As our draft noted, agencies 

were selected to provide illustrative examples of the extent to which 

individual agencies with varied sizes, reported utilization rates, and 

missions had implemented the key practices identified in our literature 

review. Nonetheless, we have added additional language to our scope 

and methodology section regarding the service delivery focus of VA’s 

mission. 

3. VA also had several comments on our findings related to the status of 

VA’s implementation of the telework practices that we identified. The 

specific issues that VA raised and our response to each are summarized 

as follows: 

a. In its comments, VA noted that it had conducted two pilot programs. 

When we requested additional information from VA to support its 

comment, VA provided us with information about two pilot programs 

that did not relate to their current telework program. VA also stated 

that it did not conduct a pilot program for its current telework policy. 

Because VA could not provide information about a pilot program for 

its current telework policy, we did not change our assessment that 

VA has not taken any steps to implement this practice.

b. VA said it had established measurable telework program goals and an 

the course of our work that VA did not have any measurable telework 

goals or an implementation plan. Therefore, we have not changed 

our assessment that VA has not taken any steps to implement these 

practices.
Appendix IV

Comments from the Department of Veterans 

Affairs

Page 61 GAO-03-679 Improving Federal Telework Efforts

c. VA commented, as our draft report had noted, that its revised 

telework policy has a “Self-Certification Safety Checklist.” However, 

as we also noted in our draft report, this policy is still in draft form 

and was not in use during our review. Because VA’s current telework 

policy does not contain a safety checklist and the draft checklist is 

not in use, we have not changed our assessment that VA has not 

taken any steps to ensure that teleworkers have safe and adequate 

places to work off-site.

d. VA indicated that it had developed a Telework Proposal form that 

was designed to facilitate communication among supervisors, 

employees, and managers. However, that form is part of VA’s revised 

telework policy, which, as noted in our draft report, has not yet been 

approved for use at VA and, therefore, was not considered in our 

evaluation. Moreover, this form, once approved, will not serve to 

establish policies or requirements to facilitate communication 

between managers and teleworkers, such as detailing the methods of 

communication that should be used or the frequency with which 

communication should occur while teleworking. More importantly, 

VA’s existing telework policy does not establish such policies or 

requirements to facilitate communication. Given these 

considerations, our assessment that VA has not taken any steps to 

implement this practice remains unchanged.

e. VA stated that the Telework Proposal form, which, as we noted, is 

still a draft, allows it to track and evaluate the effectiveness of its 

program as well as VA’s success in achieving targeted participation 

goals. This form simply allows VA to count how many employees 

have applied for telework and how many have been approved for 

such an arrangement. Such information will be important and 

valuable. However, the form would not fully enable VA to evaluate 

the effectiveness of its program or its success in achieving 

participation goals in terms of the number of employees actually 

teleworking and, equally important, the extent to which telework is 

being used. As we had noted in our draft report, a VA program 

official had indicated to us that the agency plans to implement 

telework tracking via the time and attendance system, which she 

hopes will address data inconsistency issues within the agency. Such 

a tracking mechanism, if implemented, could be helpful in tracking 

telework participation. Based on these considerations, our 

assessment that VA has taken some steps to implement this practice 

remains unchanged. 
Appendix IV

Comments from the Department of Veterans 

Affairs

Page 62 GAO-03-679 Improving Federal Telework Efforts

f. VA also stated that the department consistently advises supervisors 

and managers that performance standards for teleworkers and 

nonteleworkers should be the same and said that this was consistent 

with the criteria under our category of “Performance Management.” 

