U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL

Railroad Retirement Board’s 

Telework Program Needs 

Improvement

Report No. 20-05 April 24, 2020
OFFICE OF INSPECTOR GENERAL 

U.S. RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs 

Improvement

Report Summary April 24, 2020 Report No. 20-05

What We Found 

The Railroad Retirement Board (RRB) developed a telework 

policy, implemented a telework program, and designated a 

telework managing officer (TMO), but did not have a fully 

effective internal control system over its program. Specifically, 

we identified that RRB policy did not contain appropriate TMO 

information, the RRB’s privacy administrative circulars that 

supported its telework program were outdated, RRB controls 

were not fully effective for ensuring that telework training and 

written agreements were completed, and RRB has not 

monitored or evaluated its telework program in accordance 

with applicable guidance. Further, we determined the RRB 

submitted inaccurate and unsupported data to the Office of 

Personnel Management for fiscal years 2017 and 2018. This 

occurred because the RRB’s telework program was highly 

decentralized and someone other than the TMO provided 

program oversight. This decentralized approach, including the 

lack of a tone at the top and middle, was the primary cause for 

most of our findings outlined in the report. During 

fiscal years 2017 and 2018, the RRB did not have a full Board in 

place to ensure compliance with the applicable telework laws, 

regulations, and policy. 

What We Recommend

To address the exceptions identified in this audit, we made 

eight recommendations for improving the RRB’s telework

program, policies, procedures, and internal controls.

Of the eight recommendations, RRB management concurred 

with three, partially concurred with one, and did not concur 

with four. For the recommendations with which it concurred, 

Office of Administration and Bureau of Information Services 

provided target completion dates in management comments as 

provided in the appendix.

What We Did 

RRB’s telework program had never 

been reviewed subsequent to the 

enactment of the Telework 

Enhancement Act of 2010. By 

fiscal year 2018, the RRB offered 

telework arrangements to almost 

all of its employees.

The objective of this audit was to 

determine if the RRB’s telework 

program had controls in place to 

ensure the protection of privacy 

data and agency information used 

while teleworking and compliance 

with telework laws and 

regulations.

In order to complete this work, we 

reviewed relevant laws, 

regulations, RRB policies and 

procedures, interviewed 

appropriate RRB management and 

staff, and reviewed available 

telework reports. Additionally, we 

anonymously surveyed RRB 

managers and employees to 

determine their understanding of 

telework policies and practices. 

The scope of this audit included an 

evaluation of the RRB’s internal 

controls over its telework program 

during fiscal years 2017 and 2018.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Contents

INTRODUCTION 1

OBJECTIVE, SCOPE, AND METHODOLOGY 1

BACKGROUND 2

RESULTS OF AUDIT 5

SOME OF THE RRB’S INTERNAL CONTROLS OVER ITS TELEWORK PROGRAM NEEDED 

IMPROVEMENT 5

RRB POLICY DID NOT CONTAIN APPROPRIATE TELEWORK MANAGING OFFICER 

INFORMATION 6

RRB’S PRIVACY ADMINISTRATIVE CIRCULARS THAT SUPPORT ITS TELEWORK PROGRAM 

NEEDED TO BE UPDATED 6

RRB’S INTERNAL CONTROLS WERE NOT FULLY EFFECTIVE TO ENSURE THAT EMPLOYEE 

AND SUPERVISOR TELEWORK TRAINING WAS COMPLETED PRIOR TO TELEWORKING 7

RRB’S INTERNAL CONTROLS TO ENSURE PROPER EXECUTION OF WRITTEN AGREEMENTS 

WERE NOT FULLY EFFECTIVE 8

RRB’S MONITORING OF THE PERFORMANCE OF ITS TELEWORK PROGRAM NEEDED 

IMPROVEMENT 10

RECOMMENDATIONS 11

MANAGEMENT COMMENTS AND OUR RESPONSE 12

DATA COLLECTED AND REPORTED TO THE OFFICE OF PERSONNEL MANAGEMENT NEEDED TO BE 

SUPPORTED 14

RECOMMENDATION 15

MANAGEMENT COMMENTS AND OUR RESPONSE 15

APPENDIX I: MANAGEMENT COMMENTS 16

APPENDIX II: MANAGEMENT COMMENTS 19

APPENDIX III: INTERNAL CONTROL STANDARDS 20

APPENDIX IV: ROLES AND RESPONSIBILITIES 22

OFFICE OF PERSONNEL MANAGEMENT 22

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY 22

HEAD OF EACH EXECUTIVE AGENCY 22

TELEWORK MANAGING OFFICER 23

BUREAU OF HUMAN RESOURCES 24

BUREAU OF INFORMATION SERVICES 24

APPENDIX V: TELEWORK SURVEY 25

ADDITIONAL COMMENTS PROVIDED BY RRB TELEWORKERS 33
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

LIST OF FIGURES

FIGURE 1. QUESTION 1 SURVEY RESPONSES 25

FIGURE 2. QUESTION 2 SURVEY RESPONSES 25

FIGURE 3. QUESTION 3 SURVEY RESPONSES 26

FIGURE 4. QUESTION 4 SURVEY RESPONSES 26

FIGURE 5. QUESTION 5 SURVEY RESPONSES 27

FIGURE 6. QUESTION 6 SURVEY RESPONSES 27

FIGURE 7. QUESTION 7 SURVEY RESPONSES 28

FIGURE 8. QUESTION 8 SURVEY RESPONSES 28

FIGURE 9. QUESTION 9 SURVEY RESPONSES 29

FIGURE 10. QUESTION 10 SURVEY RESPONSES 29

FIGURE 11. QUESTION 11 SURVEY RESPONSES 30

FIGURE 12. QUESTION 12 SURVEY RESPONSES 30

FIGURE 13. QUESTION 13 SURVEY RESPONSES 31

FIGURE 14. QUESTION 14 SURVEY RESPONSES 31

FIGURE 15. QUESTION 15 SURVEY RESPONSES 32

FIGURE 16. QUESTION 16 SURVEY RESPONSES 32

FIGURE 17. QUESTION 17 SURVEY RESPONSES 33

LIST OF TABLES

TABLE 1. OIG REVIEW OF FISCAL YEAR 2017 AND 2018 TELEWORK WRITTEN AGREEMENTS 9
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 1

INTRODUCTION

This report presents the results of the Office of Inspector General’s (OIG) audit of the Railroad 

Retirement Board’s (RRB) telework program, policies, and data.

1 We conducted the audit as 

part of our annual work plan and because the program had never been reviewed subsequent to 

the enactment of the Telework Enhancement Act of 2010.2 In August 2003, the RRB began their

telework program and by fiscal year 2018, the RRB offered telework arrangements to almost all 

of its employees. According to telework guidance, telework programs have the potential to 

attract and retain employees, reduce office space, reduce commutes, increase productivity, 

improve work/life balance, reduce employee absences, and support a continuity of operations. 

Executed telework arrangements can also help put injured, recuperating, and physically limited 

employees back to work and take them off sick leave. 

Objective, Scope, and Methodology

The audit objective was to determine if the RRB’s telework program had controls in place to 

ensure

 the protection of privacy data and agency information used while teleworking; and

 compliance with telework laws and regulations. 

Our scope included an evaluation of the RRB’s internal controls over its telework program

during fiscal years 2017 and 2018. Specifically, we identified and reviewed relevant laws, 

regulations, RRB policies, RRB procedures, and external and internal guidance related to 

telework. We interviewed appropriate RRB management and staff to gain a better 

understanding of the RRB’s telework program, including processes and procedures for 

responding to the Office of Personnel Management’s (OPM) annual data call.

