Federal Telework: Additional Controls Could Strengthen Telework Program Compliance and Data Reporting
Published: 2017-02-17T00:00:00

Fast Facts:
How are federal agencies managing their 400,000+ teleworkers?
The 4 agencies we reviewed (Ed, GSA, Labor & SEC) generally met the reporting requirements in the Telework Enhancement Act of 2010. However we found some barriers to telework program success:
Training timing: Managers may make telework decisions before training.
Documentation: Agencies may not review telework agreements annually or document renewals.
Managerial resistance: Some supervisors discourage telework despite agency participation goals.
Separately, we also found OPM and some agencies had quality problems with their telework data, which we made recommendations to address.

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Telework Enhancement Act of 2010 required agencies to develop telework policies and OPM to provide guidance and report on telework use, among other things. GAO was asked to review agency telework programs.
This report examines (1) how selected agencies comply with the act's requirements, (2) the internal controls affecting federal supervisors' ability to hold teleworkers accountable for achieving results, and (3) the challenges selected agencies and OPM face in collecting and reporting telework data. GAO selected four case study agencies for review—Education, General Services Administration, Labor, and Securities and Exchange Commission—based on agency size and telework participation rates. GAO reviewed OPM guidance and reports, and policies and data at case study agencies. GAO also interviewed OPM and case study agency officials and held focus groups with case study agency supervisors and teleworkers.
section_title: What GAO Found
paragraphs: The telework policies at four selected case study agencies GAO reviewed met select requirements of the Telework Enhancement Act of 2010 (the act) for telework eligibility and agreements. These agencies followed similar processes for approving telework agreements. Office of Personnel Management (OPM) guidance recommends managers complete telework training prior to approving telework agreements, but three of the four agencies did not have a mechanism to help ensure managers have completed this training before approving employee telework agreements. Because managers in these agencies may not have completed the training before entering into agreements, they may not be familiar with telework policies. Further, three of the four agencies did not require a periodic documented review of telework agreements. By not requiring regular review of telework agreements, these agencies cannot be assured that the agreements reflect and support their current business needs. Consistent with the act, all four agencies described efforts to encourage telework participation and provide for the technology to enable it. However, GAO's focus groups with teleworkers provided some examples of how supervisors may discourage telework participation and reported that some level of managerial resistance to telework remains. Managerial resistance to telework can undermine reviewed agencies' ability to meet telework participation goals. In its leadership role for telework matters, OPM can assist agencies with tools to assess and resolve these types of concerns.
Consistent with the act, all four case study agencies have controls to help ensure that telework does not diminish employee and organizational performance. These four agencies' policies followed the act's requirement that teleworkers be treated the same as nonteleworkers for the purposes of work requirements, performance appraisals, and other managerial decisions. Agency officials and focus groups reported that telework status did not impact performance expectations. Focus groups with supervisors described numerous strategies and resources they use to supervise and stay connected with teleworking employees.
The four agencies used varied methods to collect and report telework data to be included in OPM's annual telework reports, but all cited challenges to ensuring that employee-reported telework data were accurate because employees may not know or follow policies for recording telework. While three of these agencies use electronic systems to track telework agreements, the Department of Labor (Labor) uses a manual system which limits its ability to access accurate, real-time telework agreement data that management uses to assess compliance and for resource allocation decisions. Further, GAO found that the Department of Education (Education) had not been reporting telework eligibility data compliant with the act. OPM also faced challenges in reporting accurate agency telework data and GAO identified errors in OPM's annual reports to Congress. For example, OPM's report cited Education's fiscal year 2016 telework participation goal as 5 percent, reflecting Education's goal for increasing its participation rate, instead of its overall participation goal of 90 percent. OPM may be missing opportunities to improve its data because it does not always follow up with agencies on significant data differences or outliers. The errors and invalid data in OPM's annual reports to Congress reduce the usefulness of these reports.
section_title: What GAO Recommends
paragraphs: GAO makes recommendations to each of the case study agencies, including ensuring supervisors complete telework training in a timely manner and improving telework data. GAO also recommends that OPM develop tools to help agencies assess telework barriers, and to improve telework data reported to Congress. Three agencies agreed with the recommendations. One did not comment. OPM disagreed with GAO's recommendations citing limited resources to expend on efforts not specifically required under the act. GAO maintains that OPM should implement these actions as discussed in the report.

section_title: Letter
paragraphs: Congress has encouraged federal agencies to expand staff participation  in telework, most recently in 2010 by passing the Telework Enhancement  Act of 2010 (the act) which requires executive agencies to establish  telework policies, incorporate those policies into their respective continuity  of operations plans, and provide interactive telework training to  employees eligible to telework and managers of teleworkers. The act  describes the Office of Personnel Management’s (OPM) responsibilities  and agencies’ telework program responsibilities. As telework participation  expands, agencies must address how to develop and institute internal  controls to ensure they are managing for results in a telework  environment. Also, in accordance with the act, agencies must establish  policies to ensure that telework does not diminish employee performance  or agency operations.
You asked for us to review agency internal controls for telework,  performance management in a telework environment, and how often  employees are teleworking. This report identifies and examines (1) how  selected agencies establish and monitor telework eligibility and  participation, and comply with the requirements of and expectations  included in telework agreements; (2) the internal controls and practices at  selected agencies that affect supervisors’ abilities to manage for results in  the telework environment, and hold employees who routinely telework  accountable for achieving results; and (3) the challenges selected  agencies and OPM face in collecting and reporting telework data.
To address these objectives, we reviewed and used as criteria the act,  Standards for Internal Control in the Federal Government, OPM’s  guidance and training on telework and performance management, and  our prior work on agency telework programs. We also interviewed key  OPM officials from Employee Services and Senior Executive Service and  Performance Management as well as the Executive Director of the Chief  Human Capital Officers (CHCO) Council. We also selected four agencies  as case studies, including the Department of Education (Education), the  General Services Administration (GSA), the Department of Labor (Labor),  and the Securities and Exchange Commission (SEC) for our review. We  selected these agencies using size and telework participation rates as  criteria. We also conducted a series of focus groups at the four case  study agencies with groups of supervisors of teleworkers and groups of  teleworkers. When discussing these focus groups throughout the report,  we use the word some to mean more than two but fewer than six focus  groups.
To determine how the four case study agencies establish and monitor  telework eligibility and compliance with requirements and expectations of  telework agreements, we reviewed the act, OPM guidance, telework  policies, telework training materials, blank telework agreements, and  collective bargaining agreements. We interviewed agency officials  responsible for telework policy and program implementation, including the  Telework Managing Officer (TMO) or the telework coordinator, to discuss  telework policy, program implementation, internal controls, and OPM  guidance on telework. We then compared these four agencies’ policies to  the act’s requirements, OPM guidance, and Standards for Internal Control  in the Federal Government to assess compliance. We discussed telework  eligibility and notification at our focus groups with teleworkers, and  interviewed OPM officials about OPM’s role in providing telework  guidance to federal agencies.
To determine how supervisors at the four case study agencies manage  for results in a telework environment and hold employees who routinely  telework accountable for achieving results, we reviewed requirements of  the act and agency policies, reviewed OPM and agency-specific training  materials on telework and performance management, and discussed  agency performance management policy with case study agency officials.  We also asked supervisors participating in our focus groups what  strategies and resources they use to manage their teleworking  employees, and what steps they take to help ensure telework does not  diminish their employees’ performance. We asked participants at our  teleworkers focus groups about how telework has affected their ability to  meet performance goals, how their supervisor holds them accountable  for achieving results, and how the agency supports telework.
To identify and assess the challenges the four case study agencies and  OPM face in collecting and reporting telework data, we reviewed our prior  work on OPM telework data reporting as well as OPM’s Status of  Telework in the Federal Government Report to Congress (Fiscal Year  2013) and OPM’s Status of Telework in the Federal Government Report  to Congress (Fiscal Years 2014 and 2015). We compared agency  telework data to data in OPM’s reports to Congress to identify any  discrepancies. To report data on numbers of teleworkers and the average  number of hours employees telework per pay period, we analyzed  telework data from each of the case study agencies. We reviewed  documentation of data sources, tested the data for outliers, and  interviewed case study agency officials about data reliability and  determined these data to be reliable for the purposes of our report. We  interviewed OPM and case study agency officials, teleworkers, and  supervisors about the steps they take to collect, validate, and report  telework data, and any challenges they may face in doing so. For more  detailed information on our objectives, scope, and methodology, please  see appendix I.