However, VA could not provide us with any information to support 

this comment. In fact, VA responded that it provides such advice “on 

an as-requested basis,” which does not constitute “consistently 

advising.” Furthermore, VA’s current telework policy does not 

contain any statements related to using the same performance 

standards for both teleworkers and nonteleworkers. Given these 

considerations, we have not changed our assessment that VA has not 

taken any steps to ensure that the same performance standards are 

used to evaluate both teleworkers and nonteleworkers.

g. In addition, VA noted that its ability to conduct a technology 

assessment for telework is compromised by the lack of clear 

guidance regarding which positions are suitable to telework. This 

further illustrates our finding, as stated in our draft report, that 

agencies may need additional guidance, guidelines, and/or 

individualized technical support to fully implement the practices we 

have identified. However, VA’s comment does not affect our 

assessment that VA has not taken any steps to implement this 

practice. 
Page 63 GAO-03-679 Improving Federal Telework Efforts

Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management ApendxiV

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.

See comment 3a.

See comment 3a.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 64 GAO-03-679 Improving Federal Telework Efforts

See comment 3c.

See comment 3e.

See comment 3b.

See comment 3b.

See comment 3d.

See comment 4k.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 65 GAO-03-679 Improving Federal Telework Efforts

See comment 1.

See comment 2.

See comment 1.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 66 GAO-03-679 Improving Federal Telework Efforts

See comment 4b.

See comment 4.

See comment 4a.

See comment 4c.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 67 GAO-03-679 Improving Federal Telework Efforts

See comment 4d.

See comment 4e.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 68 GAO-03-679 Improving Federal Telework Efforts

See comment 4g.

See comment 4f.

See comment 4h.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 69 GAO-03-679 Improving Federal Telework Efforts

See comment 4i.

See comment 4j.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 70 GAO-03-679 Improving Federal Telework Efforts

See comment 4k.

See comment 4l.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 71 GAO-03-679 Improving Federal Telework Efforts

See comment 5a.

See comment 5c.

See comment 5.

See comment 5b.

See comment 5d.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 72 GAO-03-679 Improving Federal Telework Efforts

GAO Responses to 

Comments from GSA 

and OPM 

1. In their combined comments, GSA and OPM agreed that telework is an 

important tool for federal agencies and stated that they would 

encourage and champion telework as a key human capital flexibility 

and do everything possible to facilitate its acceptance and use. The 

agencies also agreed to implement our recommendation that they use 

their lead roles in the federal telework initiative to assist agencies in 

implementing the key telework practices we identified. In this regard, 

GSA and OPM stated that they will provide agencies with a checklist of 

the practices we identified and recommend that agencies do a selfassessment of their telework programs using our analytical framework. 

Both GSA and OPM will then offer to help agencies to improve in the 

identified areas of deficiency. OPM will also include the key telework 

practices that we identified in telework training, which, as we had 

noted in the draft report, is being developed for launch on its Webbased training site during fiscal year 2003.

2. In addition, GSA agreed with our recommendation that it work with 

Congress to determine what was meant by the phrase “GSA 

telecommunication center” in Section 314, Division F, title III of Pub. L. 

No. 108-7 and whether this provision is in conflict with the provision 

contained in 40 U.S.C. 587(d)(2). GSA stated that it will coordinate 

internally and with the appropriate congressional committees to 

resolve the conflicting language in the statutes and then provide 

clarification to its customer agencies. 

3. GSA and OPM disagreed with several of our findings relating to their 

lead roles in the governmentwide telework initiative. Below are 

summaries of GSA’s and OPM’s comments and our responses:

a. These agencies stated that, given the efforts they have made in 

promoting telework, they were “taken aback” by language in the draft 

that noted confusion at the “implementation level” throughout the 

federal government regarding the policy guidance that they had put 

forth to date. However, as detailed in our draft report, our finding 

was actually that conflicting messages from GSA and OPM on certain 

telework-related matters had created confusion. Apart from this 

finding, we recognize GSA’s and OPM’s efforts to promote telework 

and had included in our draft report many of the examples of those 

efforts that GSA and OPM cited in their response, such as jointly 

running the telework Web site to provide information and guidance, 

OPM’s rapid issuance of guidance in response to our finding related 
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 73 GAO-03-679 Improving Federal Telework Efforts

to the lack of a definition for providing employees with the 

opportunity to telework, and GSA’s management and promotion of 

the telework centers. Also, our draft report discussed OPM’s 

outreach effort to meet face to face with agencies’ telework 

coordinators and, as GSA’s and OPM’s comments noted, this effort 

was also described in our May 2003 report entitled Human Capital: 

OPM Can Better Assist Agencies in Using Personnel Flexibilities.