3 We obtained and 

reviewed available telework reports. Finally, we developed an OIG survey and anonymously 

surveyed RRB managers and employees to determine their understanding of telework policies 

and practices while teleworking. We evaluated the results to identify issues for a future 

potential audit and determine if any immediate issues required review, such as a teleworker 

accessing the RRB network without using the virtual private network. The survey results were 

not used to identify findings or issue recommendations in this audit. However, we provided the 

 1 The official definition of “telework” can be found in the Telework Enhancement Act of 2010: "[t]he term 

'telework' or 'teleworking' refers to a work flexibility arrangement under which an employee performs the duties 

and responsibilities of such employee's position, and other authorized activities, from an approved worksite other 

than the location from which the employee would otherwise work."

2 Pub. L. 111-292, 124 Stat. 3165 (Dec. 9, 2010), codified primarily at chapter 65 of title 5 of the United States 

Code. 3 The Telework Act requires the Office of Personnel Management (OPM) to submit an annual report addressing the 

telework programs of each executive agency. In response to the original congressional mandate, OPM began to 

survey federal agencies about telework in 2000. By means of the annual call for telework data, OPM collaborated 

with federal agencies to collect information about individual agency telework programs, including participation 

rates.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 2

results in Appendix V for management and other users of this report for informational 

purposes.

Our review of internal controls was limited to those necessary to address the objective and 

scope of the audit. Specifically, we used the Government Accountability Office’s (GAO) 

Standards for Internal Control in the Federal Government (known as the Green Book) to conduct 

our evaluation of the telework program in regard to the RRB’s task to operate efficiently and 

effectively, report reliable information about its operations, and comply with applicable laws 

and regulations.4 Refer to Appendix III for more information on the Green Book, including 

further descriptions of each component and examples of the underlying principles as they 

relate to this audit.

We assessed the data reliability of the telework training completions report from RRB 

University, the RRB’s learning management system, by (1) performing electronic testing of 

required data elements, (2) reviewing existing information about the data, and (3) interviewing 

agency officials knowledgeable about RRB University. We determined the data from 

RRB University was sufficiently reliable for the purposes of this report.

Additionally, we evaluated if the RRB’s reported telework data was complete and accurate by 

(1) reviewing the 2017 and 2018 data calls the RRB submitted to OPM, (2) comparing reported 

data to the supporting documentation and data from the RRB's time and attendance systems, 

and (3) corroborating reported data with testimonial evidence. We determined the reported 

telework data was not complete or accurate. We discuss this in the section of this report titled

Data Collected and Reported to Office of Personnel Management Needed to be Supported.

We conducted this performance audit in accordance with generally accepted government 

auditing standards.5 Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

We conducted our fieldwork at RRB headquarters in Chicago, Illinois, from January 2019 

through January 2020. Audit fieldwork was limited during certain times due to resource 

requirements and mandated audits.

Background

The RRB is an independent agency in the executive branch of the Federal Government. The 

agency administers comprehensive retirement/survivor and unemployment/sickness insurance 

benefit programs for railroad workers and their families under the Railroad Retirement Act of 

1974, as amended, and the Railroad Unemployment Insurance Act.6 These programs provide 

 4 Government Accountability Office (GAO), Standards for Internal Control in the Federal Government, 

GAO-14-704G (Washington, D.C.: September 2014). 5 GAO, Government Auditing Standards – 2011 Revision, GAO-12-331G (Washington, D.C.: December 2011). 6 45 U.S.C Chapter 9 and 45 U.S.C. Chapter 11, respectively.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 3

income protection during old age and in the event of disability, death, temporary 

unemployment, or sickness.

A three member Board appointed by the President of the United States, with the advice and 

consent of the Senate, leads the RRB and is the head of the agency. The President appoints one 

member upon the recommendation of railroad employers, another upon the recommendation 

of railroad labor organizations and the third, who is the Chairman, to represent the public 

interest. The Board Members’ terms of office are 5 years and expire in different years.

Telework is a work arrangement that allows an employee to perform work, during regular paid 

hours, at an approved alternative worksite (e.g., home, telework center). Congressional interest 

in expanding the use of telework in the executive branch began with the passage of the 

Transportation and Related Agencies Appropriations Act of 2001.7 To expand on previous 

telework legislation, the Telework Enhancement Act of 2010 (the Act) was passed on

December 9, 2010.8 The purpose of the Act was “[t]o require the head of each executive agency 

to establish and implement a policy under which employees shall be authorized to telework, 

and for other purposes.” Additionally, the Act

 directed each agency to designate a telework managing officer (TMO);

 required that employees and managers complete interactive training;

 required signed written telework agreements;

 required agencies to incorporate telework into their continuity of operations plans; and

 required OPM to maintain Telework.gov to provide easy access to information about 

telework in the Federal Government.9

Since the RRB began its telework program in 2003, the Act was signed into law and OPM’s

Guide to Telework in the Federal Government (the OPM Telework Guide) was issued in 

April 2011.

10 The OPM Telework Guide outlined practical information to assist federal agencies, 

managers, supervisors, TMOs, other staff responsible for implementing telework, and 

employees.

In support of the RRB’s telework program, the RRB’s Office of Administration’s (OA) Bureau of 

Human Resources (HR) developed the RRB’s Work-At-Home Program (WAH) policy, which was 

last revised in August 2016.11 The WAH policy incorporated references to Administrative 

Circulars Information Resources Management (IRM)-2 Management of Information Privacy for 

Individuals, IRM-15 Safeguarding Protected Information and Breach Notification Protocol, and 

 7 Pub. L. 106-346 (2001). 8 Pub. L. 111-292 (2010). 9 Pub. L. 111-292 (2010). 10 Office of Personnel Management (OPM), Guide to Telework in the Federal Government (Washington, D.C.: 

April 2011). 11 Railroad Retirement Board (RRB), Work-At-Home Program (Chicago, IL: August 2016).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 4

IRM-16 Telecommuting and Mobile Computing Security.

12 We also determined that in 2015 the 

Bureau of Fiscal Operations developed a hoteling policy for eligible employees as an additional 

option under the WAH policy.13

At the time of our audit, the RRB offered telework to all eligible employees. In fiscal year 2018, 

the RRB self-reported that they offered telework to 572 eligible employees and approximately 

91 percent of those eligible choose to participate. In fiscal year 2018, the RRB employed 

approximately 820 individuals. For a discussion of the concerns we had with the accuracy and 

completeness of this data, please refer to the section in this report titled Data Collected and 

Reported to Office of Personnel Management Needed to be Supported. 

Appendix IV provides the roles and responsibilities of OPM, National Institute of Standards and 

Technology (NIST), head of each executive agency, the TMO, and HR as related to telework.

