Appendix C

Request for Leave or Approved Absence

1. Name (Last, first, middle) a

3. Organization

4. Type of Leave/Absence 5, __ Family and Medical Leave

lags rs a Bets Time Total Hours| if annual leave, sick leave, or leave without

im From Jo From To pay will be used under the Family and
pconied sna leave Medical Leave Act of 1993 (FMLA), please
Restored annual leave Z provide the following information:

Advance annual leave
[_] Accrued sick leave
[—] Advance sick leave

I hereby invoke my entitlement
‘im to family and medical leave for:

[_JBirthadoption/Foster care
Purpose: [| tinessinuryincapactaton of equesing employee \Serious health condition of

F) ecicaldentzoptcal examination ct e Ispouse, son, daughter, or parent
Care of family member, including medical exarrinaion of family member, or i i
1D Gate a family luding identaVoptical ily [D)serious health condition of self

[5 care of family member with a serious heath condition

[otter Contact your supervisor and/or your
personnel office to obtain additional
information about your entitlements and

[J Compensatory time off responsibilities under the FMLA. Medical

7 Other paid absence certification of a serious health cancition
cpa may be required by your agency.

iL] (specify in remarks)

[L Leave without pay

6. Remarks

7. Certification: | certify that the leave/absence requested above is for the purpose(s) indicated. | understand that | must comply with my
employing agency's procedures for requesting leave/approved absence (and provide additional documentation, including medical
certification, if required) and that falsification of information on this form may be grounds for disciplinary action, including removal.

7a. Employee signature 7b. Date signed

8a. Official action on request is in

Ty Avwroves disapproves frets anton o schedule)
8b. Reason for disapproval
8c. Signature 8d. Date signed

Privacy Act Statement
Section 6311 of title 5, United States Code, authorizes collection of this information. The primary use of this information is by
management and your payroll office to approve and record your use of leave. Additional disclosures of the information may be: To the
Department of Labor when processing a claim for compensation regarding a job connected injury or illness; to a State unemployment
compensation office regarding a claim; to Federal Life Insurance or Health Benefits carriers regarding a claim; to a Federal, State, or
local law enforcement agency when your agency becomes aware of a violation or possible violation of civil or criminal law; to a Federal
agency when conducting an investigation for employment or security reasons; to the Office of Personnel Management or the General
Accounting Office when the information is required for evaluation of leave administration: or the General Services Administration in
connection with its responsibilities for records management.

Public Law 104-134 (April 26, 1996) requires that any person doing business with the Federal Government furnish a social security
number or tax identification number. This is an amendment to title 31, Section 7701. Furnishing the social security number, as well as
other data, is voluntary, but failure to do so may delay or prevent action on the application. If your agency uses the information furnished
on this form for purposes other than those indicated above, it may provide you with an additional statement reflecting those purposes.

Grex Bonar nanan Local Reproduction Authorized hee 201
Fomarty Strand For (SFI


The GAO Standards for Internal Controls states transactions should be promptly
recorded to maintain their relevance and value to management in controlling operations and
making decisions. The CO 64, also states that timekeepers will keep accurate records and
supervisors will carefully monitor the use of advance annual leave. With incorrect leave
balances, employees may be using leave that they are not entitled to.

Recommendation 8. We recommend the timekeeper maintain the Annual Attendance Record for
CY 2008 and future years to reflect reconciliation based on leave slips,
emails, FMC-109 and STAR reports, to ascertain the correct leave balances
for its employees.

Recommendation 9. We recommend the timekeeper provide an updated FMC-183 to OFM for
corrections in NFC and STAR before the end of FY 2009 for CY 2008.

11


The bureau director designates the timekeepers and alternates on FMC-81, Designation of
Authorized Representative (See Appendix D). The alternate timekeeper is responsible for
entering time and attendance information when the primary timekeeper is not available. To
ensure that no individual enters his/her own T&A information into STAR the alternate
timekeeper also enters the primary timekeeper’s T&A bi-weekly.

In calendar year (CY) 2008, BTA had four timekeepers; one for the BTA front office and
one for the offices of Agreements (AGR); Service Contracts & Tariffs (SCT) and Economics &
Competition Analysis (ECA). The timekeeper relies on the information provided by the
employee (i.e. the hours worked/leave used) for STAR system input. The timekeeper also relies
upon leave slips for those employees on a “regular,” eight-hour work schedule, as the employee
is not required to maintain a FMC-109. Once the employee’s hours worked/leave used are
entered into STAR, a report is printed for each employee for that pay period. The timekeeper,
employee and the supervisor must certify to the STAR report accuracy and that leave used was in
keeping with federal laws and regulations. It is, therefore, critical that the reports are accurate
and supported by detailed records.