We conducted this performance audit from November 2015 to February  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Increasingly, agencies are using telework to diminish the disruption that  severe weather events and other events may have on agencies’ abilities  to accomplish their missions. For example, OPM encouraged agencies to  use telework in the Washington, D.C. metropolitan area in response to  the potential for disruptions caused by the papal visit in September 2015,  the unplanned 1-day shutdown of the metropolitan area’s subway system  in the spring of 2016, and ongoing subway track safety work begun in  2016.
subsections: section_title: Telework Enhancement Act of 2010
paragraphs: In 2010, Congress passed the act to specify the requirements for  executive agency telework programs and define OPM’s role in providing  leadership over telework to agencies. In drafting the act, Congress  acknowledged telework as an important human capital tool for agencies,  as well as the need for legislation to overcome resistance to telework. We  have previously reported on federal telework programs and  recommended improving the reliability of agency-reported data, the extent  to which agencies have implemented telework as a tool for continuity and  emergency planning, and the information available on costs and benefits  of telework programs.
As required in the act, executive agencies are to designate a TMO.  According to OPM guidance, the TMO develops telework policy, serves  as a resource for teleworkers and their managers, and advises the CHCO  on the agency’s telework matters. OPM guidance stresses that the TMO  position encompasses more than administrative responsibilities. The  TMO is the single agency official accountable for that agency’s telework  program and its compliance with the act. Agencies may also designate a  telework coordinator to implement the day-to-day operations of the  telework program.
The act requires OPM to work with agencies to implement the act’s  requirements. This includes assisting agencies in establishing appropriate  qualitative and quantitative measures and teleworking goals. Additionally,  the act charges OPM with providing telework guidance on pay and leave,  agency closure, performance management, official worksite information,  recruitment and retention, accommodations for employees with  disabilities, and maintaining a central telework website,  www.telework.gov.
The act also requires OPM to issue an annual report to Congress on the  status of telework in the federal government. OPM has surveyed  executive agencies with an annual data call to fulfill its role in reporting on  progress towards telework related goals to Congress. While there are  many ways to assess telework program success, the act requires OPM to  report on agencies’ goals related to increasing participation rates in their  telework programs, whether or not the agencies met their goals, and if  not, what actions agencies are taking to identify and eliminate barriers to  maximizing telework opportunities. The information collected by OPM  can shed light on the barriers agencies may face in implementation, such  as managerial resistance or technology limitations. While we have  previously reported on data limitations related to OPM’s annual telework  reports, the reports do provide useful context about the status of telework  in the federal government and are comprehensive sources of information  on telework in the executive branch. OPM reports that the number of  federal employees teleworking has increased more than 40 percent since  fiscal year 2012. Table 1 shows the number of teleworkers in the federal  government, as reported in OPM’s annual Status of Telework in the  Federal Government reports to Congress.
section_title: Types of Telework Arrangements
paragraphs: OPM has identified two general types of telework: routine telework and  situational telework. Routine telework is telework that occurs as part of an  ongoing, regular schedule. Routine telework may be part time or full  time. The key feature of routine telework—also referred to as continuing,  regular, fixed, or recurring—is that it occurs on a predictable schedule. In  contrast, situational telework is approved on a case-by-case basis, and  occurs outside of a routine telework schedule. Situational telework often  occurs in response to a specific event such as inclement weather.  Situational telework is also referred to as ad hoc, episodic, intermittent,  and unscheduled telework. Situational telework may be approved for 1  day or a number of days. For example, short-term telework is situational  telework that occurs continuously for a finite number of days. Employees  participating in short-term arrangements (e.g., because recuperating from  surgery, maternity reasons, etc.) typically do not have in-office days; they  work a full or part-time schedule from their homes. Before an employee  can participate in any telework arrangement he or she must be approved  to telework.
section_title: History of Telework at Four Case Study Agencies
paragraphs: The act requires OPM to report agencies’ progress towards meeting  telework goals, such as telework participation rates; however, telework  had existed at federal agencies before the act’s passage. As previously  mentioned, for this review we included Education, GSA, Labor, and SEC  as our case study agencies based on telework participation rates and  agency size. Table 2 shows the average number of individuals  teleworking for the pay periods that include September 30, 2015 through  May 31, 2016.
According to Education officials, Education’s telework program began in  1994 and became permanent in 2000. After the act was enacted,  Education drafted a telework policy and notified all employees of their  eligibility to participate in telework, officials stated. Education finalized its  official telework policy in 2015. Education’s telework policy is set at the  department level. The department’s components have some discretion in  applying the rules set in the policy. Education has a negotiated collective  bargaining agreement covering telework with one union that represents  Education employees.
According to GSA officials, GSA began allowing informal telework in the  early 1990s and developed its first telework policy in the mid-1990s. In  2008, GSA developed and updated its official telework policy. The policy  applied general criteria to eligibility and participation that, according to  GSA, were later mandated by the act. In October 2011, GSA further  updated its telework policies to fully comply with the act, officials said.  GSA allows for telework up to and including full-time telework. GSA has a  negotiated collective bargaining agreement that covers telework with  each of the two unions that represent GSA employees nationwide.
subsections: section_title: Labor
paragraphs: According to Labor officials, Labor’s telework program dates back to the  1990s. Labor officials stated that when the act passed, Labor officials  reviewed its telework program to ensure it complied with the act’s  provisions. Labor has not changed its telework policy significantly since  2010. While its telework policy is set at the department level, subagencies  within Labor have discretion in interpreting and applying the policy, so  long as it aligns with the department’s policy. Labor has negotiated  collective bargaining agreements covering telework with three unions that  represent its employees.
According to SEC officials, SEC launched its first official telework  program in 2002, but had allowed telework more informally since the mid- 1990s. In 2007, SEC negotiated a new collective bargaining agreement  with the one union that represents SEC employees. SEC officials said this  agreement included an expanded telework pilot program that allowed for  telework up to 5 days per week for certain employees. In 2013, SEC  made the expanded telework pilot program permanent and expanded  telework to others within the agency. SEC sets telework policy at the  commission level.
section_title: Federal Standards for Internal Control
paragraphs: Standards for Internal Control in the Federal Government provides  guidance for establishing and maintaining an effective internal control  system in federal agencies. Internal control comprises the plans,  methods, policies, and procedures used to fulfill the mission, strategic  plan, goals, and objectives of an agency. Internal control is a process  affected by the agency’s oversight body, management, and other  personnel who provide reasonable assurance that the objectives of the  agency will be achieved. These objectives and related risks can be  broadly classified into one or more of the following three categories:
Operations – Effectiveness and efficiency of operations
Reporting – Reliability of reporting for internal and external use
Compliance – Compliance with applicable laws and regulations  To be effective, an agency’s internal control system must incorporate a  series of actions and activities that occur throughout its operations and on  an ongoing basis. Once in place, internal control provides a reasonable,  but not absolute, assurance of meeting those objectives.
As related to telework, management is responsible for adapting the  internal control standards to develop activities and processes that allow  the agency to achieve its telework policy goals. The activities adapted by  the agency should help staff carry out specific program activities  according to its telework policies and procedures. For this report, we  limited our examination of internal controls to specific activities,  processes, and policies that help the four case study agencies comply  with the act. We also examined specific internal controls designed to help  the four case study agencies achieve their telework goals as expressed in  case study agencies’ individual telework policies.
section_title: Selected Agency Telework Programs Reflect Requirements of the Act, but Some Controls Are Not Documented and Agencies Face Some Barriers to Increasing Participation
subsections: section_title: Case Study Agencies’ Telework Eligibility Processes Were Consistent with Legal Requirements, but Some Agencies Lack Controls for Timing of Manager Training
paragraphs: The act sets out basic requirements for agencies for (1) telework  eligibility, participation, and notification; (2) telework agreements; and (3)  training. Furthermore, OPM also provides guidance on notifying newly  hired employees of their eligibility to telework. We reviewed the controls  and processes that our four case study agencies had in place to help  ensure they comply with the act and adhere to OPM guidance and other  agency telework policies. While controls and policies varied for each  agency, the agencies all met the act’s requirements and followed the  same general process for approving telework agreements.
subsections: section_title: Telework Eligibility Determination and Notification
paragraphs: The telework policies of all four case study agencies comply with the  eligibility and participation requirements noted in the act. The act required  agencies to determine all employees’ eligibility for telework and notify  employees of their eligibility no later than 180 days after enactment. In  keeping with the recognized importance of telework, the act describes the  limited situations in which employees are ineligible to telework instead of  prescribing eligibility. The act also describes situations in which  participation in telework may be limited or not authorized. Beyond these  exceptions, the act authorizes agencies to determine specific employees’  eligibility to participate.