 12 RRB Administration Circular Information Resources Management (IRM)-2, Management of Information Privacy 

for Individuals (Chicago, IL: September 3, 2008). RRB Administrative Circular IRM-15, Safeguarding Protected 

Information and Breach Notification Protocol (Chicago, IL: March 28, 2016). RRB Administrative Circular IRM-16, 

Telecommuting and Mobile Computing Security (Chicago, IL: May 27, 2009). 13 Bureau of Fiscal Operations, Work At Home (Chicago, IL: May 14, 2015).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 5

RESULTS OF AUDIT

Our audit determined that the RRB developed a telework policy, implemented a telework 

program, and designated a TMO as required by law.14 However, the RRB did not have a fully 

effective internal control system over its telework program to ensure the protection of privacy 

data and agency information used while teleworking or compliance with telework laws and 

regulations. The RRB did not follow some of its own telework procedures and needs to improve 

its control environment, control activities, and telework monitoring. Specifically, we identified 

that RRB policy did not contain appropriate TMO information, the RRB’s privacy administrative 

circulars that support its telework program were outdated, RRB controls were not fully effective 

for ensuring that telework training and written agreements were completed as required, and 

RRB has not monitored or evaluated its telework program in accordance with applicable 

guidance. 

Further, we reviewed the RRB’s annual data submission to OPM and attempted to verify the 

accuracy of the data submitted for fiscal years 2017 and 2018. Of the data we could review, we 

determined that the RRB submitted inaccurate and unsupported data to OPM. The remaining 

data was unavailable for our review.

During fiscal years 2017 and 2018, the RRB’s telework program was highly decentralized and 

program oversight was provided by someone other than the TMO. Since the passage of the Act, 

the single accountable person for an agency’s telework program is the TMO.15 The TMO is

directly accountable for the success of the agency’s telework program. This decentralized 

approach, including the lack of a tone at the top and middle, was the primary cause for most of 

our findings outlined in the report. During fiscal years 2017 and 2018, the RRB did not have a 

full Board in place to ensure compliance with the applicable telework laws, regulations, and 

policy.

We made eight recommendations to address these internal control weaknesses. The full text of 

management’s response to these recommendations has been included in Appendix I and II.

Some of the RRB’s Internal Controls over its Telework Program Needed

Improvement

Even though the RRB developed a telework policy, implemented a telework program, and 

designated a TMO, the RRB’s control environment, control activities, and telework monitoring 

needed improvement. The RRB did not define the TMO’s roles and responsibilities, identify a 

TMO in its policy, or update its administrative circulars for privacy and telecommuting security. 

The RRB did not always ensure that employees completed telework training before entering 

into a written telework agreement or ensure that employees completed written telework 

agreements before participating. In addition, the RRB did not adequately monitor or evaluate 

its telework program.

 14 Pub. L. 111-292 (2010). 15 Pub. L. 111-292 (2010).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 6

RRB Policy did not Contain Appropriate Telework Managing Officer Information

While the RRB designated a TMO, the RRB did not define the TMO’s roles and responsibilities in 

its WAH policy. The policy did not include a reference to the TMO or to the Director of 

Administration, who was the RRB’s designated TMO during fiscal years 2017 and 2018. The 

importance of clearly defining who was the TMO came to light during our audit. When we 

asked who was the RRB’s TMO, the RRB provided three different names before agreeing that in 

fact it was the Director of Administration.

The heads of each executive agency are required to designate and establish a TMO per section 

6505 of the Telework Act of 2010.

16 According to OPM, each agency telework policy should 

include the responsibilities of the TMO and “[t]he bottom line, however, is that each agency 

will have only one individual, i.e., the TMO, who is the single accountable person according to 

the law for the agency's telework program.”17

RRB policy did not contain appropriate information regarding the agency’s TMO because the 

RRB’s telework program was decentralized and has been managed and overseen by various HR 

employees and not the TMO. According to HR, it runs the day-to-day operation of the RRB’s 

telework program. Additionally, the RRB relied on the Act’s TMO definition in contradiction to 

OPM’s guidance. 

As the single accountable person for the RRB’s telework program under the law, the TMO is 

directly accountable for the success of the agency’s telework program. According to OPM, the 

TMO’s duties extend beyond operational day-to-day aspects of telework and delve more into 

policy, advising, and an overarching management of the entire telework program for their 

agency. When the TMO’s roles and responsibilities are undefined, management has less control 

over the success and operations of the telework program. When the TMO responsibilities are 

not fulfilled, it increases the likelihood of incorrect information being provided to RRB 

employees and being reported to OPM. See the section titled Data Collected and Reported to 

Office of Personnel Management Needed to be Supported for more information.

RRB’s Privacy Administrative Circulars that Support its Telework Program 

Needed to be Updated

The RRB privacy policies as detailed in the RRB Administrative Circulars IRM-2, IRM-15, and 

IRM-16 were outdated. These administrative circulars set forth policies regarding management 

of information privacy for individuals and telecommuting/mobile computing security, and were 

dated September 3, 2008, March 28, 2016, and May 27, 2009, respectively. Therefore, two out 

of the three policies were not updated since the Act was enacted on December 9, 2010.18

 16 Pub. L. 111-292 (2010). 17 The OPM Telework Guide. 18 Pub. L. 111-292 (2010).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 7

According to OMB Memorandum M-11-27, Implementing the Telework Enhancement Act of 

2010: Security Guidelines, the RRB must comply with NIST guidelines.19 NIST Special Publication 

800-53 Revision 4, Security and Privacy Controls for Federal Information Systems and 

Organizations, includes controls regarding governance and privacy programs.20 It requires 

agencies to update their privacy plan, policies, and procedures at least biennially. 

Due to competing priorities at the RRB, management deferred updating the privacy policies and 

procedures. As a result, without a basic foundation of information security, which requires 

updated privacy policies and procedures, an organization’s ability for an effective privacy 

program could be diminished.

In the fiscal year 2013 audit of the RRB’s privacy program, the OIG recommended that the 

Bureau of Information Services revise Administrative Circulars IRM-2 and IRM-15 to reflect 

current privacy documents and procedures.21 This recommendation remained open as of 

February 24, 2020. Therefore, we will not make any additional recommendations regarding RRB 

Administrative Circulars IRM-2 and IRM-15.

RRB’s Internal Controls were not Fully Effective to Ensure that Employee and 

Supervisor Telework Training was Completed Prior to Teleworking

Some RRB employees and supervisors did not complete telework training prior to teleworking 

even though the training was available on the agency’s internal training website, RRB 

University.22 The RRB provided us a training completion report which contained 487 instances 

(466 unique RRB individuals) of the course being completed between September 2016 through 

March 2019.

Using the completion report, we compared it to a list of managers that managed teleworkers 

and a list of teleworkers. Our evaluation identified 31 exceptions where an individual did not 

complete the required telework training. Of the 492 unique individuals that should have taken 

telework training, 26 (5 percent) did not complete it as required. There were 6 managers of 

teleworkers, 15 teleworkers, and 5 teleworkers/managers of teleworkers.

The Act required, “[t]he head of each executive agency shall ensure that ... an interactive 

telework training program is provided to ... employees eligible to participate in the telework 

program of the agency; and ... all managers of teleworkers[.]” Additionally, the Act required the 

head of each agency ensure that an employee has successfully completed telework training 

before the individual entered into a written telework agreement.23

 19 Office of Management and Budget (OMB), Implementing the Telework Enhancement Act of 2010: Security 

Guidelines, OMB Memorandum M-11-27 (Washington, D.C.: July 15, 2011). 20 National Institute of Standards and Technology (NIST) Special Publication 800-53 Revision 4, Security and Privacy 

Controls for Federal Information Systems and Organizations (Gaithersburg, MD: April 2013). 21 RRB Office of Inspector General (OIG), Audit of RRB’s Privacy Program, Report No. 13-11, Recommendation 6 

(Chicago, IL: September 20, 2013).