Timekeepers are required by the OFM SOP to maintain employee leave on FMC-183,
Annual Attendance Record, for each pay period (See Appendix E). Timekeepers are required to
enter annual/sick leave hours used by each employee for each day of the pay period. The
electronic version of the form automatically calculates the leave balances based on carryover
balances at the beginning of the year, the hours an employee accrues each pay period and the
number of hours of leave used (when applicable). OFM provides the timekeeper with this form
at the beginning of the leave year. Three of the four BTA timekeepers maintained the FMC-183
for their staff.

Objectives, Scope and Methodology

According to the Government Accountability Office (GAO), the primary objectives of
internal control in a T&A system are to ensure that the system complies with applicable legal
requirements, supports reporting of reliable financial information and operates effectively and
efficiently.

The objective of this review was to assess whether BTA complied with agency policies
and government regulations concerning employee time and attendance. At the time of our audit,
BTA had a staff of 19, including the four timekeepers. We selected two employees and the
primary timekeeper from each office for detailed review of their respective leave slips, STAR
reports, work schedule requests, employee arrival/departure sheets and annual attendance record.
The review scope included all pay periods in CY 2008.

We began the review by gaining an understanding of T&A practices used in BTA and
compared these practices with OPM and FMC timekeeping policies and procedures. For each
employee in our sample we reviewed STAR reports and reconciled leave taken with leave
request forms, and verified that each STAR report contained required certifications (timekeeper,


Appendix D

FEDERAL MARITIME COMMISSION

DESIGNATION OF AUTHORIZED REPRESENTATIVE

INSTRUCTIONS: A new form must be completed and forwarded to the Office of
Financial Management whenever the designee or alternate changes.

NAME OF DESIGNEE (Print above, last name first Me SISUATURS OF Dasionee

NAME OF ALTERNATE (Print last name first) "3 SIGNATURE OF ALTERNATE

ORGANIZATIONAL AREA OF RESPONSIBILITY

DESIGNEE (or Alternate) IS AUTHORIZED TO ADMINISTRATIVE LIMITATIONS

This cancels previously issued FMC-81
OQ 4, CERTIFY/APPROVE TIME AND ATTENDANCE CARDS

a 2. ACT IN THE CAPACITY OF TIME AND ATTENDANCE
CLERK.

a 3. REQUEST/APPROVE TRAVEL AUTHORIZATIONS,
TRAVEL VOUCHERS AND LOCAL TRAVEL
REIMBURSEMENTS.

o 4. OTHER (SPECIFY)

SIGNATURE AND TITLE OF OFFICIAL AUTHORIZED TO DESIGNATE REPRESENTATIVE DATE

Signature =

Title

Form FMC-81
(Rev. 11/06)


Appendix A

FEDERAL MARITIME COMMISSION
EMPLOYEE REQUEST FOR WORK/TELEWORK SCHEDULE

To:
‘a I request a regular work schedule.
Cc I request that the following flexible hours be established for
me.
Arrival time
Departure time :
fe I request that the following compressed work AND/OR telework

schedule be approved for me. Please indicate 8-hour day, day
off, or telework day, as appropriate. If requesting episodic
teleworking, designate work hours and check the episodic
teleworking line.

First week of pay period.

Monday : a.m. to p.m.
Tuesday a.m. to —_——P.-n.
Wednesday a.m. to SSS as
Thursday a.m. to ———P-m.
Friday a.m. to SSS pss

I~ Episodic teleworking
Second week of pay period.

Monday : a.m. to p.m
Tuesday ‘a.m. to ——F -n.
Wednesday a.m. to —————_T Pm:
Thursday a.m. to —s
Priday a.m. to —_———P-n.

Employee's Signature Date
SUPERVISORY RECOMMENDATION
[" Approve
[— Approve as modified
[~ Disapprove (justification attached)
Supervisor's Signature Date
[- Approved [— Approved as modified [V Disapproved
Bureau or office director's signature Date
ec: Employee
Timekeeper
FMC-110

(Rev. 12/2001)


We identified mixed compliance with the CO 92 among employees working an AWS and
those working eight hours per day. Nine (9) of the 12 sampled employees worked AWS. Six (6)
of these nine employees did not complete the FMC-109 for all pay periods. For example, for the
26 pay periods we reviewed, the frequency with which we observed use of the form for the 6
employees ranged from zero to 24 occurrences.

During our fieldwork, we noted that one timekeeper prepared the Form-109 with each
employee’s scheduled time included on the form. This method saves staff time as only
deviations from staff's schedule, to include leave used must be noted on the form. On the other
hand, we noted that no changes were made to forms we examined to capture small increments (5
— 15 minute deviations), leading us to conclude that employees may not be recording their actual
arrival/departure times when this format is used.

Finally, we noted that one of the nine employees that worked AWS did not record hours
worked in pay periods nine (9) and 16. We learned that the hours worked were omitted in error,
i.e., no leave was used by the employee.