48 

However, while such promotional efforts can be constructive, they 

do not address the confusion we identified as a result of GSA’s and 

OPM’s conflicting messages. 

b. GSA and OPM strongly disagreed with our finding that they have not 

fully coordinated their governmentwide telework efforts in the past. 

In one instance, they said that the draft report stated there were 

unresolved disagreements between GSA and OPM on telework policy 

issues concerning dependent care and emergency closing of 

government offices, and that they believed there were no such 

disagreements. However, GSA and OPM also stated that, while they 

believed that their responses to the dependent care and emergency 

closing issues were not in conflict, they clarified them to avoid any 

confusion. We believe this is a noteworthy development because, as 

stated in our draft report, agencies had expressed concern about 

conflicting messages they had received from GSA and OPM on 

several topics, including dependent care and emergency closings. 

More generally, we also indicated in our draft report that, because 

GSA and OPM have not developed a Memorandum of Understanding 

or other formal agreement regarding their responsibilities for the 

governmentwide telework initiative, they should work together to 

reach a formal agreement establishing a delineation of these 

responsibilities. In their comments, the agencies said that they have 

recognized the need to better outline separate and shared 

responsibilities and that a Memorandum of Understanding was 

among the options they were considering to clearly designate each 

agency’s responsibilities. We have added language to reflect GSA’s 

and OPM’s commitment to address these areas.

48U.S. General Accounting Office, Human Capital: OPM Can Better Assist Agencies in 

Using Personnel Flexibilities, GAO-03-428 (Washington, D.C.: May 9, 2003).
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 74 GAO-03-679 Improving Federal Telework Efforts

c. In addition, GSA’s and OPM’s comments said that it was unnecessary 

for OPM to re-coordinate with GSA on the final version of the 

telework guide for managers, supervisors, and telework coordinators 

because GSA’s comments had already been incorporated into the 

guide. Although we found that OPM had made substantive changes 

to the guide subsequent to GSA’s review, we now believe that, given 

the concerns expressed by agencies, and underscored by Education’s 

and VA’s comments on our draft report, it was sufficiently important 

to issue the guide in a timely fashion, without a final review by GSA. 

Relevant changes have been made to our report.

d. According to GSA’s and OPM’s comments, GSA’s senior program 

executive for telework disputed our finding that GSA had expressed 

concerns about OPM’s changes to the joint OPM/GSA telework Web 

site (www.telework.gov). However, this statement varies from 

information provided to us both by GSA and OPM officials during the 

course of our review and by the senior OPM official for the 

governmentwide telework initiative at our exit conference with OPM. 

For example, during our exit conference, the senior OPM official for 

the governmentwide telework initiative acknowledged changing the 

telework Web site without GSA being informed or OPM getting input 

from GSA. She said that GSA was not very happy with the new look, 

adding that GSA felt the changes were imposed on it by OPM without 

any consultation. Nonetheless, we have adjusted the report to reflect 

the view of the GSA senior program executive.

e. In their comments, GSA and OPM also said that the two agencies had 

jointly determined it would be inappropriate to post the “predecisional” Interagency Telework Issues Working Group report on 

the federal telework information Web site (www.telework.gov) until 

they had had the opportunity to analyze its findings, address issues 

contained therein, and fully consider all recommendations. 