22 The RRB began using the RRB University telework training on September 28, 2016. According to the RRB, it was 

required for all RRB employees, including employees who had completed a previous version.

23 Pub. L. 111-292 (2010).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 8

In addition to training being required under the Act, the RRB's WAH policy required that both 

the employee and the supervisor must complete training before the employee can start 

teleworking. However, the RRB’s WAH policy did not specify

 who was responsible for ensuring that telework training was completed;

 how the RRB would ensure that telework training was completed prior to an employee 

entering a telework agreement; or

 when a manager must complete telework training. For example, before any of their 

employees enter a telework agreement, or before any of their employees begin 

teleworking.

As we attempted to identify which employees and supervisors had completed the required 

training, we found that the monitoring of this requirement was decentralized to the individual 

bureaus or supervisors and not monitored at an agencywide level. Although the head of the 

agency was charged with the responsibility of ensuring the required training was completed 

prior to teleworking per the Act, we were not provided with any evidence that the information 

was being collected and enforced.24 Additionally, during fiscal years 2017 and 2018, the RRB did 

not have a full Board in place to ensure compliance with the applicable telework laws, 

regulations, and policy. The RRB had no consistent process or knowledge of the tracking of 

telework training requirements across the nine RRB bureaus and offices. Four bureaus believed 

that training monitoring was the responsibility of each individual manager, two said there is no 

training monitoring, two have a specific person assigned to monitor training, and one believed 

the monitoring was the responsibility of HR.

RRB employees who telework or manage teleworkers without receiving required training may 

not understand or be informed of the policy requirements. This may cause noncompliance with 

other policies, such as (1) how to properly secure RRB issued equipment; (2) how to safeguard 

sensitive data or information; (3) what to do if a data breach occurs; (4) knowing when 

telework is or is not allowed; or (5) how to handle injuries, pay issues, facility issues, and 

technical issues. Ultimately, this could lead to lost or stolen equipment or a data breach. An 

untrained manager may allow employees, either knowingly or unknowingly, to disregard RRB 

policies, such as (1) working from an unapproved location; (2) printing out personally 

identifiable information; (3) teleworking while on a performance improvement plan; or 

(4) properly recording time and attendance.

RRB’s Internal Controls to Ensure Proper Execution of Written Agreements were 

not Fully Effective

Some of the RRB’s employees teleworked without properly executed telework agreements

which were required by law and the RRB’s own policy.

25 Seven of the nine RRB bureaus or 

offices evaluated were missing telework documentation or maintained unsigned versions. 

 24 Pub. L. 111-292 (2010). 25 Pub. L. 111-292 (2010).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 9

Table 1 summarizes our review of the RRB’s telework written agreements and supporting

documents.

Table 1. OIG Review of Fiscal Year 2017 and 2018 Telework Written Agreements

RRB Bureaus and Offices Reviewed a

MMO LMO BAR OGC FS OA BFO BIS OP

Of the reviewable agreements, did the bureau 

or office have any unsigned agreements? No No No Yes Yes No Yes Yes Yes

Did the bureau or office have any missing 

telework documents?

a. Telework Agreement Yes No No No No No Yes Yes No

b. Equipment Checklist Yes No No No No Yes Yes No Yes

c. Safety Self-Certification Checklist Yes No No No No No Yes No No

Source: Railroad Retirement Board (RRB) Office of Inspector General (OIG) analysis of RRB telework written agreements for 

fiscal years 2017 through 2018. The Chairman’s office was vacant during the scope of this audit. a Management Member Office (MMO); Labor Member Office (LMO); Bureau of the Actuary and Research (BAR); 

Office of General Counsel (OGC); Bureau of Field Service (FS) -- headquarter employees only; Office of Administration (OA); 

Bureau of Fiscal Operations (BFO); Bureau of Information Services (BIS); and Office of Programs (OP).

The Act stipulated that each agency is to “... require a written agreement that ... is entered into 

between an agency manager and an employee authorized to telework, that outlines the specific 

work arrangement that is agreed to; and ... is mandatory in order for any employee to 

participate in telework....”26 The RRB’s WAH policy supported this requirement and also 

required the supervisor to maintain copies of the signed telework agreements.

To examine the RRB’s compliance over this matter, we contacted HR. They were not able to 

provide assurance that written agreements had been signed appropriately. Further, neither the 

TMO nor HR could provide copies of the written agreements because the process of obtaining 

and maintaining the signed written agreements was delegated to the supervisors of each 

bureau and office. After individually contacting each bureau and office, we determined that 

some of the telework agreements were available. After the exit conference, HR provided an 

update:

The day-to-day functions, such as training, are reserved for Human Resources (and 

specifically, the Telework Coordinator) rather than the TMO. HRLinks now affords us 

the option to capture cursory information in the system on Telework. HR will be 

individually collecting cursory information on telework arrangements within the 

system to include information on telework agreements.

 26 Pub. L. 111-292 (2010).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 10

Since the program lacked fully effective control activities and had an ineffective organizational 

structure, the RRB’s employees were not in compliance with the Act or with the RRB's own 

WAH policy. Additionally, managers may not know which employees were approved for 

telework, or actually teleworking, or what to do if an emergency arises. RRB employees 

teleworking without the proper telework forms completed, signed, and approved by their 

supervisor risk not being covered under the Federal Employees Compensation Act for 

continuation of pay or workers compensation for on-the-job injury or occupational illness. 

Improperly completed Employee Safety Self Certification Checklist could put the employee at 

risk of working in an unsafe environment.27

RRB’s Monitoring of the Performance of its Telework Program Needed

Improvement

The RRB did not adequately monitor its telework program. During our review, we determined 

that monitoring was not performed or the monitoring that was performed needed 

improvement. Specifically, HR did not conduct an appropriate evaluation of the RRB’s telework 

program in accordance with the OPM Telework Guide, RRB WAH policy, or key telework 

practices outlined by GAO. They did not determine the success of the RRB’s telework program 

by assessing evaluation data and administrative data. However, two of the nine RRB bureaus or 

offices conducted an evaluation of the impact of the RRB’s telework program on their 

workgroup. They were the Bureau of Fiscal Operations and the Bureau of Information Systems.

The OPM Telework Guide required that an agency's telework policy include clear and specific 

requirements for an evaluation of the telework program, both for the individual teleworker and 

for the agency in general. This guidance also indicates that the TMO was responsible to help 

with the development of goals and metrics to evaluate the effectiveness of the program. The 

RRB’s WAH policy supports this through the following monitoring and oversight activities:

 As appropriate, the HR will conduct periodic evaluations of the telework program. These 

evaluations will be analyzed to determine the employees’ and supervisors’ perceptions 

and overall impact of the work-at-home arrangement.

 HR will determine the success of the program by assessing the evaluation data and 

administrative data, such as leave usage and attendance records. 

 Bureau and office heads will evaluate the impact of the [Work-At-Home] program on 

their organization(s). 

According to GAO’s Key Practices to Increasing Federal Telework, key practices for 

implementation of a successful federal telework program was through program evaluation. 

Agencies should have established processes, procedures, and/or a tracking system to collect 

data to evaluate the telework program and should identify issues with the telework program 

and make appropriate adjustments.28 The Green Book requires that management document in 

policies the internal control procedures of the organization, and that procedures may include 

 27 RRB Form HR-190b, U.S. Railroad Retirement Board Work At Home Employee Safety Self Certification Checklist 

(Chicago, IL: September 2016). 28 GAO, Human Capital Key Practices to Increasing Federal Telework, GAO-04-950T (Washington, D.C.: July 8, 2004).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 11

the timing of when a control activity occurs. Management should establish and operate 

monitoring activities of the internal control system and evaluate the results through ongoing 

monitoring and separate evaluations. 