Education, Labor, and SEC designed additional policies to clarify when  employees were either ineligible or could not participate in telework.  GSA’s policies did not have additional eligibility or participation  requirements. As noted in its telework policy, GSA supports the broadest  possible use of telework. For example, GSA required all employees to  have a telework agreement. Even if GSA employees choose not to  telework, they may be required to have an agreement authorizing  telework in the event of an unexpected need to telework. Figure 1  shows the 4 case study agencies’ policy compliance with the act’s  eligibility and participation requirements, as well as additional related  policies.
The act required agencies to notify all employees of their eligibility to  telework within 180 days of enactment. OPM reported in 2012 that most  agencies required to make this notification did so within the given time  frame. While the act does not specify when newly hired employees must  be notified of their eligibility to participate, OPM guidance provides that  agency policies should provide for notification of newly hired employees  within a reasonable time frame. Officials at Education, GSA, and Labor  said they include information on telework eligibility in employment  announcements. According to agency officials at the four case study  agencies, newly hired employees are informed of their eligibility in new  employee orientation or during the onboarding process. SEC officials  said all new employees are required to take telework training at which  time employees are again informed of their eligibility. We heard in all of  our focus groups with teleworkers that employees were notified through a  variety of methods including agency-wide notices, union notifications,  discussions with a supervisor, newsletters, intranet sites, and direct e- mail notification.
section_title: Telework Approval Process
paragraphs: The act requires agencies’ employees to enter into a written telework  agreement with an agency manager before they can telework. The  telework agreement is to outline the specific work arrangement agreed  upon between employee and supervisor. With slight variations, the 4 case  study agencies generally follow the same telework approval process, as  shown in figure 2.
Executive management at all four case study agencies require  supervisors and, in one case, managers, to approve or deny telework  applications. At GSA, Labor, and SEC, first-line supervisors are  responsible for approving or denying agreements. At Education, first-level  supervisors recommend approval or denial to second-level managers,  who make the final decisions. Employees at Education, GSA, and SEC  submit agreements to their direct supervisors or managers through  electronic approval systems. Conversely, Labor’s telework application  system is largely paper based. Labor employees submit paper  agreements or electronic versions of paper applications to their direct  supervisor for approval. Finalized telework agreements are then  maintained either by supervisors or centrally within the agencies, by  reporting to a telework program official or in an electronic telework  agreement system.
The four case study agencies provide supervisors and managers  guidance on making telework agreement decisions through telework  policies. Telework policy at all four case study agencies allows  supervisors to use their professional judgment or discretion within the  parameters of the official policy. According to these policies, decisions to  approve or deny telework agreements should be based on sound  business and performance management principles. For example, to help  managers determine the eligibility of both positions and employees, Labor  has developed a decision tree that includes a series of yes or no  questions that help managers and supervisors determine whether or not  to approve an agreement. Supervisors are also encouraged to discuss  telework with their employees before formal requests are made.
Telework policies at each case study agency include procedures for  employees to appeal the denial of a telework agreement. In all four of our  focus groups with supervisors we heard that telework denials due to  performance or conduct issues are rare. In addition, collective bargaining  agreements at each agency afford bargaining-unit employees the ability  to file a grievance if denied telework. Agency or union officials at each  case study agency also told us that grievances are rare.
section_title: Telework Training
paragraphs: The act requires that agencies provide interactive telework training to  employees eligible to telework and to managers of teleworkers. The act  also requires that employees successfully complete the training before  entering into a telework agreement. Consistent with this requirement, all  4 case study agencies require employees to complete and document  telework training before signing a telework agreement. To verify  completion, Education, Labor, and SEC require employees to include a  certificate of telework training when they submit a telework agreement for  approval. At GSA, employees are not granted access to the online  telework agreement system until they have successfully completed  telework training. Figure 3 shows the training requirements for both  employees and managers at the 4 case study agencies.
The act also requires agencies to provide training to managers of  teleworkers. OPM provides tools and policy guidance intended to improve  agency telework programs. In its guidance to managers and supervisors,  OPM defines 13 basic steps managers should follow to help them  effectively implement a telework program. This guidance sequences  training completion (step 3) before entering into telework agreements  (step 6). See table 3 for the key steps for managing teleworkers as  sequenced by OPM.
Consistent with federal internal control standards, persons in the key role  of approving or denying telework agreements need to possess and  maintain a level of competence that allows them to accomplish their  assigned task in accordance with established policies. To achieve this  competency, management provides training to help staff develop the  knowledge, skills, and abilities needed to accomplish assigned tasks. If  an agency ineffectively times training for managers or supervisors or  lacks controls for ensuring the training is complete before entering into  telework agreements, then managers or supervisors might make telework  decisions before having completed the training.
All four case study agencies require managers and supervisors to  complete telework training, but not all require it before signing telework  agreements. Education’s and SEC’s telework policies stipulate that  managers and supervisors are to complete telework training before  entering into telework agreements. However, officials at Education and  SEC told us that managers and supervisors are required to take training  within a specific timeframe, but not necessarily before entering into  telework agreements. Telework policies at GSA and Labor do not  mention the timing of training for managers or supervisors. However,  because GSA’s automated telework application system requires  personnel to successfully complete telework training before granting  access to either the employee or the supervisor, GSA supervisors and  managers must complete telework training before approving telework  agreements. Labor officials told us that new managers have 6 months to  complete telework training.
Other than at GSA, case study agency training systems contain the  mechanisms to track manager and supervisors’ completion of training and  are not directly linked to the telework program system. At these three  agencies, the internal controls in place for training completion do not  interface with the telework systems and therefore may affect the ability of  telework program officials to readily track completion. SEC officials told us  that after receiving a biannual report listing managers, supervisors, and  employees who have not completed the training, the TMO will send a  reminder to complete training. Education and Labor telework officials said  they can request data from the learning divisions on telework training, but  they do not have direct access to the information.
Managers and supervisors at Education, Labor, and SEC who do not  undergo telework training prior to entering into telework agreements may  not fully understand the agency’s telework policy before approving or  denying a telework request. Without adequate knowledge of agency  policy, these managers and supervisors may not be performing their  assigned tasks in a manner that helps their respective agencies achieve  telework program goals and objectives. Given the expectation that  managers will apply professional judgment when approving or managing  telework agreements, it is important that they have the appropriate  training before entering into agreements.
section_title: Some Selected Agencies Do Not Review Telework Agreements Annually nor Document Annual Renewals
paragraphs: According to OPM’s best practice guidance for managers and  supervisors, telework agreements are living documents that should be  regularly reviewed and re-signed by both the manager and teleworker.  However, our four case study agencies were inconsistent in whether they  review or document the review of ongoing telework agreements. As a  result, the telework agreements on file may not accurately reflect current  telework participation and may undermine the quality of the telework data  the agency has. Federal internal control standards state that agencies  should use quality information to achieve agency objectives. To help  ensure that the information contained in telework agreements is accurate,  management should design control activities to respond to the risk of  having inaccurate data, including outdated information. In addition,  according to federal internal control standards, documentation is a  necessary part of an effective internal control system. Therefore, as  applied to telework agreements, these standards suggest that agencies  should document these reviews. Unless telework agreements are  regularly reviewed and these reviews documented, the agencies face the  increased risk of having inaccurate information.
The four case study agencies varied in how frequently they reviewed and  documented their review of telework agreements.
Education’s telework policy requires telework agreements to be  renewed annually. Telework agreements expire 1 year after their  approval date. According to Education officials, Education’s new  telework agreement management system will require all telework  agreements to be renewed annually during the same time period and  for this review to be documented in the system.
GSA’s telework policy does not require telework agreements to be  periodically reviewed once they are approved. Instead, GSA officials  told us they remind supervisors to review agreements as part of the  performance appraisal process. However, unless a change is made to  the agreement in GSA’s electronic system, the telework agreement  review is not documented. GSA officials said the agency is  considering a new policy to require a periodic, documented review of  telework agreements.
Labor’s policy requires supervisors to annually review agreements to  help ensure that agency and employee needs are being met, but  documentation of the review is not required.
SEC’s telework policy notes that employees may be required to  recertify agreements to help ensure the accuracy of the information in  the agreement, but a periodic and documented review is not required.  SEC officials said they anticipate updating SEC’s telework agreement  system sometime in 2017, including requiring that all telework  agreements be renewed annually and the actions documented.
