Human Capital: Further Guidance, Assistance, and Coordination Can Improve Federal Telework Efforts
Published: 2003-07-18T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Telework--work done at a location other than a traditional office--has gained widespread attention over the past decade as a human capital flexibility offering various potential benefits to employers, employees, and society. Using such flexibilities as management tools can help the federal government address its human capital challenges. GAO did this study in response to a congressional request to assess the federal government's progress in implementing telework programs and to determine what else can be done to give federal employees the ability to telework under appropriate circumstances.
section_title: What GAO Found
paragraphs: The statutory framework for federal telework requires agencies to take certain actions related to telework, provides agencies with tools for supporting telework, and provides both the Office of Personnel Management (OPM) and the General Services Administration (GSA) with lead roles and shared responsibilities for the federal telework initiative. Both agencies offer services and resources to support and encourage telework in the federal government. However, these agencies have not fully coordinated their telework efforts and have had difficulty in resolving their conflicting views on telework-related matters. As a consequence, agencies have not received consistent, inclusive, unambiguous support and guidance related to telework. After we discussed the issues created by the lack of coordination between GSA and OPM with both agencies, a GSA official then indicated that GSA and OPM expressed a new commitment to coordination. Such a commitment reflects a promising start for better assisting federal agencies in improved implementation of their telework programs. However, the key to success will be sustained efforts by both agencies to work together in assisting agencies and providing consistent and straightforward guidance, services, and resources on the governmentwide telework initiative. GAO identified 25 key practices in telework-related literature and guidelines as those that federal agencies should implement in developing telework programs and grouped these practices under seven categories. While the four selected executive agencies we reviewed--the Department of Education (Education), GSA, OPM, and the Department of Veterans Affairs (VA)--have taken at least some steps to implement most of the key practices, only 7 of the 25 key practices, such as establishing a cross-functional project team and establishing an agencywide telework policy, had been fully implemented by all four agencies. Although some telework-related resources from GSA and OPM provide federal agencies with information on how to implement several of the key practices we identified, agencies may need additional guidance, guidelines, and/or individualized technical support to fully implement these practices.

section_title: Letter
paragraphs: Telework, also referred to as telecommuting or flexiplace, has gained  widespread attention over the past decade in both the public and private  sectors as a human capital flexibility that offers a variety of potential  benefits to employers, employees, and society.1,   The term telework refers  to work that is performed at an employee’s home or at a work location  other than a traditional office.  Using such readily available flexibilities as  management tools is critical to addressing the federal government’s human  capital challenges.  In the Office of Personnel Management’s (OPM) 2003  report to Congress on the status of telework in the federal government, the  Director of OPM described telework as “an invaluable management tool  which not only allows employees greater flexibility to balance their  personal and professional duties, but also allows both management and  employees to cope with the uncertainties of potential disruptions in the  workplace, including terrorist threats.”
Throughout this report, the terms telework, telecommuting, and flexiplace are used  interchangeably. which selected federal agencies are implementing key practices in  developing telecommuting programs, and (4) identify additional  governmentwide actions that could be taken to encourage federal agencies  to increase telecommuting participation.
We took several steps to address these objectives.  In order to characterize  the federal laws and their requirements that currently apply to  telecommuting within the federal agencies in the executive branch, we  identified and analyzed the relevant laws and discussed the requirements of  selected laws with agency officials.  To determine what GSA and OPM are  doing to coordinate and promote telecommuting in the federal government,  we interviewed GSA and OPM officials regarding their governmentwide  telework efforts and analyzed documents related to these efforts.  We  determined the extent to which selected federal agencies are implementing  key practices in developing telecommuting programs by first conducting a  review of literature and guidelines to identify these practices.  Then, we  interviewed agency officials and analyzed documents related to telework  implementation at four agencies—the Department of Education  (Education), the Department of Veterans Affairs (VA), GSA, and OPM.   These agencies were selected for various reasons, including function, size,  and reported level of telework participation.  This agency selection  process was not designed to produce findings that could be considered  representative of telework implementation in the federal government as a  whole, but rather to provide illustrative examples of the extent to which  selected individual agencies had used the key practices identified in our  literature review.  To identify additional governmentwide actions that could  be taken to encourage federal agencies to increase telecommuting  participation, we interviewed officials and union representatives from the  four selected agencies, as well as other unions representing federal  employees.  Our review was conducted in accordance with generally  accepted government auditing standards.  (See app. I for additional  information on our scope and methodology.)