TINO Requests

The Time Inquiry-Leave Update System (TINQ) is an online entry and inquiry system
that allows users to query and/or correct leave data from remote locations. The OIG reviewed all
leave slips and transactions reported in the STAR for the 12 sampled employees to determine
whether the correct annual/sick leave transactions were entered into STAR. When timekeeper
errors are identified in STAR after the timecards are transmitted, corrections to the system (i.e.,
TINQ’s) must be performed by OFM staff.

BTA timekeepers generally entered the correct leave category in STAR. However, we
identified one instance (pay period 24) where 10 hours of annual leave were erroneously entered
in STAR in place of sick leave. Rather than correcting the error through a prior pay period
adjustment, the timekeeper simply made the adjustment in pay period 26 when the employee
used annual leave (the timekeeper entered 10 hours of sick leave in STAR in place of the annual
leave used). It is important to note the employee had the required leave balances to
accommodate this transaction.

Although administratively simpler, errors that occur using this method would be difficult
to find and correct. We suggest using prior pay period adjustments to make corrections.

The T&A SOP states that when a correction is needed to an employee’s leave balance the
timekeeper shall initiate a TINQ request to OFM’s T&A administrators, through e-mail, with
notification to the employee whose record is being changed and to his/her supervisor. We found
the timekeeper did not follow this procedure stated in the T&A SOP.

Recommendation 4.__ We recommend the timekeepers familiarize themselves with the T&A SOP
and follow the stated instructions when applicable.


annual leave. This employee accumulated 50 hours and used 44 hours without proper
documentation.

These and other findings, along with recommendations to address the noted deficiencies,
are provided below.

Finding 1. Leave Documentation Requirements were not Routinely Followed

According to GAO’s T&A guidance, Maintaining Effective Control over Employee Time
and Attendance Reporting, leave approval should be made by the employee’s supervisor before
the leave is taken. If leave is not approved in advance, because of an unusual or emergency
situation, it should be reviewed for approval or disapproved as soon as reasonably possible after
it is taken.

Commission Order 64, Employee Absence and Leave, requires employees to request
annual and sick leave, compensatory time off, leave without pay, family and medical leave, and
other paid absences, on OPM Form 71, Request for Leave or Approved Absence. These requests
are initiated by the employee and approved (or disapproved) by the employee’s supervisor and,
except in extenuating circumstances, are to be submitted in advance of leave used. The form is
given to the timekeeper (i) to validate that leave taken in a given pay period was approved and
(ii) to identify the number of leave hours used in the pay period for entry into STAR.

We reviewed leave request forms for the 12 employees in our sample for each pay period
in 2008 (26 pay periods). Specifically, we reviewed whether leave was requested in advance
using required leave request forms and reconciled to the STAR reports, and whether leave
requests unnecessarily contained Personally Identifiable Information (PII), e.g., social security
numbers (SSN).

Leave Slips were not routinely used to Request Leave in Accordance with OPM and
FMC Regulations

The BTA management requires staff to request all leave on OPM Form 71 and we found
this policy is generally followed, although there is room for improvement. When we identified
exceptions, BTA staff that used the FMC-109, Employee Arrival and Departure Record, noted
the leave hours on that form.

The OIG identified 22 instances, totaling 255 hours of leave charged by five (5) of the 12
sample staff, where no approved leave slip was provided for leave used. We relied upon the
FMC-109 to reconcile leave taken with leave entered in STAR. The following table illustrates
the number of hours of leave used during the year without a valid leave request form:


employee and supervisor). We reviewed employee requests for leave to determine whether leave
was requested and approved in advance of the leave taken. We also tied leave requests back to
the STAR system to verify that leave requested matched leave recorded and inspected each form
for Personally Identifiable Information (PII). We reviewed forms FMC-109 and FMC-110 to
determine whether they were completed accurately and, when applicable, evidenced supervisory
approval. Finally, we reviewed the FMC-183 for accuracy and reconciliation with STAR for the
last pay period in the year.”

We conducted the audit in January through June 2009, in accordance with generally
accepted government auditing standards. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on these objectives.

Audit Findings and Recommendations

BTA has generally implemented controls over T&A processing. The OIG did not
identify payroll abuse and managers and timekeepers, for the most part, seemed cognizant of
controls over payroll processing. We found staff was protective of PII on payroll-related
documents. All timekeepers have received required training on the STAR payroll system.

On the other hand, we identified practices in BTA that, while not material, are not
compliant with agency payroll policies and procedures. Still, noncompliance in some areas
could, if not addressed, eventually lead to findings of waste or abuse. Findings of
noncompliance involved leave request and certification requirements, and selected other work
schedule documentation requirements. For example, employees did not routinely prepare the
OPM Form 71, Request for Leave or Approved Absence, when requesting/accounting for leave
used. In total, we identified 255 hours of leave used without a leave slip (or e-mail) by five
sampled employees. We noted that these employees accounted for the leave used on FMC-109,
Employee Arrival and Departure Record, but the FMC-109 is not provided to the supervisor
either in advance of the leave taken or for supervisory approval.