By not requiring telework agreements to be regularly reviewed, GSA,  Labor, and SEC cannot be assured that the agreements reflect and  support their current business needs. Of these agencies, Labor is most  vulnerable to the risk of having inaccurate data on current telework  agreements because it uses a largely paper-based manual system to  manage its telework agreements. Given the likelihood of changes in work  responsibilities and employee schedules over time, telework agreements  not subject to a periodic and documented review may contain outdated  information. In turn, that may result in management at these agencies  using inaccurate data when making decisions that require telework data,  such as for space planning, technology investments, or calculating the  costs and benefits of telework. Also, employees at these agencies may  be teleworking more often than approved or on days not specified in their  agreements. Without a documented periodic review, these agencies lack  an important internal control to better help ensure the accuracy of  reporting, and to reasonably assure that policy guidelines are being  maintained.
section_title: Managerial Resistance and Technology Challenges Continue to Be Barriers to Telework Participation
paragraphs: Case study agency officials and some focus groups with supervisors and  teleworkers report that while managerial resistance to telework has gone  down, and telework technology has improved in the 6 years since the  act’s passage, they remain the key challenges to increasing telework  participation. In its 2014 report to Congress, OPM reported that the top 2  reported barriers to employees’ ability to telework were management  resistance (22 percent) and information technology (IT)/infrastructure (20  percent). In its 2016 report, OPM continued to cite managerial resistance  and technology limitations as barriers to telework.
According to the act, OPM shall assist agencies in establishing  appropriate qualitative and quantitative measures and teleworking goals  as well as consult with GSA on policy guidance for telework technology  and equipment. OPM asks each agency in its annual data call to report  its goal for increasing telework participation to the extent practicable or  necessary. OPM also asks agencies to explain whether or not they met  the participation goal and, if not, what actions are being taken to identify  and eliminate barriers to maximizing telework opportunities. We  previously identified 25 key practices that federal agencies should  implement in developing successful telework programs. This includes 2  practices that demonstrate managerial support for telework and 5  practices related to technology. OPM has previously identified  managerial resistance and technology limitations as common challenges  to agency telework programs, which is consistent with what we found at  our four case study agencies, as discussed in detail below.
subsections: section_title: Managerial Resistance
paragraphs: All four of our case study agencies described agency-wide activities  demonstrating the senior leadership’s efforts to design and implement a  successful telework program. However, in our focus groups with  teleworkers and supervisors we heard a range of examples of how  supervisors or managers discourage or support agency telework  programs. Table 4 provides examples of how supervisors reportedly  demonstrated this support and discouragement at our case study  agencies. Officials at three of our four case study agencies and two focus  groups with teleworkers and supervisors reported that some managers do  not support telework because they believe it contributes to poorer  performance, as compared to the performance of in-office employees.
Agency and union officials said the frequency of telework varied across  the agencies and supervisors. All four agencies noted in their telework  policies that some supervisor discretion should be used when approving  and monitoring telework agreements, but some agency and union officials  said the resulting variation in telework usage contributed to a perception  that the agency was inconsistently implementing the telework program.  We heard from some union officials and focus groups with teleworkers  that employees sometimes assumed that supervisors were approving  telework based on favoritism or other reasons not supported by agency  policy. Agency and union officials did not characterize the extent to which  supervisors or managers were discouraging telework, partly because  none of our case study agencies had conducted any recent agency-wide  surveys on telework. We also heard at one focus group with teleworkers  that employees did not always feel comfortable voicing concerns publicly  for fear of negative consequences for their careers. However, if  employees are not provided an opportunity to voice their concerns without  concern for negative consequences to their jobs, agencies may be  missing an opportunity to better identify and address barriers to telework,  including managerial resistance. Addressing managerial resistance could  help increase telework participation rates by reducing inconsistencies in  how agency telework policy is applied.
According to federal standards for internal control, management, along  with oversight from the oversight body, should determine through an  evaluation process the extent to which deviations are occurring that would  prevent the organization from achieving its objectives. Although OPM is  not in an oversight capacity, given the requirements the act has placed on  OPM to assist agencies, OPM can help ensure that the agencies have  the appropriate tools and processes to assess barriers to telework and  develop solutions to address them. OPM officials said organizations that  are the most successful at telework are those that incorporate telework  throughout agency operations and policies as opposed to simply having a  written policy on telework.
section_title: Technology
paragraphs: Case study agency officials said technology issues remain a challenge to  their telework programs’ success. We heard at ten of our eleven focus  groups with supervisors and teleworkers that teleworkers have  experienced challenges accessing needed equipment and applications.  Sometimes this limits the type of work that could be done while  teleworking. Seven of these focus groups discussed how network  connectivity or access was a challenge, including having to repeatedly log  on to the agency network after being disconnected and spending time  getting assistance from their respective agencies’ IT help desks. One  focus group with supervisors reported that when IT challenges arose,  supervisors may have to cover teleworking employees’ daily tasks while  the employee resolved the IT issues. We also heard at some of the focus  groups that teleworkers and supervisors discussed what resources and  tools the teleworker would need to perform work activities while  teleworking, and how to address any telework technology-related  problems. For example, we heard at one focus group that if a teleworker’s  phone or other telework-related technology was not working properly, the  teleworker may be expected to return to the office to work until the issue  could be corrected.
Case study agency officials described a number of actions to address  telework technology challenges. For example, these agencies provide  dedicated help desk support to teleworkers; provide equipment, including  webcams, to teleworkers; and have upgraded IT systems to support  telework. GSA officials said they focus IT investments on mobile  strategies that allow employees to work from anywhere. Labor officials  said they have upgraded IT to expand the number of programs supported  remotely. SEC officials said they provide employees who telework 3 days  a week or more with laptops, monitors, and printers to use in their  telework location. SEC officials also said that in 2015, they introduced  new tools, including phones with integrated cameras and upgraded  videoconference equipment, which have helped enable more  collaboration, among both teleworkers and employees across their 11  field offices.
We heard at all seven focus groups with teleworkers that teleworkers do  not always have access to, or were not aware of, the IT tools available to  teleworkers. For example, one focus group reported that some newly  issued laptops at GSA did not have webcams. GSA officials confirmed  that a recent order of laptops did not include webcams. Also, while  external webcams were available to these employees, officials were  unsure if the affected employees had been notified about how to request  one.
GSA officials said they had recently surveyed teleworkers about  technology issues to assess the user experience and determine if there  was capacity for additional telework. Education officials said they have  solicited feedback from employees during training, which identified IT  challenges for the telework program, but had not conducted other surveys  on telework IT. Labor and SEC officials said they have not surveyed their  employees about their IT needs or experiences. However, these case  study agency officials said they conduct IT tests to monitor their networks’  abilities to handle telework needs and identify areas needing  improvement.
section_title: Case Study Agencies Report Being Generally Satisfied with OPM’s Telework Guidance
paragraphs: Case study agency officials told us that OPM telework guidance generally  met their needs, although some agencies would like more clarity on  OPM’s guidance on unscheduled telework. In accordance with the act,  OPM provides telework guidance to agencies on its website,  www.telework.gov. The website covers a number of areas including  agency closure. OPM officials said they also have had multiple  meetings with TMOs and coordinators to clarify its meaning of  unscheduled leave. They added that agencies should treat unscheduled  telework the same as unscheduled leave. Officials also stated that since  OPM introduced the concept of being telework ready, employees are  expected to telework when there is an adverse weather event. This has  led to less confusion about what agencies should do.
Education and Labor officials said that OPM’s announcements of  unscheduled telework and unscheduled leave have created difficulties for  them. These agency officials told us that employees assume OPM’s  announcement allows them to telework even though agency policy  requires employees to either request permission to telework or notify their  supervisors of their intentions to telework. To decrease the confusion,  Labor communicates with employees to remind them of the agency policy  requiring them to notify their supervisors ahead of known continuity of  operations (COOP) events, such as weather-related closures. Labor  officials also encourage managers to speak with employees ahead of a  known event to work out details of telework or leave in advance. In  addition to sending notifications to all employees ahead of known COOP  events, Education advises supervisors to have procedures and guidance  in place beforehand when inclement weather or other possible closures  are expected. Education officials said they would like OPM to more  strongly emphasize the need for employees to follow their agency’s policy  in its announcements.
OPM officials said that when OPM receives multiple questions on a  particular area, OPM usually issues clarifying guidance to all agencies. If  a question comes up often enough, OPM officials said the topic is  included on OPM’s Frequently Asked Questions page at telework.gov.  For example, in August 2016, OPM revamped the site to include answers  to specific questions concerning unscheduled telework and unscheduled  leave.
section_title: Selected Agency Telework Policies and Supervisors’ Strategies Enable Agencies to Manage for Results
subsections: section_title: Policies Include Internal Controls Designed to Maintain Performance and Consistent Performance Expectations
paragraphs: Consistent with the act, all four case study agencies have developed  internal controls designed to help ensure employee and organizational  performance is maintained with telework. The act calls for agencies to  establish performance related internal controls by making performance a  criterion for continued program participation. Specifically, the act states  that telework policies should ensure that telework does not diminish  employee performance or agency operations. It also requires agencies  to ensure that teleworkers and nonteleworkers are treated the same for  the purposes of performance appraisals, among other management  activities. In addition to the requirements of the act, three of the four  case study agencies had additional performance management controls  related to employee telework eligibility. For example, some agencies  limited telework for new employees and those employees on a  performance-improvement plan. Figure 4 shows performance-related  controls included in each case study agency’s telework policy.