However, GSA has already independently posted this report on its 

own Web site with a disclaimer, stating: “OPM and GSA co-led the 

Interagency Telework Issues Working Group by offering technical 

guidance, support, and resources. The findings and 

recommendations made in this final report reflect the opinions of the 

Working Group members. This final report does not in any way, 

specific or implied, represent the official views, positions, or policies 

of the U.S. Government, OPM, GSA, nor any of the agencies 

participating on the Working Group. This report is currently under 

review by both OPM and GSA.” Given that GSA and OPM co-led this 
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 75 GAO-03-679 Improving Federal Telework Efforts

group with participation from 15 federal agencies to identify policy 

actions needed to facilitate agency use and expansion of telework 

and then make recommendations, we believe that the report should 

be posted on www.telework.gov, with the same or a similar 

disclaimer, in the interests of transparency.

4. OPM also raised issues with our analysis of its internal telework 

program. OPM stated that our draft report indicated that 12 of our 25 

identified key practices still needed to be implemented at OPM. While 

our draft report showed that OPM had “fully implemented” 13 of the 

practices, it went on to say that OPM had “taken some steps to 

implement” 5 of the remaining practices and had “not taken any steps 

to implement” the other 7 practices. OPM’s comments related to its 

internal telework program maintained that it has fully implemented 24 

of the 25 practices, stating that the 25th practice should not apply to it. 

As we clarified in this report, some of the practices, such as developing 

an implementation plan and establishing a pilot program, are historical 

in nature and cannot be implemented at this time by agencies with 

existing telework programs. However, as we also clarified in the 

report, agencies with existing programs that did not initially implement 

some of the more developmental practices can still be successful with 

sustained attention to the other practices we identified. 

In its comments, OPM stated that “[E]ach comment listed was 

conveyed to GAO during the interview process.” On the contrary, 

OPM’s comments, for the most part, contain new information and/or 

information that does not correspond with what was conveyed to us 

during our meetings with OPM officials. Summaries of OPM’s 

comments, and our responses, are discussed below: 

a. OPM disputed our finding that the agency had not established 

measurable telework program goals, saying that it had done so by 

meeting, even exceeding, the requirements of Section 359 of Pub. L. 

No. 106-346. OPM said that, “[i]n effect, the legislation has provided 

the program goals for Federal agencies through 2004.” However, in 

its May 2003 telework guide for managers, supervisors, and telework 

coordinators,49 OPM discusses the importance of establishing 

program goals and objectives for telework because they will be 

49U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for 

Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 76 GAO-03-679 Improving Federal Telework Efforts

helpful in conducting program evaluations of a telework program. 

OPM’s guide notes that “[k]ey issues for evaluation for most agencies 

include the effect of telework on productivity, operating costs, 

employee morale, recruitment, and retention” and that the evaluation 

plan “should be based on quantifiable program goals and objectives 

to allow for ease of measurement.” Section 359 of Pub. L. No. 106-

346 refers broadly to the federal workforce and OPM has not 

provided any documentation illustrating how it has converted the 

law’s requirements into program goals to measure the effect of 

telework on productivity, operating costs, employee morale, 

recruitment, retention, or any other such desirable outcome. 

Moreover, OPM’s telework coordinator told us during the course of 

our review that goals have not been set for OPM’s internal program. 

Given these considerations, our assessment of OPM for this practice 

remains unchanged.

b. OPM disagreed with our finding that it had not established a business 

case for implementing a telework program, stating that the business 

case for telework has been developed through various means, 

including statements made in its governmentwide guidance, 

information provided in training sessions for its managers, and by 

referring its managers to the OPM/GSA telework Web site. As 

described in a source from which we drew our key practices, a 

comprehensive business case for a telework program entails 

identifying full costs and benefits to the extent practicable, prior to 

implementation of the program, that are specific to the organization, 

including IT components, facilities, recruiting, retention, contingency 

support, and security and risk assessments.50 The business case that 

OPM refers to in its comments does not fully meet these criteria. 