The T&A files did not contain the required documentation to identify work schedules for
three of the 12 employees we reviewed. A third of the employees sampled worked an alternative
work schedule and, although required, did not routinely record their arrival and departure times.
For one employee, the FMC-109 was prepared in advance by the timekeeper with the
employee’s approved work schedule. Deviations from the approved schedule were not noted on
the form. The employee certified the FMC-109 as correct bi-weekly.

We also identified one employee who worked an alternate work schedule (AWS), worked
on scheduled days off, but did not request approval to earn “comp time” or to use it in lieu of

? Because the OIG relied on timekeepers to supply much of the documentation we audited, we requested
the BTA staff certify, in writing, that the records were not modified (created, deleted or altered) from the date of our
request. The Director, primary and alternate timekeepers signed the certification.

3


Appendix B

FEDERAL MARITIME COMMISSION

Employee Arrival and Departure Record

Name

Pay Period Beginning Ending,

ARRIVAL DEPARTURE LEAVE (hours)
DAY TIME TIME ANNUAL SICK

MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY

MONDAY
TUESDAY
WEDNESDAY
THURSDAY
FRIDAY

[hereby certify the accurateness of this
information.

Employee Signature Date

FMC-109
(3/92)


In September 2006, the agency issued guidance to staff regarding the use of PII. The
guidance stated, in part, that the SSN was no longer required on leave slips and other agency-
used forms. Further, the agency disabled the SSN field on the electronic leave request form.
None of the 12 employees used their SSN on any of the leave slips that were provided. We
commend the BTA staff for protecting PII.

Finding 2. Adherence to Agency Policies

The Commission establishes policies and procedures for staff (employees, timekeepers
and supervisors) to follow to ensure compliance with government-wide regulations. Review of
timekeeping practices used by the employees in our sample revealed inconsistent compliance

with agency guidelines in the following areas.

Employee Request for Work/Telework Schedule

According to CO 92, Work Schedules, employees are responsible for completing
FMC-110, Employee Request for Work/Telework Schedule and submitting it to their
Supervisor/Director (if applicable) for approval. This enables supervisors to better manage
employees around office needs and to monitor employee arrivals and departures. Supervisors are
responsible for providing each employee with a copy of the approved or disapproved form
FMC-110. The FMC-110 is available on the agency’s intranet.

We found three of nine sampled employees that worked AWS did not have a FMC-110
on file with the supervisor’s approval. Another three employees that worked an AWS did not
have an updated FMC-110 in the file to reflect the new form and/or the current supervisor.

To comply with the agency’s policies we make the following recommendation.
Recommendation 3. | We recommend that all BTA staff complete FMC-110 to reflect their

current work hours and obtain approval by the supervisor and/or the
Director.

Employee Arrival and Departure Record

Commission Order 92 requires employees on AWS to submit a written record of arrival
and departure times on FMC-109, Employee Arrival and Departure Record, at the end of each
pay period. The form is to be certified by the employee before it is submitted to the timekeeper.
Employees working a “regular” work schedule (eight hours per day) are encouraged by the
Office of Financial Management to use the form to document hours worked and leave used.
When signed by the employee, it provides an audit trail which can be used to validate the
accuracy of the T&A.


Office of Inspector General

Review of the
Bureau of Trade Analysis
Time and Attendance Practices
A09-06

July 2009

FEDERAL MARITIME COMMISSION



According to GAO’s Standards for Internal Control in the Federal Government, key
duties and responsibilities should be divided or segregated among different people to reduce the
risk of error or fraud. Further, the agency’s T&A procedures state that alternate T&A clerks are
responsible for entering the primary time clerk’s T&A into STAR. We verified from the
FMC-81 that BTA assigned alternate timekeepers for each primary timekeeper to perform duties
in the primary timekeeper’s absence and to enter the primary timekeeper’s T&A into the STAR
system. In BTA the front office primary timekeeper is responsible for entering the remaining
three timekeeper’s T&A into STAR. Her alternate is a timekeeper in the Office of Service
Contracts & Tariffs.

For pay periods two (2) and 11, we noted that the front office timekeeper did not certify
the SCT timekeeper’s timecard. Due to the absence of the primary timekeeper, she relied on (i)
OFM and (ii) another BTA timekeeper to certify her T&A input. In the first instance, the
timekeeper followed the OFM’s process to have her card certified by OFM. Staff in OFM have
access to all payroll records and can input pay-related information. In the second instance, the
timekeeper entered her own T&A information, but requested that another timekeeper certify the
card. This certification signifies that the second timekeeper entered the information. However,
she could not enter it because she does not have the required access. We note that this was not a
routine occurrence and was done only to facilitate processing of the individual’s timecard.