Supervisors at all four case study agencies may reduce or revoke  telework participation if an employee’s performance declines. We heard  in all of our focus groups with supervisors that denying or limiting telework  for performance reasons was rare. Many supervisors said they have  never done so. We heard at some focus groups with supervisors that  supervisors assess whether a teleworking employee’s performance has  declined through performance reviews and monitoring work flow. We  have previously reported that day-to-day performance management  activities like those discussed below can help marginal staff improve  performance.
The act requires that teleworkers and nonteleworkers be treated the  same for the purposes of work requirements, performance appraisals,  and promotions, among other managerial decisions. We heard from  agency officials and in ten of our eleven focus groups with teleworkers  and supervisors that telework status did not affect performance  expectations. Some agency officials, supervisors, and teleworkers also  said that employee performance problems were generally not specific to  telework status. For example, we heard at two of four focus groups with  supervisors that teleworkers with performance problems typically have  them when in the office as well. Further, teleworkers cited personal  benefits that they believed improved their performance. For example, we  heard at all of our focus groups with teleworkers that employees often felt  more productive, were able to concentrate on their work better, and  experienced fewer interruptions when they teleworked.
section_title: Supervisors Cited Several Strategies and Resources for Managing Teleworkers
paragraphs: Supervisors in our focus groups described numerous strategies and  resources they use to supervise and stay connected with their  employees, including teleworking employees. For example, some  supervisors required all employees to work in the office on a certain day  so everyone could participate at weekly staff meetings in person.  Supervisors in one focus group said they monitor employees’ work tasks  online, regardless of telework status. Figure 5 shows the strategies and  resources supervisors discussed using to manage teleworking  employees. Because employees are not always collocated with their  supervisors, these strategies can also be used for managing across  locations, whether the employee is teleworking or not.
Participants in our supervisor and teleworker focus groups spoke about  the importance of discussing the expectations and preferences for  communicating before beginning a telework arrangement. Supervisors  and teleworkers in these focus groups also reported that they rely on  phone calls, conference calls, e-mails, instant messaging, and, for some,  videoconferencing to stay in contact when teleworking. In all of our focus  groups with teleworkers we heard that telework status either had no effect  on how often employees communicated with their supervisor or, in some  cases, led to increased communication. For example, one focus group  discussed that some teleworkers communicate with their supervisors  almost exclusively through e-mail or phone calls, regardless of telework  status. We also heard in some of our focus groups that sharing calendars  allows other team members to see what individuals were working on and  when they were available to collaborate.
section_title: OPM and Case Study Agencies Face Challenges in Collecting and Reporting Accurate and Consistent Telework Data
subsections: section_title: Agencies Faced Some Challenges in Collecting and Reporting Telework Data
paragraphs: Having robust telework data is important for managing and improving  telework programs. Telework data can inform management decisions  about investing resources, planning for COOP events, assessing  compliance with the act, and managing physical space needs. For  example, Education officials said they use telework data to support  space-reduction efforts by informing work space allocation decisions.  SEC uses telework data to ensure those teleworking full-time are  assigned to their proper duty station. Having reliable and timely data  available to management for decision making and reporting is both  important to managing agency telework programs and consistent with  federal internal control standards.
While our case study agencies varied in the methods used to collect,  validate, and report telework data, all agreed that there are challenges to  ensuring that telework data are accurate. Three of our case study  agencies use an electronic telework agreement management system, but  Labor’s manual system creates challenges in tracking the number of  telework agreements. GSA and SEC use electronic systems for storing  and tracking telework agreements. Education transitioned to an electronic  system in 2016. The electronic telework agreement systems allow  Education, GSA, and SEC to integrate certain internal controls into the  telework agreement and data collection process. For example, the  electronic systems can prevent employees from applying for telework if  they have not completed training. They can also show supervisors their  employees’ approved telework schedule when approving employee  timesheets.
In 2016, Education transitioned from tracking telework agreements on  paper to using an electronic system where employees request telework  agreements electronically. As part of this conversion, Education  employees created new telework agreements in the electronic system.  Education officials said this process will serve two key functions: first, it  will convert telework agreements from paper files to electronic  agreements; second, it will require all agreements to be renewed annually  to ensure they continue to fit the needs of the employee or the agency  unit. The electronic system will generate annual reminders to employees  to renew their telework agreements.
Unlike the three other case study agencies, Labor uses a manual, largely  paper-based system. Labor officials said budget limitations had prevented  them from procuring an electronic telework management system. Labor  employees submit a written request for telework to their supervisor, either  on paper or an electronic document. If approved and signed by the  supervisor, the telework agreement is then forwarded to a telework point- of-contact (POC) in the employee’s division or region. The POC then logs  the agreement into a spreadsheet and scans the agreement if it is  submitted on paper. POCs supply telework data for their respective  divisions or regions to the TMO quarterly via a spreadsheet; the TMO  aggregates the data for management reporting and for inclusion in OPM’s  annual reports.
Labor officials said their data on telework agreements may be inaccurate  due, in part, to this manual process and some individuals not following  policy. For example, an employee is allowed to telework as soon as a  supervisor signs the agreement. However, if the agreement is not  forwarded on to the POC, it is not included in the telework data the POC  transmits to the telework coordinator and TMO. Thus it may not be  included in the telework data used by senior department leadership for  decision-making and reporting purposes. Further, Labor officials said that  they began collecting information on scheduled telework hours quarterly  beginning in October 2015, but they did not yet routinely use the data  because they are known to not reflect actual telework hours. Additionally,  Labor officials said that many employees have situational telework  agreements and use them to telework fairly regularly. Such situational  telework would not be part of the scheduled telework hours reported.  These officials also said they are working towards improving telework  data quality to use more data to manage and expand the telework  program.
Because employees may adjust their telework agreement throughout the  year, Labor’s manual process may prevent the agency from being able to  have accurate real-time data on the total number of employees  authorized to telework or accurate expectations for levels of scheduled  telework. Labor officials said senior leadership reviews telework data at  least quarterly. It uses the data for such decision-making purposes as  COOP planning and assessing compliance with the act. If these data are  inaccurate, then any decisions or internal controls based on these data  may be less effective.
All of our case study agencies reported actual telework hours through  employee self-reported data in electronic time and attendance tools. All of  our case study agencies have employees input their bi-weekly work hours  into their electronic timesheet and code for the number of work hours that  were spent teleworking. Supervisors review and certify these timesheets,  and the data are sent to OPM’s Enterprise Human Resources Integration  (EHRI) system. Figure 6 shows the number of telework hours agencies  reported for the pay periods ending October 3, 2015 through June 11,  2016.
Our case study agencies, as well as OPM, agreed that self-reported  telework data may be inaccurate because employees may be unsure how  to correctly report telework hours. Some case study agency officials said  they continue to field questions from employees about how to properly  code for telework hours. This shows that confusion remains about how to  report telework hours correctly. Case study agency officials also said they  sometimes identify instances of incorrect telework time coding in periodic  reviews of telework data. The case study agencies may require  timesheets be corrected when discrepancies are identified.
To address issues with improper recording of telework hours, telework  officials at our case study agencies took a variety of training and  communication approaches. For example, they said they stress the need  for telework data accuracy in communications to supervisors, send  frequent reminders to both teleworkers and supervisors on how to  properly code for telework hours, and offer training and provide job aids to  both teleworkers and supervisors on how to properly code telework time.
Supervisors in our focus groups identified some tools they use to help  ensure their employees’ timesheets properly reflect their telework hours.  For example, supervisors in one focus group said they refer to shared  calendars to verify telework hours before certifying timesheets. At SEC,  electronic timesheets are pre-filled with an employee’s telework schedule,  so employees need only to change the telework time coding if there is a  change to their telework schedule for the pay period, such as for  situational telework. Supervisors at SEC can also run reports from their  telework agreement system showing the telework schedule for all  employees reporting to them.