Overall, the telework program was not adequately monitored because the roles and 

responsibilities for monitoring, oversight, and evaluation of the telework program were not 

clearly defined in policy and the program was highly decentralized. After inquiring with HR, they 

explained that they did not monitor the program on an agencywide level and that they relied 

on each bureau and supervisor to enforce the RRB telework policy. Therefore, HR was unable to 

determine if program requirements were being met or if teleworkers and managers complied 

with the program. RRB management explained that HR did consider feedback from OPM's 

annual Federal Employee Viewpoint Survey. However, we determined this survey was limited 

as it only had three telework related questions for fiscal year 2017 and two telework related 

questions for fiscal year 2018, and there was no further explanation provided as to how the 

RRB used the results. HR also stated that OPM was expected to assist agencies in developing 

metrics and reviewing agency policies on telework, which they didn't. As of February 2020, HR 

stated, “RRB has already reached out to telework.gov to identify best practices for evaluating 

the telework program.” Further, RRB management explained that each individual manager 

within the RRB has primary oversight of the telework program because direct supervision 

occurs at that level. Therefore, HR elected to not exercise control over whether teleworkers 

and managers complied with telework policies. HR staff stated that they did not believe policing 

the telework program was a function of the HR.

Evaluation of the program is critical to determining the best means of operating a telework 

program. The lack of evaluation of the entire program limited the ability for the RRB and the 

TMO to provide guidance to other RRB bureaus and offices to improve the success of the 

telework program.

Recommendations

We recommend that the Bureau of Human Resources

revise the Railroad Retirement Board's Work-At-Home Program policy to incorporate 

the telework managing officer definition, designation, roles, and responsibilities as 

required in the Telework Enhancement Act of 2010 and the Office of Personnel 

Management’s Guide to Telework in the Federal Government. Once completed, obtain 

the Telework Managing Officer’s written approval of the revised policy prior to issuance 

or publication.

We recommend that the Bureau of Information Services 

update Administrative Circular Information Resources Management (IRM)-16 to ensure 

its accuracy and compliance with the National Institute of Standards and Technology

Special Publication 800-53 Revision 4, Security and Privacy Controls for Federal 

Information Systems and Organizations.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 12

We recommend that the Bureau of Human Resources, in coordination with the Telework 

Managing Officer

develop controls to ensure telework training is completed prior to an employee entering 

a written telework agreement and obtain Board approval of said controls;

develop controls to ensure supervisors complete telework training prior to managing 

teleworkers; 

develop controls to ensure written telework agreements are executed by the employee 

and supervisor prior to teleworking;

perform an initial evaluation of the Railroad Retirement Board’s telework program in 

accordance with the Office of Personnel Management’s Guide to Telework in the Federal 

Government, the Government Accountability Office’s Key Practices to Increasing Federal 

Telework, and the Railroad Retirement Board’s Work-At-Home Program policy; and 

update the Railroad Retirement Board’s Work-At-Home Program policy to include clear 

and specific requirements for evaluation of the telework program, both for the 

individual teleworker and for the Railroad Retirement Board as a whole, including 

frequency, documentation, and reporting requirements.

Management Comments and Our Response

For recommendations one, two, and three, Office of Administration (OA) and Bureau of 

Information Services concurred with our recommendations.

For recommendations one and three, OA provided a target completion date that satisfied the 

prompt resolution rule per OMB. However for recommendation two, Bureau of Information 

Services provided September 30, 2021 as its target date of completion. Bureau of Information 

Services should implement corrective action within one year after issuance of a final report. 

OMB guidance requires, “[m]anagement must make a decision regarding OIG audit 

recommendations within a six-month period after issuance of the audit report and implement 

management's decision within one year to the extent practicable.”29

For recommendations four through seven, OA did not concur with our recommendations. 

For recommendation four, OA explained, “[t]here is no requirement in either the Telework 

Enhancement Act or the Office of Personnel Management’s (OPM) Guide to Telework in the 

Federal Government that requires supervisors to receive training prior to managing 

teleworkers.” We agree that the Act doesn’t specifically state supervisors must have training 

prior to managing teleworkers and for clarity we provided a quote of the Act instead of a 

summarization in section titled RRB’s Internal Controls were not Fully Effective to Ensure that 

Employee and Supervisor Telework Training was Completed Prior to Teleworking. As stated in 

our report, 20 teleworkers failed to complete required training. Additionally, OA failed to 

mention that RRB’s policy required that, “[b]efore the employee starts the Work-At-Home 

 29 OMB, Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, 

OMB Memorandum M-16-17 (Washington, D.C.: July 15, 2016).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 13

program, both the employee and the supervisor must be trained in Work-At-Home policies and 

guidelines.” Even though OA did not concur with recommendation, they stated, “RRB has 

created a separate supervisory/managerial telework training which will be a component of our 

supervisory training for all managers.” Our evaluation of OA’s response and planned correction 

action determined that it partially addressed the identified control weakness outlined in this 

report. OA must work in coordination with the TMO to fully meet the intent of this 

recommendation. Our recommendation remains as written.

For recommendation number five, OA did not concur with our recommendation but 

acknowledged that a written agreement was required prior to teleworking. As described in this 

report’s section titled RRB’s Internal Controls to Ensure Proper Execution of Written Agreements 

were not Fully Effective, we determined that RRB’s employees teleworked without properly 

executed telework agreements. Seven of the nine RRB bureaus or offices did not maintain 

telework documentation or maintained unsigned versions of the agreements. Missing and 

unsigned versions equate to improperly executed telework agreements. OA further stated, 

“[a]s indicated in the survey responses submitted by the OIG, 99% of the respondents indicated 

they completed a telework agreement prior to teleworking.” Out of 386 surveyed, we received 

119 responses. The survey data was provided as informational only, was not statistically valid, 

and did not cover the entire population of approximately 520 teleworkers.30 We agree there 

was an indication a teleworker may be following the Telework Act per the survey. However, our 

evaluation determined that the RRB’s written policy was not effective. The RRB required

supervisor’s to maintain copies of signed telework agreements, which they did not. Proper 

record keeping is vital to keep track of telework in the agency and is a necessary part of an 

effective internal control system. Our findings and recommendations remain as written.

For recommendation numbers six and seven, OA did not concur with our recommendations. In 

OA’s response they state that the Telework Act and OPM rules or regulations did not require an 

evaluation. However, they failed to mention that RRB’s policy required an evaluation of the 

telework program. According to RRB’s Work-At-Home Program policy,

Evaluation of the program is critical to determining the best means of operating an 

alternative work arrangement. As appropriate, the Bureau of Human Resources will 

conduct periodic evaluations of the program. These evaluations will be analyzed to 

determine the employees’ and supervisors’ perceptions overall on the impact of the 

work-at-home arrangement. As a result of these periodic evaluations, the program 

and its terms may be modified from time to time ... The success of the Work-At-Home 

program will be determined by assessing the evaluation data and administrative data, 

such as leave usage and attendance records.