The larger issue here is the absence of internal control in the STAR system that allows
timekeepers to access their own T&A information. This is a serious internal control
vulnerability because timekeepers can make adjustments to, for example, their own leave
balances with little fear of detection. To correct this deficiency the agency will need to eliminate
the timekeepers’ access to their records in STAR.

Since this condition is present in all bureaus/offices, the change will have to be addressed
by the Office of Administration (OA). The OIG made the recommendation to OA, to deny
access to timekeepers to their own payroll files, in a companion report on T&A administration in
another FMC office.

Recommendation 6. | We recommend BTA inform the timekeepers to request OFM staff to enter
their T&A in STAR when the alternate timekeeper is not available.

Finding 5. Certification of STAR

The STAR report is generated by the timekeeper after T&A information has been entered
into the STAR system. The STAR report is printed and must be certified for accuracy by the
timekeeper, employee and the supervisor. The T&A SOP states that when an employee is not
available to certify the STAR, a notation explaining the employee’s absence shall be made.

We found timekeepers; employees and supervisors did not always certify all STAR
reports as required. For example, primary timekeepers failed to certify the STAR on five

> Review of Office of the General Counsel's Time and Attendance Practices (A09-03), dated July 7, 2009.

9


Finding 3. Compensatory Time was Improperly Recorded and Used

Commission employees are eligible to earn compensatory time by following the program
regulations. Requests for compensatory time off must be approved in advance to allow
supervisors time to adjust workload and assignments as necessary, and the “comp” hours
identified that will compensate for requested time off. Requests for compensatory time off are
submitted to the supervisor for authorization on OPM Form 71, Request for Leave or Approved
Absence. The timekeeper will record compensatory time earned and taken on the time and
attendance record.

The accumulated balance of unused compensatory time earned must not exceed 40 hours,
and such leave should be used as soon as administratively practical. No charge may be made to
annual leave until the compensatory balance has been exhausted, and in no event may a
compensatory leave balance be carried forward to a new leave year. An employee who fails to
take compensatory time off to which he or she is entitled shall lose the right both to
compensatory time off and to overtime pay, unless the failure is due to an exigency of the service
beyond the employee’s control.

The current CO 92, Work Schedules, states that work in excess of 80 hours for the pay
period will be treated as paid overtime or compensatory time. When an employee requests
overtime or compensatory time, form FMC-70, Request, Authorization, and Report of
Overtime/Compensatory Time, must be filled out and approved by the bureaw/office Director,
Deputy Director, Office of Administration and the Director, OFM.

The OIG identified one BTA employee who was “informally” administering a
compensatory time benefit without completing the agency’s-required processes for requests or
usage. The employee worked on scheduled AWS days off, and then used the hours as “comp”
time. The OIG found no indication that the employee was abusing the hours banked. On the
other hand, the employee did not complete any required documentation to earn the hours (FMC-
70) nor did the employee request approval to use the hours. However, the employee recorded
hours worked on scheduled AWS days off on FMC-109. The employee worked scheduled AWS
days off in pay periods 5, 6, 7, 11, and 13 which resulted in 50 hours of banked leave. The
employee used the “comp” time in pay periods 7, 11 and 12 using 17, 20 and 7 hours
respectively, for a total of 44 hours.

Recommendation 5. We recommend that BTA management adhere to the agency’s policy
regarding use of compensatory time for its staff.

Finding 4. STAR Certification by Non-Designated Alternate Timekeepers

Bureau/Office heads submit form FMC-81, Designation of Authorized Representative, to
the Office of Human Resources through the Office of Financial Management to identify the
payroll certifier and the primary and alternate timekeepers. Timekeepers are assigned user codes
and passwords to access the system. In BTA, there are four timekeepers responsible for entering
time and attendance information for their respective offices within BTA.


Table 1. Employee Leave without OPM Form 71

The OIG identified 23 leave events, totaling 255 hours of
leave, where no approved leave slip was provided for leave

ue J ie used. We observed that 81 percent of the leave hours without
Staff 2 19 a leave slip were associated with two timekeepers. Three of

he ‘ a4 the 4 timekeepers told us that when leave slips are provided to
Total 23 255 the supervisor and approved, they are generally returned to the

timekeeper for reconciliation with the FMC-109, when
available. This is a strong control over leave abuse because it prevents employees from altering
or withholding the leave slip from the timekeeper with the intent of not recording leave used. A
few hours of leave taken at the beginning of a pay period could easily be overlooked by a
supervisor when certifying several STAR reports.