All four of our case study agencies periodically reviewed telework data to  identify and address trends and outliers, as well as to assess compliance.  Officials at the four case study agencies said they compare lists of  individuals charging telework codes against a list of individuals with valid  telework agreements on file. This helps ensure that everyone who  teleworks is authorized to do so. Agency officials said that when they  identify discrepancies, they notify the individual charging telework and  potentially others, such as the supervisor and local telework coordinator,  of the need for a valid agreement. For example, SEC officials said they  identified 66 individuals teleworking without an agreement in their most  recent review. They then followed up with the individuals to get a telework  agreement in place. SEC officials said they also review situational  telework hours to determine if employees are teleworking routinely and  need a continuing telework agreement. According to agency officials at  our four case study agencies, incorrectly coding work time and  teleworking without a valid agreement were the most common types of  telework data errors.
The case study agencies varied in how they collect and report telework  data. GSA and SEC’s electronic telework management systems and  electronic timesheets provide aggregated data reports. Officials at both  agencies said they can readily collect and report the telework data  required in OPM’s annual telework data calls and for other internal needs.  Officials at Education and Labor said they had some difficulty reporting  certain telework data. As previously discussed, Labor’s telework  management process relies on manual quarterly reporting from  subagencies which does not allow for a real-time assessment of some  telework data. Education officials also said they have had difficulty with  reporting annualized numbers of telework days per employee, as  originally requested by OPM. The process of generating such data  includes comparing data across several systems which is difficult and  time-consuming. For this reason, Education has instead reported to OPM  biweekly telework data for a full year.
section_title: OPM’s 2014 and 2016 Telework Reports to Congress Contained Some Incorrect Data
paragraphs: We identified errors in OPM’s 2014 and 2016 Status of Telework in the  Federal Government reports issued to Congress. The act requires the  Director of OPM, in consultation with the Chief Human Capital Officers  (CHCO) Council, to submit a report annually to Congress addressing  telework at executive branch agencies. This report is to include data on:    telework participation and eligibility; methods for gathering telework data; explanations for changes in participation rates of 10 percent or more; agency goals for increasing telework participation; a discussion of whether agencies met prior year goals and, if not,  what actions are being taken to identify and eliminate barriers to  maximize telework opportunities; an assessment of agencies’ progress towards meeting telework goals; best practices in agency telework programs.
OPM issued a Status of Telework in the Federal Government report for  fiscal years 2012, 2013, and 2014, reporting on data from the prior fiscal  year. However, OPM did not issue the 2014 report until November 2015.  OPM did not issue a fiscal year 2015 report. Instead, it issued a fiscal  year 2016 report in September 2016, using data from fiscal years 2014  and 2015. For the purposes of this report, we refer to the two most  recent reports as the 2014 report and the 2016 report.
To gather data for these annual reports, OPM requests that telework  officials at executive branch agencies and subagencies complete a data  call that includes a series of questions on participation rates and telework  goals, among other topics. OPM updated data standards in March 2012  to assist agencies in reporting telework data properly. It aggregates and  analyzes the data in a spreadsheet and compiles them into the annual  report. OPM officials said that to issue the report, they work within a tight  timeframe and with limited staff resources. They stated, however, that  data accuracy in these reports is a priority. Consistent with federal  internal control standards, OPM provides agencies with a chance to  review their data to help ensure they are accurate before completing the  report. Specifically, these internal control standards state that agency  management should communicate with and obtain quality information  from external parties, and also use quality information (data that are  relevant and from reliable sources) to meet agency objectives. However,  despite this step, we identified some instances of inaccurate agency data  being included in both the 2014 and the 2016 reports. Examples include  the following:   In the 2016 report, Education’s telework participation goals are listed  as 5 percent (the lowest percentage goal for agencies reporting one).  This sharply contrasts with prior fiscal year goals of 85 percent.  Education officials said that they interpreted the question in the data  call as asking for the increase in the telework participation rate goal,  and provided 5 percent as the agency response. The overall  participation goal for fiscal year 2016 should have been 90 percent.  Education officials also said that the data call instructions for this item  and others are not always clear.
In the 2014 report, OPM erroneously reported Labor’s participation  goal. Labor officials said that when OPM provided them with a chance  to review the data to be included in the 2014 report, Labor identified  an error in its reported telework participation goal. Labor officials  notified OPM of the error and supplied the corrected goal information.  However, the published report did not include this corrected goal  information.
In the 2014 report, OPM highlighted the fact that Labor reported  having varying telework eligibility criteria among its subagencies.  However, Labor’s actual telework eligibility criteria are uniform across  the entire department, as had been reported in the prior annual report.  Labor officials said that they had mistakenly supplied incorrect  information to OPM on eligibility criteria for four subagencies. They  added that they did not recognize the error until the final report was  issued.
Education officials said that although OPM sometimes follows up on data  supplied in the data call, they believe it would be helpful if OPM reviewed  agencies’ year-to-year data and followed up on any unexpected or large  changes. For example, OPM did not contact Education to clarify why its  overall telework participation goal dropped from 85 percent to 5 percent.  Had OPM done so, Education officials could have clarified their response.  We have previously found that OPM may be missing opportunities to  improve upon data it reports by not following up with agencies on data  differences.
OPM officials, however, said that they do some data verification, but that  they rely on the agencies to submit the correct data compliant with OPM’s  data standards. OPM holds training sessions for each data call to answer  questions telework officials may have about completing the data call.  OPM officials also said that given the sheer volume of data that they  receive, it is unrealistic for OPM to catch all reporting errors. However,  given that OPM has aggregated data call responses into spreadsheets, it  would be feasible to automate some comparisons of numeric data across  these spreadsheets to identify changes in year-to-year data, and follow  up with agencies on changes above a given threshold.
We also identified instances where the agencies failed to properly report  data on telework eligibility. For example, in the 2014 report, Labor  reported the number of individuals eligible to participate in telework as  higher than the number of total employees for several subagencies, with  the difference sometimes as high as 32 percent. Labor officials explained  that at the time of the 2013 data call—which provided the data used in the  2014 report—they counted the number of positions eligible to telework,  regardless of whether the positions were filled or not. This resulted in  some subagencies reporting a higher number of eligible teleworkers than  total employees. Labor officials said they have since changed the way  they count the number of individuals eligible to telework. They included  this adjusted methodology when providing data for the 2016 report.
In the 2014 report, Education also reported the number of individuals  eligible to participate in telework as higher than the number of total  employees for several of its offices. According to Education officials, they  last determined telework eligibility by position in 2011 and have reported  the same number of eligible positions for all data calls since, including in  the 2016 report. Education officials said that they interpreted the  instruction on the data call as allowing for such static data reporting. OPM  officials said that for the 2016 report they systematically compared the  reported number of employees, eligible employees, and teleworking  employees to identify situations in which the number of eligible  employees exceeded the number of employees or when the number of  teleworkers exceeded the number of eligible employees. They then  contacted every agency where they found inconsistent data, including  Education. According to OPM officials, they discussed with Education  officials OPM’s expectation that agencies update their eligibility records  regularly. However, OPM officials said they deferred to Education’s  decision regarding what eligibility information it wanted to provide and  published Education’s static eligibility data despite the accuracy issues  identified.
Agencies reporting on position eligibility and not individual eligibility  overstate telework eligibility. As a result, they also understate other data  points calculated from eligibility data, such as total participation rates.  Further, the methodology of counting eligible positions does not take into  account the additional telework eligibility requirements of the act at the  individual level, such as personal conduct and performance history.  Accounting for these requirements may further reduce the total number of  employees eligible for telework. The methodology Education officials  described using for counting and reporting eligibility indicates that the  data Education has been reporting to OPM do not comply with the act.
In the 2016 report, OPM recognized that some agencies have not  revisited eligibility determinations since early implementation of telework.  However, it concluded that this may result in agencies understating, not  overstating, eligibility because more individuals may become eligible as  agency telework policies and capacities expand. OPM officials said this is  a reasonable conclusion because as agency telework programs mature,  more individuals should become eligible. Furthermore, Federal Employee  Viewpoint Survey data show that both self-reported eligibility and telework  participation have been increasing over time. The version of the 2016  report issued to Congress in September 2016 did not explain why some  agencies report a higher number of eligible employees than total  employees. However, OPM included some discussion of this data  discrepancy in an updated version of the report posted on  www.telework.gov in November 2016.