During our audit, there was no evidence that OA’s Bureau of Human Resources conducted an 

appropriate evaluation using telework data, metrics, or quantifiable program goals or 

objectives. Even though OA did not concur with our recommendations, they have started to 

take corrective action to address the findings and recommendation seven. OA stated,

 30 In fiscal year 2018, the RRB self-reported that they offered telework to 572 eligible employees and 

approximately 91 percent of those eligible choose to participate (i.e. approximately 520 total teleworkers).
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 14

RRB has ... revised our policy (draft is as of April 2020) to clarify evaluation efforts for 

telework. Please note, the RRB already reviews the information from the Federal 

Employee Viewpoint Survey (FEVS), and uses the data collection efforts at the end of 

the fiscal year to review the telework program. In addition, effective with the FEVS 

2020 survey, RRB employees will have the opportunity to answer four additional 

questions with respect to RRB’s telework program.

As indicated in the report, the evaluation of the RRB’s telework program was required in 

accordance with the OPM’s Guide to Telework in the Federal Government, the GAO’s Key 

Practices to Increasing Federal Telework, and the RRB’s Work-At-Home Program policy. Our 

findings and recommendations remain as written.

Data Collected and Reported to the Office of Personnel Management

Needed to be Supported

The RRB submitted inaccurate and unsupported telework data to OPM. We reviewed the RRB’s 

annual data submission to OPM and attempted to verify the accuracy of the data submitted for 

fiscal years 2017 and 2018. We were unable to verify the data’s accuracy and completeness

based on the following observations:

 The RRB did not maintain data to support telework time and attendance for a portion of 

fiscal year 2018. Specifically, the Electronic Time and Attendance Management System 

(ETAMS) data from October 1, 2017 through May 25, 2018 was no longer available.

 The count for the number of teleworkers erroneously included Senior Executive Service 

and OIG employees and appeared to double count employees if they were situational 

and routine teleworkers.

 There are no procedures on collecting the data in the WAH policy, including no summary 

of procedures used.31

The Telework Act requires OPM to submit an annual report addressing the telework programs 

of each executive agency. In response to the original congressional mandate, OPM began to 

survey federal agencies about telework in 2000. By means of the annual call for telework data, 

OPM collaborated with federal agencies to collect information about individual agency 

telework programs, including participation rates. OPM worked directly with the agency TMOs 

to discuss the types of data required and methods for data collection as needed.

According to the OPM Telework Guide, an agency's telework policy should include clear and 

specific requirements for record keeping and reporting, both for individual teleworkers and to 

keep track of telework in the agency for reporting purposes each year (i.e., annual report to 

Congress). OPM recommended that the agency describe in policy the system and workflow 

being used to capture participation of the various types of telework and provide specific 

 31 U.S. General Services Administration’s Electronic Time and Attendance Management System (ETAMS) was used 

world-wide by federal agencies to record and certify pay and leave data for federal employees. ETAMS was housed 

on GSA’s FEDdesk which is a virtual desktop available in an Internet/Intranet environment.
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Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 15

instructions to managers and employees that this information must be carefully and 

consistently collected either manually or electronically for reporting purposes. 

Inaccurate and unsupported data were used because the process for the collection and 

reporting of the data was not defined, documented, or validated. According to HR, the RRB was 

in the process of transitioning, updating, and replacing the technology that drove the time and 

attendance system, including the personnel processing systems. During our fieldwork in 2019, 

HR stated that these systems had not been updated in more than 15 years (since 2004) and 

explained there was a loss of the ability to pull complete data from the former time and 

attendance system. Additionally, the RRB management did not stress the importance of the 

OPM reporting requirements for telework program through its control environment. After the 

exit conference, the RRB provided an update and stated that the data collection issue has been 

resolved for the fiscal year 2019. We will assess this action during the follow up process.

As a result of inaccurate data, Congress and the public could not rely on the RRB’s telework 

data. This data was intended to provide readers with an overview of the RRB’s telework 

program and the RRB’s progress in their use of telework.

Recommendation

We recommend that the Bureau of Human Resources in coordination with the Telework 

Managing Officer

develop procedures to be included in the Railroad Retirement Board’s Work-At-Home 

Program policy for collecting data, maintaining records, and reporting accurate telework 

data to the Office of Personnel Management.

Management Comments and Our Response

For recommendation eight, OA partially concurred with our recommendation and stated, “BHR 

agree to include procedures for collecting and reporting data with the [TMO], and/or his/her 

designee. However, these procedures will not be contained in RRB’s telework policy. They will 

be identified as Standard Operating Procedures (SOPs) maintained outside the policy.” OA plans 

to take correction action with a target completion date that satisfied the prompt resolution rule 

per OMB. Our findings and recommendations remain as written.
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APPENDIX I: MANAGEMENT COMMENTS
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

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OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

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OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 19

APPENDIX II: MANAGEMENT COMMENTS
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Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 20

APPENDIX III: INTERNAL CONTROL STANDARDS

Government Accountability Office’s Standards for Internal Control in the Federal Government

(known as the Green Book) sets the standards for an effective internal control system for 

federal agencies.32 The Green Book approaches internal control through a hierarchical structure 

of 5 components and 17 principles. The five components must be effectively designed, 

implemented, operating, and operating together in an integrated manner, for an effective 

internal control system. The five components are (1) control environment, (2) risk assessment, 

(3) control activities, (4) information and communication, and (5) monitoring. 

According to the Green Book, management assigns responsibility and delegates authority to key 

roles throughout the entity. Those in key roles retain ownership for fulfilling overall 

responsibilities, management enforces accountability, and accountability is driven by the tone 

at the top. We applied the Green Book’s components and principles of internal control as it 

applied to the Railroad Retirement Board’s (RRB) task to create, implement, and operate a 

telework program efficiently and effectively, report reliable information about its telework 

program, and comply with internal and external telework criteria, including telework laws and 

regulations.

Our review of internal controls was limited to those necessary to address the objective and 

scope of the audit. Further descriptions of each component and examples of the underlying 

principles as they relate to this audit are:

 Control Environment – The foundation for an internal control system. It provides the 

discipline and structure to help an entity achieve its objectives. For example, tone at the 

top; adherence to standards of conduct; oversight and organizational structure; 

assignment of responsibility and delegation of authority; and enforcement of 

accountability are some of the attributes that contribute to a successful control 

environment;

 Risk Assessment – Assesses the risks facing the entity as it seeks to achieve its 

objectives. This assessment provides the basis for developing appropriate risk 

responses. For example, definitions of objectives; definitions of risk tolerances; 

identification, analysis, and response to risks; and consideration fraud, fraud risk factors, 

and response to fraud risks are some of the attributes that contribute to a successful 

assessment of risks facing the agency; 

 Control Activities – The actions management establishes through policies and 

procedures to achieve objectives and respond to risks in the internal control system, 

which includes the entity’s information system. For example, design of appropriate 

types of control activities; design of control activities at various levels; segregation of 

duties; and design of the entity’s information system are some of the attributes that 

contribute to successful control activities;

 32 GAO-14-704G.
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 Information and Communication – The quality information management and personnel 

communicates and uses to support the internal control system. For example, 

identification of information requirements; relevant data from reliable sources; data 

processed into quality information; communication throughout the entity and with 

external parties; and appropriate methods of communication are some of the attributes 

that contribute to quality information and effective communication; and

 Monitoring – Activities management establishes and operates to assess the quality of 

performance over time and promptly resolve the findings of audits and other reviews. 