Recommendation 1. We recommend the supervisors provide the approved leave slips directly
to the timekeeper for reconciliation for all BTA staff.

Use of Updated OPM Form 71

We reviewed completed leave slips (when available) to determine whether employees
used the revised OPM Form 7] and to identify PII.

The Standard Form 71 was provided to federal employees through OPM in December
1997 until OPM re-issued an updated OPM Form 71 in June 2001. The revised OPM Form 71
requires an employee who requests sick leave to indicate the purpose for the leave, to include
(i) illness/injury/incapacitation of requesting employee and (ii) care of family member with a
serious health condition. The CO 64 requires an employee who invokes his/her right to Family
and Medical Leave to provide medical certification. These requirements provide the employee’s
supervisor with additional information relating to the use of sick leave. FMC requires that all
leave request be made on the revised OPM Form 71.

Two (2) of the 12 BTA employees we reviewed always used the discontinued version of
the form (25 requests) even though the updated form is provided to FMC employees on the
intranet and as an appendix in the SOP for timekeepers. The two employees were timekeepers.
We commend the remaining 10 employees for using the current OPM Form 71.

Recommendation 2. We recommend all staff use the updated OPM Form 71 for leave
requests.

Social Security Numbers on Leave Slips

The SSN is a unique identifier issued to U.S. citizens, and to permanent and temporary
residents. However, with increased awareness of identity theft and the need to protect PII, the
collection of SSNs for routine uses has been significantly curtailed. PII is any information about
an individual which can potentially be used to uniquely identify, contact or locate that individual.

5


Appendix E

ANNUAL LEAVE RECORD - 2009

A - Annual

S - Sick

H - Holiday

Daily Record of Leave Used During Each Pay Period
Example: If you are sick 4 hrs. enter S-4 under the appropriate day.
If you take a day of annual leave, enter A-8 for that day.

Note: Annual leave
earned each pay
period depends on
your length of service

Annual
Leave

Sick
Leave

Carry Over

Carry Over

Carry Over

Earned|Used| Balance|

Earned] Used] Balance]

Earned] Used] Balance

Pay Period

Jan 4 - Jan 17

Jan 18 - Jan 31

Feb 1 - Feb 14

SUN |MON|TUE [WED|THU [FRI [SAT [SUN |MON]TUE [WED|THU [FRI [SAT

Feb 15 - Feb 28

Mar 15 - Mar 28

Mar 29 - Apr 14

Apr 12 - Apr 25

1
2
3]
4
5|Mar 4 - Mar 14
6
ad
8
9

Apr 26 - May 9

10|May 10 - May 23

41 |May 24 - Jun 6

42} Jun 7 - Jun 20

13} Jun 21 - Jul 4

14} Jul § - Jul 18

15} Jul 19 - Aug 1

16|Aug 2 - Aug 15 _|

17|Aug 16 - 29

18|Aug 30 - Sep 12

19|Sep 13 - Sep 26

20|Sep 27 - Oct 10

21|Oct 11 - Oct 24

22] Oct 25 - Nov 7

23/Nov 8 - Nov 21

24|Nov 22 - Dec 5

25|Dec 6 - Dec 19

26

Dec 20 - Jan 2

Form FMC-183 (Front)

Last, First, MI

Leave Cat. Code

Service Comp Date



Review of the Bureau of Trade Analysis
Time and Attendance Practices

The Office of Inspector General (OIG) completed a review of time and attendance (T&A)
practices in the Federal Maritime Commission’s (FMC) Bureau of Trade Analysis (BTA). This
audit was part of a coordinated review of T&A practices in five Commission bureaus and offices.
The audit objective was to assess whether BTA complies with agency policies and government
regulations concerning T&A reporting.

Background

The FMC has a Service Level Agreement with the U.S. Department of Agriculture,
National Finance Center (NFC), to process agency time and attendance records and to pay its
employees. The System for Time and Attendance Reporting (STAR), a web-based application,
is used by timekeepers to prepare and transmit attendance reports to the NFC as a first step in
pay and leave administration. Employees are responsible for accurately recording their time and
attendance and certifying the accuracy of their T&A records. Supervisors are responsible for
approving work schedules, leave requests and certifying T&A biweekly submissions.