Furthermore, this comment does not correspond with what was 

conveyed to us during our meetings with OPM officials. Instead, 

OPM’s telework coordinator at the time its current program was 

developed in 2001 told us that a business case for telework had not 

been developed prior to implementing the telework program. Given 

these considerations, our assessment of OPM for this practice 

remains unchanged. 

c. OPM disputed our finding that it has only taken some steps to 

provide funding to meet the needs of the telework program. The 

50Booz Allen Hamilton, V-2.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 77 GAO-03-679 Improving Federal Telework Efforts

agency said that it has provided “full funding” for its telework 

program and that it has identified resources that have allowed it to 

accommodate “every employee (who is otherwise eligible and wants 

to telecommute) with appropriate computer equipment, technology 

support, and remote connections.” OPM did not provide 

documentation of this funding. As our draft report indicated, OPM 

has taken important steps to implement this practice, by paying the 

salary for a telework coordinator and setting aside $50,000 in fiscal 

year 2002 for telework center use, as required by law. However, an IT 

official at OPM said that there were times that the agency has 

experienced shortages of the older computers it loans to 

teleworkers. He said that the people who absolutely need to 

telework get computers immediately, if they require one, but that 

people who would like to telework, but do not have a “need” to do so, 

have had to wait to begin teleworking until computers become 

available. According to this IT official, managers usually make the 

decision about whether telework is a “need,” although employees 

will sometimes decide for themselves that it is not necessary for 

them to telework. Given these considerations, we did not change our 

assessment that OPM had taken some steps to implement this 

practice.

d. OPM questioned the validity of our having assessed its telework 

program against the practice of establishing a pilot program because 

“the founding legislation” did not include a requirement for 

establishing pilot programs and because OPM is confident that a pilot 

would not have added significant value to its program. As noted in 

our draft, we used a variety of sources, including GSA’s and OPM’s 

telework guidance, to identify key practices. Successful telework 

experiences and related telework literature suggest that pilot 

programs can be valuable at the outset of telework initiatives by 

providing a means to test the concept and its integration within a 

particular organization’s environment. However, as we recognize in 

this report, agencies with existing telework programs that did not 

implement this practice when the program was initially developed 

can still have successful telework programs with sustained attention 

to the other practices. Because OPM did not establish a pilot 

program at the outset of its telework program, our assessment of 

OPM for this practice remains unchanged.

e. OPM disagreed with our finding that it had taken some steps to 

establish eligibility criteria to ensure that teleworkers are selected on 
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 78 GAO-03-679 Improving Federal Telework Efforts

an equitable basis using criteria such as suitability of tasks and 

employee performance, stating that it had fully implemented this 

practice by providing objective eligibility criteria in its telework 

policy. Our draft report noted the progress OPM had made in this 

area and that guidance was in place on eligibility criteria. However, 

OPM’s telework coordinator also told us that the eligibility criteria 

varied by OPM unit and may not be consistently applied. Therefore, 

while the OPM guidance is an important step, its consistent 

application is not being ensured. Thus, we continue to believe that 

OPM has taken some steps to implement this practice.

f. OPM disagreed with our finding that it had taken some steps to 

establish policies or requirements to facilitate communication among 

teleworkers, managers, and coworkers, stating that its policy and 

associated forms serve to facilitate communication. Based on 

further analysis of the policy and its associated forms, we have 

changed the report to reflect that OPM has fully implemented this 

practice. 

g. OPM disagreed with our finding that it has taken some steps to 

develop guidelines on workplace health and safety issues to ensure 

that teleworkers have safe and adequate places to work off-site, 

because one of the appendixes included with OPM’s telework policy 

is a safety checklist for the alternate worksite. As we noted in our 

draft report, OPM’s telework policy states that the telework 

agreement should include a safety checklist. Importantly, however, 

the suggested checklist, included as an appendix to OPM’s policy, 

states that the employee “may use” it to “assist them in a survey of 

the overall safety and adequacy of their alternate worksite.” It goes 

on to say “the following are only recommendations and do not 

encompass every situation that may be encountered.” Moreover, the 

checklist does not have a signature line or any way for it to be 

certified by the employee. Because this checklist is only 

recommended, not required, and does not need to be certified by the 

employee, it is not sufficient to ensure that teleworkers have a safe 

and adequate place to work off-site. Therefore, we continue to 

believe that OPM has taken some steps to implement this practice.