For example, establishment of a baseline; evaluation of results; reporting of issues; 

evaluation of issues; and corrective actions are some of the attributes that contribute to 

successful internal control monitoring.
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APPENDIX IV: ROLES AND RESPONSIBILITIES

Office of Personnel Management

The Telework Enhancement Act of 2010 (the Act) requires that the Office of Personnel 

Management (OPM) provide policy, support, guidance, and consultation to each executive 

agency. OPM shall, ‘‘(1) provide policy and policy guidance for telework in the areas of pay and 

leave, agency closure, performance management, official worksite, recruitment and retention, 

and accommodations for employees with disabilities; ... (2) assist each agency in establishing 

appropriate qualitative and quantitative measures and teleworking goals....” Additionally, OPM 

shall, ‘‘(1) maintain a central telework website ... (2) include on that website related ... telework 

links ... announcements ... guidance developed by the [OPM]; and ... guidance submitted by the 

Federal Emergency Management Agency, and the General Services Administration to the 

[OPM]....”33

OPM is also required to submit an annual report addressing the telework programs of each 

executive agency to the Committee on Homeland Security and Governmental Affairs of the 

Senate; the Committee on Oversight and Government Reform of the House of Representatives; 

and transmit a copy of the report to the Comptroller General and the Office of Management 

and Budget.34

National Institute of Standards and Technology

National Institute of Standards and Technology (NIST) is responsible for developing standards 

and guidelines, including minimum requirements, for providing adequate information security 

for all federal agency operations and assets. The Act required, “[t]he Director of the Office of 

Management and Budget, in coordination with the Department of Homeland Security and the 

National Institute of Standards and Technology, shall issue guidelines not later than 180 days 

after the date of the enactment of this chapter to ensure the adequacy of information and 

security protections for information and information systems used while teleworking.”35

Head of Each Executive Agency

As the head of the agency, the Board is responsible to reach the goals of the Telework Act. The 

Act required executive agencies to appoint a leader, with direct access to the head of each 

agency, who would oversee and be accountable for the agency telework program. Specifically, 

the Act required the head of each agency to designate a telework managing officer (TMO)

within “the Office of the Chief Human Capital Officer or other comparable office with similar 

functions.” This placement ideally brings management of telework programs into the circle of 

top leadership and ensures alignment with strategic decision-making.

 33 Pub. L. 111-292 (2010). 34 Pub. L. 111-292 (2010). 35 Pub. L. 111-292 (2010).
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The Act requires that the head of each executive agency shall, ‘‘... establish a policy under which 

eligible employees of the agency may be authorized to telework; ... determine the eligibility for 

all employees of the agency to participate in telework; and ... notify all employees of the agency 

of their eligibility to telework.” Further, the Act required that

[t]he policy described under subsection (a) shall—‘‘(1) ensure that telework does not 

diminish employee performance or agency operations; ‘‘(2) require a written 

agreement that— ‘‘(A) is entered into between an agency manager and an employee 

authorized to telework, that outlines the specific work arrangement that is agreed to; 

and ‘‘(B) is mandatory in order for any employee to participate in telework...‘‘(5) be 

incorporated as part of the continuity of operations plans of the agency in the event 

of an emergency.

In regards to training, the Act required that

[t]he head of each executive agency shall ensure that— ‘‘(1) an interactive telework 

training program is provided to— ‘‘(A) employees eligible to participate in the 

telework program of the agency; and ‘‘(B) all managers of teleworkers; ‘‘(2) except as 

provided under subsection (b), an employee has successfully completed the interactive 

telework training program before that employee enters into a written agreement to 

telework described under section 6502(b)(2); 

Telework Managing Officer

The Act assigned specific duties that reflect the strategic role of the TMO. According to the Act

The Telework Managing Officer shall—‘‘(1) be devoted to policy development and

implementation related to agency telework programs; ‘‘(2) serve as— ‘‘(A) an advisor 

for agency leadership, including the Chief Human Capital Officer; ‘‘(B) a resource for 

managers and employees; and ‘‘(C) a primary agency point of contact for the Office

of Personnel Management on telework matters; and ‘‘(3) perform other duties as the 

applicable delegating authority may assign.

The TMO is also responsible for leading development of goals and metrics to evaluate the 

effectiveness of the telework program and data collection related to reporting requirements.

According to the OPM Telework Guide

The TMO designation is new with the passage of the Act, which requires the TMO to 

be a senior official of the agency, established within the office of the Chief Human 

Capital Officer (CHCO), or its equivalent, and who has direct access to the head of the 

agency. Note that s/he does not need to be the CHCO. The important thing is that the 

position be given direct access to the head of the agency. The TMO is meant to be a 

strategic thinker and planner who will help the agency to incorporate telework in a 

way that makes good business sense ... this person is directly accountable for the 

telework program at each agency.

The OPM Telework Guide provided clarification by explaining that, “[t]he TMO assumes many 

of the duties of what was formerly the Department-level "Telework Coordinator." The role 
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within an agency of pulling together information on telework from various internal sources and 

then reporting to OPM now falls on the TMO.”

Bureau of Human Resources

The Railroad Retirement Board’s (RRB) Bureau of Human Resources (HR) was tasked with the 

day-to-day operations of its telework program. The RRB’s Work-At-Home Program WAH policy 

outlines HR’s responsibilities. Specifically, HR will provide materials and train the participating 

employees and the supervisors, maintain a list of participants, and evaluate the program.

According to the RRB WAH policy

Evaluation of the program is critical to determining the best means of operating an 

alternative work arrangement. As appropriate, the Bureau of Human Resources will 

conduct periodic evaluations of the program. These evaluations will be analyzed to 

determine the employees’ and supervisors’ perceptions overall on the impact of the 

work-at-home arrangement. As a result of these periodic evaluations, the program 

and its terms may be modified from time to time.36

HR coordinates the RRB’s telework program on a day-to-day basis. HR operates the RRB 

telework program as a whole, however, the individual managers do their own oversight within 

each bureau or office, including ensuring that individuals follow the program. Annually, HR 

accumulates information and statistics related to the telework program and sends it to OPM for 

inclusion in OPM’s Annual Report to Congress.

Bureau of Information Services

The RRB’s WAH policy outlined Bureau of Information Service’s responsibilities. Specifically, 

Bureau of Information Service will provide work at home privacy and security training to 

participating employees and their supervisors, maintain a tracking system for RRB issued 

equipment, and provide service and maintenance for RRB issued equipment.

 36 RRB, Work-At-Home Program (Chicago, IL: August 2016).
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APPENDIX V: TELEWORK SURVEY

In April 2019, we conducted an anonymous survey of Railroad Retirement Board (RRB)

teleworkers and managers to obtain their views and understanding of the RRB’s telework 

program and policies.

37 Out of 81 surveys sent to RRB managers, we received 12 responses. 

Due to the low number of responses, we did not provide the graphics or results from those

responses. Out of approximately 386 RRB teleworkers surveyed, we received 119 responses to

the survey. The answers to our survey have been provided in Figures 1 through 17. We also 

summarized the additional comments provided at the end of this Appendix.

Figure 1. Question 1 Survey Responses

Source: RRB Office of Inspector General (OIG) analysis of survey response. There were 119 answers by 119 individuals.

Figure 2. Question 2 Survey Responses

Source: RRB OIG analysis of survey response. There were 121 answers by 119 individuals, some people provided more than one 

answer to this question.

 37 Surveys were sent to RRB teleworkers and RRB managers who supervised employees that teleworked during 

fiscal years 2017 and 2018.