The FMC’s Office of Financial Management (OFM) issued Standard Operating
Procedures (SOP) for T&A in July 2007 and again in April 2008. The SOPs identify procedures
and responsibilities relating to the documentation and transmission of the agency’s T&A records
and processes. The agency also provides guidance to its employees in Commission Order (CO)
64, Employee Absence and Leave (December 3, 2004), and CO 92, Work Schedules, (December
15, 2003). CO 92 requires employees to document their work schedules on FMC-110, Employee
Request for Work/Telework Schedule (See Appendix A) and the actual hours worked on
FMC-109, Employee Arrival and Departure Record.' (See Appendix B)

Employee requests for leave (sick, annual or other) are to be made to the supervisor on
Office of Personnel Management (OPM) Form 71, Request for Leave or Approved Absence (i.¢.,
leave slip) in advance of the proposed leave (See Appendix C). The supervisor can approve,
disapprove or modify the request. When the supervisor approves the leave slip it is generally
provided to the timekeeper to reconcile with other supporting documents at the end of the pay
period. The employee’s signature on the leave request form is a strong control over leave abuse,
as it certifies that the leave/absence requested is for the purpose(s) indicated... and that
falsification of information on the form may be grounds for disciplinary action, including
removal. OPM Form 71 provides employees with the option to include their social security
number (SSN) on the form when requesting leave. However, in September 2006, the
Commission notified its staff that this identifier was no longer needed to process the leave
requests.

' Employees on compressed work schedules are required to complete FMC-109, however the agency
recommends that all employees use the form to document time and attendance.


Form FMC-2 UNITED STATES GOVERNMENT FEDERAL MARITIME COMMISSION

(Rev. 07-89)

Memorandum
DATE: July 2, 2009
TO 4 Office of the Inspector General
FROM f Director, Bureau of Trade Analysis
SUBJECT: Response to Review of the Bureau of Trade Analysis Time and

Attendance Practices

Below please find the Bureau of Trade Analysis’ (BTA) seriatim response to the

Office of the Inspector General (OIG) Review of BTA’s Time and Attendance Practices.

sek

OIG recommendation 1: OIG recommends “the supervisors provide approved leave
slips directly to the timekeeper for reconciliation for all BTA staff.”

BTA response: BTA concurs. On June 23, 2009, BTA supervisors were so instructed.
Corrective action taken to address OIG’s recommendation 1 is complete.

OIG recommendation 2: OIG recommends “all staff use the updated OPM Form 71
for leave requests.”

BTA response: BTA concurs. On June 23, 2009, all BTA staff were instructed to use the
updated OPM form 71 as reproduced on the Commission’s intranet page for leave
requests. Corrective action taken to address OIG’s recommendation 2 is complete.

OIG recommendation 3: OIG recommends “all BTA staff complete FMC-110 to
reflect their current work hours and obtain approval by the supervisor and/or the
Director.”

BTA response: BTA concurs. On June 23, 2009, all BTA staff were given Form FMC
110 with the instruction to complete the form and return to their supervisors by July 10,
2009.

OIG recommendation 4: OIG recommends “the timekeepers familiarize themselves
with the T&A SOP and follow the stated instructions when applicable.”

BTA response: BTA concurs. On June 23, 2009, timekeepers were instructed to re-read
the T&A SOPs. Also, BTA will request the Office of Financial Management (OFM) give


for BTA timekeepers to ensure they are keeping abreast of the latest T&A’s SOPs and
will also request that OFM assist timekeepers in entering T&A information into STAR
when the alternate timekeeper is unavailable.

Dorn Gur

Florence A. Carr

ce: Director, Office of Operations
Director, Office of Administration
Director, Office of Financial Management


Other observations and findings, and recommendations to address them, are provide in
the attached report. We thank BTA staff for its help and cooperation.

ce: Deputy Director, Bureau of Trade Analysis
Deputy Director, Office of Administration
Special Assistant, Office of Administration
Director, Office of Financial Management
Director, Office of Human Resources


FEDERAL MARITIME COMMISSION
Office of Inspector General
Washington, DC 20573-0001

July 28, 2009

Office of Inspector General

TO: Florence A. Carr
Director, Bureau of Trade Analysis

Inspector General
SUBJECT: Review of the Bureau of Trade Analysis’ Time and Attendance Practices

The Office of Inspector General (OIG) conducted a review of the Bureau of Trade
Analysis’ (BTA) Time and Attendance (T&A) practices. The primary objectives of internal
control in a T&A system are to ensure that the system complies with applicable legal
requirements, supports reporting of reliable financial information, and operates effectively and
efficiently. The objective of this review was to assess whether BTA complied with agency
policies and government regulations concerning employee time and attendance.

The OIG selected T&A records for 12 employees to test payroll procedures and processes
used in BTA. Four of the employees selected have T&A processing responsibilities. All records
pertained to calendar year 2008.

BTA has generally implemented controls over T&A processing. The OIG did not
identify payroll abuse and managers and timekeepers, for the most part, seemed cognizant of
controls over payroll processing. We found staff protected Personal Identifiable Information on
payroll-related documents. T&A administrators are responsible for providing training to the
timekeepers.