subsections: section_title: Background
paragraphs: Over the last decade, telework has emerged as a management tool in the  federal government.  Congress and the executive branch have shown  interest in telework, primarily based upon the belief that its use will benefit  the federal government.  Benefits of telework include reducing traffic  congestion and pollution, improving recruitment and retention of  employees, increasing productivity, and reducing the need for office space.   Employees also can realize benefits from teleworking, including reduced  commuting time; lowered costs in areas such as transportation, parking,  food, and wardrobe; removal of barriers for those with disabilities who  want to be part of the workforce; and improvement in the quality of  worklife and morale accruing from the opportunity to better balance work  and family demands.  Guidance issued by the Federal Emergency  Management Agency, along with telework-related literature, also suggests  that telework programs can facilitate emergency preparedness by helping  agencies to maintain continuity of operations in emergency situations,  thereby increasing agencies’ effectiveness.  In light of the uncertainties  facing the United States today, telework can be a particularly relevant and  useful tool.
The importance of telework to federal employees has been highlighted in  recent studies.  Based on its 2000 Merit Principles Survey, the U.S. Merit  Systems Protection Board (MSPB) reported that, of all the family-friendly  programs studied, telework showed the greatest disparity between  importance and availability, potentially making it the most desired but least  available family-friendly program.  In addition, the MSPB said that, of all  the work-life programs it asked about in the survey, only telework  appeared to have a relationship to employees’ intentions regarding leaving  their employment in the coming year, with those who considered telework  important being more likely to plan to leave when it is not available (55  percent) than when it is available (44 percent).  According to OPM’s 2002  Federal Human Capital Survey, almost 74 percent of federal employee  respondents said that telework was at least somewhat important to them.
Despite this level of importance, more than 59 percent of the respondents  reported that this flexibility was not available to them.
Since 1990, Congress has supported the telework initiative by holding  hearings and passing a number of laws related to telework, including laws  that provided for the establishment and funding of the GSA telework  centers.  Most significant was the Department of Transportation and  Related Agencies Appropriations Act, 2001, Pub. L. No. 106-346, October  23, 2000.  Section 359 of this law provides the current mandate for telework  in the executive branch of the federal government.  This law, which was to  be implemented in 25 percent increments over 4 years, required each  federal agency to “establish a policy under which eligible employees of the  agency may participate in telecommuting to the maximum extent possible  without diminished employee performance” and instructed OPM to provide  for the law’s requirements to be met.
Telework has also received significant attention in the executive branch  since 1990, when the President’s Council on Management Improvement  approved plans for the implementation of a governmentwide pilot  flexiplace program.  In the executive branch, telework has been proposed  as a tool to address a number of issues, including establishing a family- friendly workplace, reducing traffic congestion and pollution, and enabling  people with disabilities to join the federal workforce.  Currently, GSA and  OPM share responsibilities for the federal government’s telework initiative,  providing federal agencies with services and resources related to this  initiative.  To this end, both GSA and OPM have included strategies, goals,  and measures directly related to their efforts to support the  governmentwide telework initiative in their fiscal year 2003 annual  performance plans and their related strategic plans.  For example, GSA’s  fiscal year 2003 performance plan includes a goal to increase the  percentage of federal employees that telework to 5 percent by the end of  fiscal year 2003 under its performance goal to increase the number of  agency programs meeting their social and environmental responsibilities in  areas of GSA’s Office of Governmentwide Policy responsibility.
Also among efforts in the executive branch was the formation of an  Interagency Telework Issues Working Group, with participants from 15  federal agencies.  GSA and OPM jointly established and led this group,  which canvassed agencies to identify policy actions needed to facilitate  agency use and expansion of telework.  A final report, issued in August  2002, contained a series of recommendations related to such policy  actions.