99%

1%

0% 0%

Have you read and understood the RRB policies and procedures?

Yes, I read and understood (118).

No, I read, but did not understand (1).

No, I did not read (0).

Other (0).

31

79

6 5

Count of Answers

How often, on average, have you teleworked?

1 day per week.

2 days per week.

3 or more days per week.

Emergency or as needed.
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Figure 3. Question 3 Survey Responses

Source: RRB OIG analysis of survey response to question three. There were 428 answers by 119 individuals. Some individuals 

stated that other factors were (1) lower transportation costs, (2) works well with my exercise schedule, (3) weather, (4) better 

monitor, (5) ineffective cubicle, (6) health, and (7) less stressful.

Figure 4. Question 4 Survey Responses

Source: RRB OIG analysis of survey response. There were 120 answers by 119 individuals, some people provided more than one 

answer to this question.

96

65

95

83

65

24

Count of Answers

What were the factors in your decision to telework? (Choose all that apply.)

The amount of time it took to

commute.

The distance (number of miles) of my

commute.

I had fewer interruptions at home.

I could be more productive at home.

I could better balance career and

family obligations.

Other.

92

2

15

8

3

Count of Answers

Did your supervisor promote telework and/or provide telework guidance?

Yes, they promoted and provided

guidance.

No, they promoted, but did not

provide guidance.

No, they did not promote, but

provided guidance.

No, they did neither.

Other.
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Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 27

Figure 5. Question 5 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals.

Figure 6. Question 6 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals. Some individuals stated that (1) it 

depends on your position description and role, (2) there is a discrepancy between how policy was applied even within 

departments, (3) they are fair in one department, but not all departments, (4) Yes and no, it should be earned not granted, 

(5) the RRB telework policies are not as equal as other federal agencies – at another agency, I teleworked 5 days a week.

Yes 92%

No 8%

Did the RRB communicate your eligibility to telework to you?

Yes 82%

No 6%

Other 13%

Do you believe eligibility requirements for telework are fair?
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Figure 7. Question 7 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals.

Figure 8. Question 8 Survey Responses

Source: RRB OIG analysis of survey response. There were 122 answers by 119 individuals, some people provided more than one 

answer to this question.

Yes (99%)

No (0%)

I don't know (1%)

Before you started teleworking, did you sign the RRB's Telework Agreement 

and Checklists?

0% 5% 10% 15% 20% 25% 30% 35%

No communication occurred.

Once.

Twice.

Three times or more.

Other.

During a typical telework day, how often did your supervisor communicate 

with you?

Percent of total number of answers (e.g. 50% answered yes)
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 29

Figure 9. Question 9 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals. Some individuals stated that they 

teleworked (1) in DC for conference and had RRB business, (2) at my significant other’s home, who also participates in the 

program, (3) various places and may not have updated my agreement, sometimes I lived in my car, (4) from my elderly 

mother’s home, and (5) somewhere else, occasionally when WAH location Wifi was unavailable.

Figure 10. Question 10 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals.

Yes 7%

No 93%

Other than approved travel, did you work at a telework location other than 

what was specified on your telework agreement?

78%

2%

20%

When you submitted a telework request, did your supervisor respond with a 

written decision within ten working days?

Yes.

No.

I do not know.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 30

Figure 11. Question 11 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals.

Figure 12. Question 12 Survey Responses

Source: RRB OIG analysis of survey response. There were 122 answers by 119 individuals, some people provided more than one 

answer to this question.

83%

7%

10%

Did you complete telework training before signing a RRB Work-at-Home 

Agreement?

Yes.

No.

I do not know.

92%

5%

0%

3%

Were you required to send an email at the beginning of each workday 

stating your starting work time, and at the end of each workday stating your 

ending work time?

Yes.

No.

I do not know.

Other.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 31

Figure 13. Question 13 Survey Responses

Source: RRB OIG analysis of survey response. There were 196 answers by 119 individuals. Some individuals stated that they 

report there telework time through (1) email, (2) SharePoint time management system, and (3) Bureau of Information Service

time reporting system.

Figure 14. Question 14 Survey Responses

Source: RRB OIG analysis of survey response. There were 119 answers by 119 individuals. Some individuals stated that the 

technical issues experience were related to (1) slow connection, (2) VPN issues, (3) stuck in work-desk sessions, (4) logging in, 

(5) local internet service, (6) slow speeds related to work desk and mainframe, (7) Wifi issues, and (8) PIV errors.

54%

27%

19%

How did you report your teleworking time?

HRLinks.

Manual timesheet.

Other.

0% 10% 20% 30% 40% 50% 60% 70% 80%

Yes, every time I teleworked.

Yes, sometimes when I teleworked.

No.

Did you ever experience any technical difficulties while teleworking?

Percent of total number of answers (e.g. 50% answered yes)
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 32

Figure 15. Question 15 Survey Responses

Source: RRB OIG analysis of survey response. There were 120 answers by 119 individuals, some people provided more than one 

answer to this question.

Figure 16. Question 16 Survey Responses

Source: RRB OIG analysis of survey response. There were 121 answers by 119 individuals. Some individuals stated that (1) they 

were not sure what those specific policies were, (2) if they were covered in training yes, but I don’t have time to read them, and 

(3) I don’t deal with sensitive materials.

99%

0%

1%

0%

While teleworking, did you use a personal identity verification (PIV) 

credential and RRB issued equipment (such as a laptop)?

Yes, I used both (119).

No, I used a PIV, but not RRB issued

equipment (0).

No, I used RRB issued equipment,

but not a PIV (1).

No, I used neither (0).

88%

0%

11%

Was your access and use of sensitive materials consistent with RRB security 

policies such as IRM-2, IRM-15, and IRM-16?

Yes.

No.

I do not know.
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 33

Figure 17. Question 17 Survey Responses

Source: RRB OIG analysis of survey response. There were 120 answers by 119 individuals, some people provided more than one 

answer to this question.

Additional Comments Provided by RRB Teleworkers

At the end of the survey, we asked the teleworkers, “Do you have any additional comments?” 

After a review of the comments, we summarized them in the following list. In general, they 

expressed that

 they were much productive at home and produced a better work product;

 there has been an improvement to the RRB’s telework program over the years and it 

has become a great and wonderful program;

 the availability of the program has led to a greater work/life balance and saving a 

significant amount of money on lunches, parking, and train costs;

 the program has benefited their health because it is less stressful, therefore they used 

less leave; 

 being able to telework saved them when they got sick;

 they would like to work at home more often and the program should be expanded to 

include newer people;

 the rules were not clear or provided fairly across each bureau and office;

 some people abuse the program and appear not to do any work at home while 

teleworking;

0% 20% 40% 60% 80% 100%

I printed documents or files that contained

PII while at home (2).

I brought sensitive information home with

supervisor approval (2).

I brought sensitive information home

without supervisor approval (0).

My RRB issued equipment was lost, stolen,

or compromised (1).

I connected personal devices to RRB issued

equipment (i.e. printer) (2).

I connected to RRB network without

utilizing VPN connection (1).

None of the above (111).

No Response provided (1).

Did any of the the following occur while teleworking? (Choose all that apply.)

Percent of total number of answers (e.g. 50% answered yes)
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

Railroad Retirement Board’s Telework Program Needs Improvement - Report No. 20-05 34

 transporting a laptop back and forth is challenging; and

 capabilities while teleworking need to be improved and added, the RRB has slow 

systems and we should be able to print documents at home.