On the other hand, we identified practices in BTA that, while not material, are not
compliant with agency payroll policies and procedures. Still, noncompliance in some areas
could, if not corrected, eventually lead to payroll-related waste or abuse. Findings of
noncompliance involved leave request and certification requirements and select other work
schedule documentation requirements. For example, employees did not routinely prepare the
OPM Form 71, Request for Leave or Approved Absence, when requesting/accounting for leave
used. In total, we identified 255 hours of leave used without a leave slip by five employees. We
noted that these employees accounted for the leave used on FMC-109, Employee Arrival and
Departure Record, but the FMC-109 is not provided to the supervisor either in advance of the
leave taken or for supervisory approval.


occasions; supervisors failed to certify the STAR on 13 occasions and BTA staff failed to certify
the STAR report on 70 occasions.

Recommendation 7. We recommend the BTA timekeeper adhere to the T&A SOP to obtain all
certifications for the STAR or identify the reason an employee was not
available to certify the STAR.

Finding 6. Maintenance of the Annual Attendance Record with Errors

The T&A SOP states that timekeepers shall record all leave taken during the pay period
to the employee’s FMC-183, Annual Attendance Record, which is available manually or
electronically. Each calendar year the timekeeper is provided a blank FMC-183 for this purpose.
This record is to be maintained regularly, as it is used to create and verify leave balances, and it
is routinely used by OFM to make corrections to the NFC database when errors occur.

We used a modified version of this form to perform a leave audit for the 12 employees in
our sample using balances carried over from the last pay period in CY 2007, leave slips, FMC-
109 and hours charged on STAR, and compared it to the FMC-183 maintained by the
timekeeper.*

We identified one timekeeper that did not maintain the FMC-183 as required for 2 of the
12 sampled employees. Therefore, we could not compare it to the FMC-183. However, our
leave audit and the STAR reconciled.

For the three timekeepers that did maintain the FMC-183, we identified discrepancies in
five of the nine-sampled employees annual and sick leave balances that carried over into
calendar CY 2009. Adjustments to correct these leave balances must be performed by OFM
staff.

Table. 2 Leave Audit Results

‘Annual Leave - STAR 250° 248 38 53 233

Annual Leave - FMC-183 250 258 38 63 231
Annual Leave — Leave Audit 221 248 38 57 243
Difference (29) (10) 0 (4) 12
Sick Leave—- STAR 101 596 66 8 220
Sick Leave— FMC-183 101 596 66 8 222
Sick Leave — Leave Audit 91 596 62 8 210
Difference (10) 0 (4) 0 (10)

* A leave audit reconciles opening leave balances, leave earnings and usage, with closing leave balances for
a predetermined time period.

10


a refresher session to BTA timekeepers on the T&A SOPs, with special emphasis given
on procedures that might have changed since the last version of the SOP.

OIG recommendation 5: OIG recommends “that BTA management adhere to the
agency’s policy in regards to use of compensatory time off for its staff.”

BTA response: BTA concurs. On June 23, 2009, the Director, BTA reminded all BTA
supervisors of the agency policy with particular emphasis on re-scheduling alternative
work schedules. Corrective action taken to address OIG’s recommendation 5 is
complete.

OIG recommendation 6: OIG recommends “BTA inform the primary timekeeper to
request OFM stqff to enter her T&A in STAR when the primary and/or alternate
timekeeper is not available.”

BTA response: BTA concurs and on June 23, 2009, advised timekeepers to conform
their behavior to this policy. BTA also will request OFM assistance to BTA timekeepers
in this respect.

OIG recommendation 7: OIG recommends “the BTA timekeeper adhere to the T&A
SOP to obtain all certifications for the STAR or identify the reason an employee was
not available to certify the STAR.”

BTA response: BTA concurs. At a meeting on June 23, 2009, all BTA employees were
reminded to adhere to this T&A SOP. Corrective action taken to address OIG’s
recommendation 7 is complete.

OIG recommendation 8: OIT recommends “the timekeeper maintain the Annual
Attendance Record for CY 2008 and future years to reflect reconciliation based on
leave slips, emails, FMC-109 and STAR reports, to ascertain the correct leave balances
for its employees and provide an updated FMC-183 to OFM for corrections in NFC
and STAR before the end of FY 2009 for CY 2008.”

BTA response: BTA concurs. On June 23, 2009, BTA timekeepers were instructed by
the Director, BTA to maintain the FMC-183 forms for 2008 and future years, with the
understanding that OFM might have further instruction as to records retention policies
and practices. Also on that date, the Director, BTA instructed BTA timekeepers to
provide OFM with updated FMC-183s by July 10, 2009.

ood

Based on the foregoing, BTA considers the corrective action it has already taken in
response to OIG recommendations 1, 2, 5 and 7 to be complete. BTA has already taken
steps to respond to OIG recommendations 3 and 8, but these corrective actions are not yet
complete. BTA will advise OIG when those actions have been fully completed. As to
OIG’s recommendations 4 and 6, BTA will request that OFM conduct refresher courses