Interest in and implementation of telework programs has also occurred in  states and foreign countries.  Several states piloted telework programs in  state government agencies in the mid- to late 1990s and have since  implemented telework in individual agencies or on a statewide basis.  For  example, in Florida, telework became a permanent option for state  employees in October 1998 after two 3-year pilot studies.  In Europe, about  6 percent of the workforce was teleworking as of 1999 and, in some  countries, the participation rate for telework was higher.  Finland, for  example, had a telework participation rate of about 17 percent of the  workforce in 1999.  However, only 4 percent of all teleworkers in European  countries worked for government entities.
According to OPM’s January 2003 report to Congress on the status of  telework in the federal government, 77 executive agencies reported that, as  of November 2002, 90,010 of their employees teleworked on either a regular  or episodic basis, which is 5 percent of those agencies’ 1,806,192  employees.  The U.S. Department of Labor reported that, in May 2001, 19.8  million persons, accounting for 15 percent of total employment, usually did  some work at home as part of their job.  However, only 17 percent of these  workers had a formal arrangement with their employer to be paid for the  work they did at home.
section_title: Federal Laws and Their Requirements Cover a Gamut of Telework Issues
paragraphs: Legislation related to telework began to emerge from Congress in 1990.   Since then, these provisions have typically, but not always, been included  in a variety of appropriations acts and have covered a wide range of issues  related to telework.  The statutory framework for telework includes  provisions that require agencies to take certain actions related to telework,  provide agencies with tools for supporting telework, and provide both GSA  and OPM with lead roles in the implementation of telework in the federal  government.
Within this framework, the most significant congressional action was the  enactment of Section 359 of Pub. L. No. 106-346 in October 2000, which  provides the current mandate for telecommuting in the executive branch of  the federal government.  This law, for the first time, required each  executive branch agency to establish a telework policy “under which  eligible employees of the agency may participate in telecommuting to the  maximum extent possible without diminished employee performance.”  It  also directed OPM to provide that the law’s requirements were applied to  25 percent of the federal workforce by April 2001 and to an additional 25  percent of the federal workforce in each subsequent year, until 2004 when  the law is to be applied to 100 percent of the federal workforce.  The  requirements of this law should also be considered in combination with its  conference report and guidance that has been issued by OPM.
The conference report accompanying Pub. L. No. 106-346 stated that  agencies shall “develop criteria to be used in implementing [a  telecommuting] policy” and “ensure that managerial, logistical,  organizational, or other barriers to full implementation and successful  functioning of the policy are removed.”  Furthermore, it stated that  agencies “should also provide for adequate administrative, human  resources, technical, and logistical support for carrying out the policy.”  It  also clarified what constitutes eligibility for telework by defining an eligible  employee as “any satisfactorily performing employee of the agency whose  job may typically be performed at least one day per week [by  telecommuting].”
On February 9, 2001, OPM sent a memorandum to department and agency  heads containing guidance on the requirements of Pub. L. No. 106-346 that  directed agencies to examine the barriers that inhibit the use of  telecommuting, act to remove them, and increase participation.  This  memorandum went on to say, “The law recognizes that not all positions are  appropriate for telecommuting; therefore, each agency must identify  positions that are appropriate in a manner that focuses on broad objective  criteria.  Once an agency has established eligibility criteria, subject to any  applicable agency policies or bargaining obligations, employees who meet  them and want to participate must be allowed that opportunity if they are  satisfactory performers.”  OPM recently clarified this statement in a  publication entitled, Telework: A Management Priority—A Guide for  Managers, Supervisors, and Telework Coordinators.  This guide, which  was released on May 8, 2003, indicates that agencies should offer eligible  employees the opportunity to telework by having supervisors extend the  option of teleworking to all employees they determine are eligible, using  established criteria.