Agencies are responsible for providing OPM with telework data that  comply with OPM’s data standards, but OPM’s responsibility for reporting  telework data annually is not limited to aggregating and reporting data  directly from agencies without verifying its reliability. Consistent with  federal internal control standards, OPM is responsible for taking  reasonable measures to help ensure the accuracy of the information it  reports and, where necessary, indicating in the report where data may be  of questionable accuracy. Although OPM has taken some steps over  the years to improve the accuracy of the telework data it reports, in  reviewing OPM’s two most recent telework reports we found that the  report included some inaccurate data for two of our four case study  agencies. Without clear and accurate data in these annual reports,  Congress does not have all of the information necessary to conduct its  oversight work and federal agencies and other users of the report do not  have an accurate picture of how telework is working across the federal  government.
section_title: OPM’s Plans to Report Telework Data from the Enterprise Human Resources Integration System May Improve Data Consistency
paragraphs: In an August 11, 2016, memorandum, OPM announced to CHCOs and  TMOs that it will begin using telework data in the EHRI system to  automate the telework data collection process. OPM plans to use these  data to meet the act’s annual reporting requirements to Congress, and to  analyze cross-agency telework data to demonstrate links between  telework and agency outcomes. While this will not eliminate the annual  telework data call, according to the memorandum, it will reduce the  manual reporting burden for agencies. OPM stated that it will continue to  administer an annual data call to collect telework program information not  available in EHRI, such as agency progress towards reaching telework  goals and best practices for telework programs.
Although we have previously reported that EHRI data are sometimes  incomplete or inaccurate, using these data could be helpful in identifying  and addressing data quality issues. Further, OPM officials told us there  are known problems with some telework data because agencies vary in  how they report them. To address these limitations and help ensure  agencies are following data standards, OPM set a timeline for testing and  assessing the accuracy of telework data in EHRI over the course of fiscal  year 2017. This process includes as a first step having agency TMOs and  human resources staff examine telework data pulled from EHRI for one  pay period to assess the accuracy of the data and determine any  potential issues affecting data accuracy. OPM then plans to hold a series  of meetings with agency TMOs, human resources directors, and payroll  providers to discuss the steps and assistance needed to ensure telework  data in EHRI are reported accurately. OPM officials said they plan to  pursue an iterative process with agencies to verify the accuracy of  telework data in EHRI.
OPM’s plan to use EHRI data for future telework data reporting is a  positive step toward improving the accuracy of telework data and OPM’s  ability to compare data year to year. For prior data calls, agencies  supplied telework data from their own systems, which may have differed  from data reported to EHRI. OPM officials told us they were unsure how  much, if at all, agencies were adjusting their telework data across various  data sources before responding to data calls. OPM did not compare these  data to payroll data aggregated in EHRI because, according to OPM  officials, doing so would have been inappropriate given the known  limitations of the EHRI data at the time. According to OPM officials,  reporting telework data directly from EHRI going forward will reinforce to  agencies the importance of recording and certifying telework data  regularly through payroll reporting. Further, reporting data consistently  from one source for all agencies will allow the federal government to  compare telework data more consistently across agencies and across  years.
section_title: Conclusions
paragraphs: Telework is an important tool agencies can use to realize benefits for both  themselves and their employees. As technology and the nature of work in  the federal government evolve, incorporating telework into agency  operations and expanding telework participation could help agencies  continue normal operations during adverse weather or other COOP  events, as well as attract and retain employees. But to have a telework  program that can achieve these benefits and comply with the act’s  requirements, the four case study agencies we reviewed must ensure that  their telework policies, procedures, and other controls are implemented  appropriately, and that the technology needed for employees to telework  functions as it should. Documenting that those responsible for  implementing agency telework policy are trained before doing so and  reviewing telework agreements regularly can help these agencies ensure  that they are applying their telework policies consistently, and improve  telework data accuracy. Identifying pain points for teleworkers can also  help agencies prioritize ways to improve and investments in their  programs.
Because telework data are used across the government, such as by  Congress for oversight, and by agencies for decision-making purposes,  the four agencies and OPM need to ensure that the data they report  accurately reflect the status of telework at federal agencies. Reporting  and using data that either do not comply with the act or are known to be  of questionable quality compromises these agencies’ abilities to  effectively manage their telework programs, and limits the usefulness of  OPM’s annual reports to Congress. OPM’s plans to use data in EHRI and  a shorter data call instrument could improve telework data accuracy.  However, OPM and agencies must also take steps to help ensure that  these annual reports include only accurate data or clearly explain why this  is not possible.
section_title: Recommendations for Executive Action
paragraphs: To support the consistent application of agency telework policy  throughout the agency, the Secretaries of the Departments of Education  and Labor and the Chair of the Securities and Exchange Commission  should implement controls to verify that supervisors have completed  telework training prior to entering into telework agreements with their  employees and that completion of this training is documented.
To help ensure that telework agreements accurately reflect telework  participation, and to further ensure the accuracy of telework data reported  internally and externally, the Secretary of the Department of Labor, the  Administrator of the General Services Administration, and the Chair of the  Securities and Exchange Commission should require documentation of  regular or periodic reviews of all telework agreements in agency telework  policies.
To improve the accuracy of telework data transmitted to OPM, the  Secretary of the Department of Labor should direct the Chief Human  Capital Officer to work with the Telework Managing Officer to develop and  implement a plan to modernize Labor’s telework agreement tracking  system to enable more timely access to accurate telework data.
To help ensure the employee eligibility data transmitted to OPM comport  with what OPM is required to report under the Telework Enhancement Act  of 2010 and accurately reflect the current number of employees eligible to  telework, the Secretary of the Department of Education should direct the  Telework Managing Officer to take the steps necessary to regularly  update employees’ eligibility status.
To provide additional guidance to agencies and encourage the elimination  of barriers to increased telework opportunities consistent with the act, and  to ensure the accuracy of telework information OPM annually reports to  Congress, the Director of OPM should: develop tools to help agencies assess and analyze persistent barriers  to telework, including managerial resistance, such as a survey or  other feedback mechanism; and  strengthen controls for reviewing, validating, and reporting telework  data in annual Status of Telework in the Federal Government reports.  Specifically, OPM should follow up with agency officials on data  outliers, including significant changes in year-to-year data.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to Education, GSA, Labor, SEC, and  OPM for review and comment. We received written comments from  Education, GSA, SEC, and OPM which are reprinted in appendixes II, III,  IV and V, respectively. Education, Labor, and OPM also provided  technical comments, which we incorporated into the report as  appropriate. Labor also commented on the recommendations addressed  to it, which we summarize and discuss below.
Education, GSA, and SEC agreed with the recommendations in our  report. GSA and SEC stated they are making changes to require a  periodic and documented review of telework agreements. Education and  SEC stated they will implement controls to help ensure supervisors  complete telework training before entering into telework agreements with  employees. Education also agreed to take steps necessary to regularly  update employees’ eligibility status and report data that meet the criteria  in the act.
Labor neither agreed nor disagreed with our recommendations but  provided comments on the report’s recommendations. Labor stated that  budgetary constraints have prevented it from employing an automated  telework agreement system, as we noted in the report. We recognize this  in our recommendation by stating Labor should modernize its telework  agreement tracking system to allow for more timely access to accurate  data, which can include changes other than implementing an automated  system. Labor also stated that it has controls to monitor manager  telework training and telework agreement review. We agree that Labor  takes steps to monitor manager training and has a process for regularly  reviewing telework agreements. However, these processes could be  strengthened by requiring additional documentation.
OPM did not concur with the two recommendations directed to it. For the  first recommendation on creating tools to help agencies assess and  analyze persistent barriers to telework, OPM agreed with our assessment  of the value of such tools and their ability to help agencies increase  participation rates. However, OPM stated it has fulfilled its responsibilities  under the act through training, policy guidance, and tools for program  evaluation and management, and that, given limited resources, it is not in  a position to expand upon materials and tools for an area not required by  the act. We agree that OPM has provided resources to agencies to help  identify barriers to telework and are encouraged that it is developing  additional tools. However, we disagree with OPM’s assertion that  developing tools to address persistent barriers is not related to internal  controls. Federal internal control standards state that to help ensure an  agency is meeting its objectives management should identify, analyze,  and respond to risks related to achieving objectives, such as by  addressing deviations from established policies. Barriers to telework  reflect a risk to an agency’s ability to meet the goals they have  established for increasing telework participation, as directed in the act.  And as noted in our report, some managers’ decisions to limit or deny  employees’ ability to telework may be for reasons other than those  outlined in the agencies’ policies, suggesting deviations from established  policy that should be addressed. Because agencies and OPM continue to  identify persistent barriers to telework participation, as did responses in  our focus groups and discussions with agency officials, we continue to  believe that OPM should play a key role in aiding agencies in assessing  and analyzing, not just identifying, barriers to telework participation.