h. OPM disagreed with our finding that it has not taken any steps to 

ensure that the same performance standards, derived from a modern, 

effective, credible, and validated performance system, are used to 

evaluate both teleworkers and nonteleworkers, saying that the 
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 79 GAO-03-679 Improving Federal Telework Efforts

performance standards that employees are evaluated against 

annually are based on the duties and responsibilities of the 

employee’s position and not on whether the employee is a teleworker 

or nonteleworker. OPM further stated that the performance 

standards are the same, regardless of where the work is performed. 

As we stated in the draft report, although OPM’s policy does state 

that the employees’ current performance standards will be used to 

govern all telecommuting assignments, as well as those in the 

telecommuters’ current traditional federal offices. However, it does 

not include a statement requiring that the same performance 

standards be used for teleworkers and nonteleworkers. Without 

such a statement, at a minimum, OPM cannot fully ensure that the 

same performance standards are used to evaluate both teleworkers 

and nonteleworkers. Nonetheless, we have revised the report to 

acknowledge that OPM has taken some steps to implement this 

practice. While these steps are important, there are steps that OPM 

can take to more fully ensure that the criteria have been consistently 

applied, such as periodically checking the performance appraisals for 

consistency. 

i. OPM disagreed with our finding that it had not taken any steps to 

train all involved in its telework program, including, at a minimum, 

managers and teleworkers, saying that it has provided extensive 

training to both managers and employees. However, this comment 

does not correspond with what was conveyed to us during our 

meetings with OPM officials. According to both the current and past 

OPM telework coordinators, OPM had provided mandatory training 

to managers and optional training to employees when the telework 

program began, more than 2 years ago. In addition, they told us that 

OPM has not provided any training since then. Even the initial 

training would not have been sufficient to train “all involved” in the 

telework program, because employees were not required to attend. 

In response to OPM’s comments, we have revised our report to 

reflect OPM’s initial training efforts by indicating that OPM has taken 

some steps to implement this practice. We are also pleased that OPM 

indicated in its comments that, now that its agency restructuring has 

been completed, it plans to provide continued outreach and training 

on telework. However, OPM cannot be considered to have fully 

implemented the practice of training all involved in its telework 

program until this training is actively provided to and required of all 

relevant parties.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 80 GAO-03-679 Improving Federal Telework Efforts

j. OPM disputed our finding that it had not taken any steps to establish 

standards for equipment in the telework environment, saying that 

OPM has a standard platform for connectivity and has established a 

protocol for requesting necessary equipment and connectivity. 

During our review, an IT official from OPM told us that the equipment 

standards had not yet been fully applied to agency-owned equipment, 

but he expected this to be done between July and October 2003. 

Based on OPM’s more recent comments, we have revised our report 

to reflect that OPM has taken some steps to implement this practice. 

However, the IT official also told us that OPM does not have a 

standard for employee-provided equipment. Until OPM establishes 

and applies its standards to employee-provided equipment, it will not 

have fully implemented this practice.

k. OPM disputed our finding that it had taken some steps to establish 

processes, procedures, and/or a tracking system to collect data to 

evaluate the telework program, stating that it collects and tracks a 

variety of data that is used to evaluate and report on its telework 

program. According to OPM, because its policy states “[c]ompleted 

work agreements must be forwarded to the organizational 

telecommuting contact for record keeping purposes,” the agency has 

fully implemented this practice. In our draft report, we recognize 

OPM’s policy that employees sign a work agreement with their 

supervisor. However, OPM’s telework coordinator told us that work 

agreements, whether in hard copy or e-mail form, are not always 

completed and forwarded to her. Additionally, while OPM endeavors 

to track participation rates through these work agreements, the 

agreements only provide information on how many employees have 

been approved to telework, not how many are actually participating. 

Without a tracking and evaluation system that accurately measures 

program participation, OPM cannot be considered to have taken 

more than some steps to implement this practice. One such system 

was suggested by OPM itself in the section of GSA’s and OPM’s 

comments on our draft report that is related to those agencies’ 

governmentwide leadership roles. These comments said, “OPM has 

concluded from research that the best telework data is collected 

through time and attendance tracking systems. OPM will be issuing 

guidance to agencies later this year on the use of this data source for 

its next survey.” Such guidance will be an important step toward 

helping all agencies to more accurately track and report such data 

and so that they can use the data for evaluation and program 

improvement purposes.
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 81 GAO-03-679 Improving Federal Telework Efforts

l. OPM disputed our finding that it had not taken any steps to identify 

problems and/or issues with the telework program and make 

appropriate adjustments, indicating that the various surveys and data 

it collects are used, not only to report on the number of employees 

teleworking in the agency, but also to help inform enhancements to 

its program. However, OPM’s telework coordinator indicated that 

she does not actively seek to identify issues using any evaluation 

tools. Instead, as OPM pointed out in its comments, she relies on 

employees to bring issues to her attention. While employees can be 

an important source of information, such data sources are 

complements to, and not substitutes for, formal feedback 

mechanisms and well-designed evaluations, as described in OPM’s 

recently released telework guide to managers, supervisors, and 

telework coordinators.51 Nonetheless, given these considerations, 

we have revised our assessment of OPM for this practice to reflect 

that it has taken some steps to implement this practice. 

5. GSA did not disagree with our findings pertaining to its internal 

telework program. However, the agency did note several areas where it 

would like us to revise statements relative to its implementation of the 

key practices we identified. Below is a summary of GSA’s comments 

and our responses: 

a. GSA said that, since its program has been in place for more than 10 

years, it does not have or need a current implementation plan. 

Furthermore, GSA indicated that it had an implementation plan that 

was utilized 10 years ago, when the program was first developed. 

However, GSA stated that this plan was not kept in the files, because 

it is no longer in use. We agree that GSA should not develop an 

implementation plan for a program that is already in place. Our 

analysis was focused on whether an agency had developed an 

implementation plan to shape the design and implementation of its 

program to ensure future success. In this regard, GSA’s telework 

coordinator had told us that there was not a written implementation 

plan for the telework program when it was first started. 

Nevertheless, we have revised our report to indicate that we were 

unable to assess GSA on this practice.

51U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for 

Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).
Appendix V

Comments from the General Services 

Administration and the Office of Personnel 

Management

Page 82 GAO-03-679 Improving Federal Telework Efforts

b. GSA indicated that it does not have a central telework fund and that 

individual organizations within GSA provide their own funding. We 

had considered this information in our analysis of the level of GSA’s 

implementation of this practice. However, we have added GSA’s 

statement to our report to provide additional context. Also, as 

already noted in our draft report, GSA said that it had set aside the 

required central funding for telecenter utilization.

c. GSA noted that it has an operational telework program and, 

consequently, there is no further need for piloting. We agree with 

GSA that there is no further need for piloting. Our analysis in this 

regard assessed whether or not an agency had established a pilot at 

the beginning of its individual telework program. GSA did not 

establish a pilot program prior to implementation of its telework 

program. Therefore, our assessment of GSA for this practice remains 

unchanged.

d. In addition, GSA provided comments related to several other areas, 

including: 1) its position on establishing telework eligibility criteria, 

2) its emphasis on fairness toward teleworkers and others, and 3) its 

existing lines of communication regarding telework, including its 

network of telework coordinators in regions and organizations 

throughout the agency, its provision of e-mail and on-line information 

on telework, and its “strong emphasis on communication.” While 

these comments were helpful in setting the context for GSA’s internal 

telework program, they were not relevant to our analysis and, 

therefore, are not reflected in the body of our report.

(450126)
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