For the second recommendation, OPM said it recognizes the importance  of data accuracy and states it takes reasonable steps to follow up with  agencies to resolve possible reporting errors, but that agencies are  ultimately responsible for providing complete and accurate data. OPM  further states that the act does not obligate OPM to spend significant  resources to independently validate agency telework data. We agree that  OPM should not independently validate agency data, but OPM should  take the steps necessary to identify and explain data outliers and  limitations. Because OPM is the agency responsible for reporting telework  data, OPM should ensure its annual reports to Congress include a clear  discussion of data reliability limitations, as we have previously  recommended. Following up on data outliers and large year-to-year  changes can help OPM identify data errors that could be corrected by  agencies and provide OPM with the opportunity to discuss data limitations  with agencies. Including such information clearly in the annual telework  reports to Congress can make them more useful to Congress and to  others.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to OPM,  Education, GSA, Labor, and SEC as well as to interested congressional  committees and other interested parties. In addition, this report is  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-6806 or at jonesy@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix VI.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report identifies and examines (1) how selected agencies establish  and monitor telework eligibility and participation, and comply with the  requirements of and expectations included in telework agreements; (2)  the internal controls and practices at selected agencies that affect  supervisors’ abilities to manage for results in the telework environment,  and hold employees who routinely telework accountable for achieving  results; and (3) the challenges selected agencies and the Office of  Personnel Management (OPM) face in collecting and reporting telework  data.
To address these objectives, we reviewed and used as criteria the  Telework Enhancement Act of 2010 (the act), Standards for Internal  Control in the Federal Government, OPM’s guidance and training on  telework and performance management, and our prior work on agency  telework programs. We also interviewed key OPM officials from  Employee Services and Senior Executive Service and Performance  Management as well as the Executive Director of the Chief Human  Capital Officers (CHCO) Council.
To address all of our objectives, we selected the Department of Education  (Education), General Services Administration (GSA), the Department of  Labor (Labor), and the Securities and Exchange Commission (SEC) as  case study agencies for our review. Because a case study approach does  not allow for generalizable results, we limited our case study agencies to  four to compare telework programs across agencies of varying sizes. We  selected these agencies using size and telework participation rates as  criteria. We reviewed OPM’s 2014 Status of Telework in the Federal  Government Report to Congress (Fiscal Year 2013) and created a list of  all of the agencies that reported telework data that year. To ensure that  our case study agencies would have a sufficient number of active  teleworkers, we limited this list to agencies with more than 2,500  employees. Using data from OPM’s report, the most recent available at  the time of our analysis, we compiled a list containing data on each  agency’s number of employees, number of employees eligible to  telework, number of employees with telework agreements, percentage of  employees with telework agreements, and percentage of employees who  teleworked in fiscal year 2013. We also reviewed data from the 2015  Federal Employee Viewpoint Survey (FEVS), the most recent data  available at the time of our analysis, and incorporated data on telework  frequency rates into our list of agencies. After building this universe of  agencies and their associated telework data, we applied 3 filters to the  list: agencies where the percent of employees eligible to telework is  greater than or equal to 50 percent;  the percent of eligible employees with telework agreements is greater  than or equal to 50 percent; and  the percent of employees teleworking at least once per week is  greater than or equal to 25 percent.
These filters produced a list of seven agencies. To compare and contrast  telework programs of different sizes, we divided the remaining agencies  into 2 groups: 1 of agencies with more than 10,000 employees and the  other with fewer than 10,000 employees. We eliminated one large agency  because it was negotiating its telework program with relevant labor  unions, and had been the subject of recent reports on telework internal  controls. For the smaller agencies, we rank ordered the agencies by the  number of teleworkers as of February 2014, the most recent data  available across the agencies. These filters produced GSA and Labor as  the large agencies, and Education and SEC as the smaller agencies for  inclusion as our case study agencies.
To address all of our objectives, we conducted a series of focus groups at  our four case study agencies with groups of supervisors of teleworkers  and groups of teleworkers. When discussing these focus groups  throughout the report, we use the word some to mean more than two but  fewer than six focus groups. To determine supervisor focus group  participants, the agencies sent us lists of all supervisors and the agency,  office, or division where they worked. We randomized the list using a  random number generator and sorted the list in rank order. To avoid  inviting individuals who work closely with each other to the focus groups,  we chose from the list the first individual from each agency, office, or  division, and created a list of alternates in the event the first individual  could not participate. We then confirmed with the agencies that these  supervisors on our invite and alternates lists met the following criteria: (1)  they were not senior executives and (2) they supervised at least one  employee with a regular telework agreement. We sent invitations to  participate in the focus groups to the first 10 individuals who met our  criteria. We then invited alternates for individuals who could not attend.  Each focus group had between 6 and 8 participants.
To determine focus group participants for teleworkers, agencies sent us  lists of employees, which included, at a minimum, the employee’s name,  location, and whether they had a telework agreement. To ensure we  could gather information from nonsupervisory employees, we removed  from the lists, as necessary, any individuals who were supervisors or  otherwise not covered by a collective bargaining unit. We also excluded  individuals from the Offices of Inspector General. We additionally  excluded individuals with only a situational telework agreement. We  randomized the list using a random number generator and sorted the lists  in rank order. Similar to supervisors, to avoid inviting individuals who work  closely together, we chose from the list the first individual from each  agency, office, or division. Also, to determine if employees similarly  experienced telework in the field as in headquarters, we created two lists  of potential focus group participants—one for employees who work in  Washington, D.C., and one for employees who work in a regional or field  office. For field employees, we chose the first individual from each  location from the ranked list to participate. Because telework experiences  can be influenced by an employee’s supervisor, we then requested from  the agencies the name of the supervisor for those on our preliminary  invitation list, and eliminated individuals from the invitation list if someone  higher on the list worked for the same supervisor. For Education, Labor,  and SEC, we held two focus groups for teleworkers, each with between  four and six participants. For GSA, due to scheduling difficulties, we held  one combined focus group of seven teleworkers from headquarters and  the field.
To determine how case study agencies establish and monitor telework  eligibility and compliance with requirements and expectations of telework  agreements, we reviewed the act, OPM guidance, telework policies,  telework training materials, blank telework agreements, and collective  bargaining agreements. We interviewed agency officials responsible for  telework policy and program implementation, including the Telework  Managing Officer or the telework coordinator, to discuss telework policy,  program implementation, internal controls, and OPM guidance on  telework. We then compared agency policies to act requirements, OPM  guidance, and Standards for Internal Control in the Federal Government  to assess compliance. We discussed telework eligibility and notification at  our focus groups with teleworkers and discussed reasons for denying  telework agreement applications with supervisors. We also interviewed  OPM officials about OPM’s role in providing telework guidance to federal  agencies.
To determine how supervisors at case study agencies manage for results  in a telework environment and hold employees who routinely telework  accountable for achieving results, we reviewed requirements of the act  and agency policies, reviewed OPM and agency specific training  materials on telework and performance management, and discussed  agency performance management policy with case study agency officials.  We also asked supervisors participating in our focus groups what  strategies and resources they use to manage their teleworking  employees, and what steps they take to help ensure telework does not  diminish their employees’ performance. We asked participants at our  teleworkers focus groups about how telework has affected their ability to  meet performance goals, how their supervisor holds them accountable for  achieving results while teleworking, and how the agency supports  telework. We also spoke with representatives from the unions that  represent employees at the four case study agencies to discuss any  concerns the unions have heard about telework.
To assess the challenges the four case study agencies and OPM face in  collecting and reporting telework data, we reviewed our prior work on  OPM telework data reporting. We also reviewed OPM’s Status of  Telework in the Federal Government Report to Congress (Fiscal Year  2013) and OPM’s Status of Telework in the Federal Government Report  to Congress (Fiscal Years 2014 and 2015). We requested case study  agencies’ original telework data call submissions to OPM for fiscal years  2013, 2014, and 2015, and compared these data to what OPM included  in the final reports to Congress to identify any discrepancies. To report  data on numbers of teleworkers and the average number of hours  employees telework per pay period, we analyzed telework data from each  of the case study agencies. We reviewed the data for outliers, reviewed  agency documentation on how the agencies enter and maintain telework  data, and interviewed agency officials. We determined these data to be  reliable for the purposes of reporting reported telework hours and the  number of individuals teleworking for a 9-month period between  September 2015 and June 2016. We interviewed OPM and case study  agency officials about the steps they take to collect, validate, and report  telework data, and any challenges they may face in doing so. We also  asked teleworkers in our focus groups how they record their telework  hours. In addition, we asked supervisors what challenges they may face  to ensuring these telework hours are recorded and reported accurately.
We conducted this performance audit from November 2015 to February  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Education
section_title: Appendix III: Comments from the General Services Administration
section_title: Appendix IV: Comments from the Securities and Exchange Commission
section_title: Appendix V: Comments from the Office of Personnel Management
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Chelsa Gurkin (Assistant  Director), Miranda Cohen, Ann Czapiewski, Karin Fangman, Cheryl L.  Jones, Danielle Novak, Steven R. Putansu, and Stewart W. Small made  key contributions to this report.