Congress also passed other laws that require agencies to take certain  actions related to telework.  One such provision requires executive  agencies to consider whether needs for additional space can be met using  alternative workplace arrangements, such as telework.  Another recent  provision, contained in the fiscal year 2003 appropriations for the  Departments of Commerce, Justice, and State, the Judiciary, and the Small  Business Administration, makes $100,000 available to each of the  departments and agencies covered by this provision only for the  implementation of telecommuting programs.  These departments and  agencies are required to provide the committees on appropriations with a  report on the status of their telecommuting programs every 6 months and  to designate a “Telework Coordinator” to oversee the implementation of  telecommuting programs.
In addition to these provisions, another provision directs executive  agencies to make a minimum of $50,000 available annually for the  necessary expenses to carry out telecommuting programs, which would  permit employees of 20 specified federal departments and agencies,  including Education, GSA, OPM, VA, the Department of the Interior (DOI),  and the Department of Energy (DOE), to perform all or a portion of their  duties at GSA telework centers.  However, a provision has been included  in the appropriations acts for DOI and related agencies since fiscal year  2001 prohibiting several departments and agencies, including DOI and  DOE, from using appropriated funds for the use of “GSA  telecommunication centers.”  GSA officials believe that the provisions  contained in these appropriations laws were intended to apply to GSA  telework centers.  However, this remains unclear, because these statutes  pertain to “GSA telecommunication centers,” which is not a title by which  the GSA telework centers are known.  At least in some instances, though,  this provision has not been applied to the telework centers.  OPM’s January  2003 report to Congress identified two of the agencies prohibited from  using funds as described by this provision—DOI and DOE—as having  provided funds for telework center usage fees in fiscal year 2002.
Generally, when statutory provisions in separate laws are in conflict, as  may be the case with the laws detailed above, the requirements of the most  recently passed law supercede the requirements of the earlier law.  In this  case, the provision prohibiting the use of funds for “GSA  telecommunication centers” would take precedence over the provision that  requires specified agencies to make $50,000 available annually for use of  the GSA telework centers, but only for those departments or agencies that  are common to both provisions.  However, because of the lack of a  definition or explanation for “GSA telecommunication centers” in the  appropriations law and the fact that the legislative history does not provide  any insight, it is not clear whether the provisions are in conflict.  Given that  both of these provisions refer to one or more types of GSA operations, GSA  should work with Congress to determine what was meant by the phrase  “GSA telecommunication centers” and then issue guidance to the relevant  agencies to clarify these provisions and explain the impact of these laws on  agencies’ telework programs.
Congress has also provided agencies with several tools to support  telework.  For example, federal agencies were authorized to spend money  for installation of telephone lines, related equipment, and monthly charges  for federal teleworkers through legislation that was originally enacted in  1990 and made permanent in 1995.  In 1992, Congress established the first  federal telework centers, which were to be maintained by GSA.  Since  then, Congress has passed several laws to continue funding the centers,  change the formula for funding the centers, and add new telework center  locations.
The legislative framework for telework also contains provisions that  provide both GSA and OPM with lead roles in the implementation of  telework in the federal government.  As stated above, Pub. L. No. 106-346  directs OPM to provide that the requirements of the law are applied as  specified with regard to the federal workforce.  In addition, $500,000 of the  money appropriated for OPM’s salaries and expenses for fiscal year 2003 is  intended to be used by OPM to provide a telecommuting training program  to educate managers in executive branch agencies, where less than 2  percent of employees telework, about the benefits and logistics of  telework.  According to OPM’s comments on a draft of this report, the  agency plans to conduct focus groups for managers in four locations across  the country this summer to identify reasons why some managers resist  permitting telework.  OPM plans to use the focus group data to tailor  agency telework training.  OPM indicated that it plans to train agencies’  human resources directors and telework coordinators and provide them  promotional telework materials.  Congress has also provided GSA with a  lead role in the federal government’s telework initiative, giving the agency  responsibility for maintaining the federal telework centers and the  authority to provide guidance, assistance, and oversight regarding the  establishment and operation of telework and other distributive work  arrangements.
section_title: Lack of Clarity in OPM Guidance Led to Misleading Telework Data, but OPM Has Recently Taken Steps to Address This Issue
paragraphs: Until recently, OPM had not defined a statement contained in its February  2001 guidance regarding the implementation of Pub. L. No. 106-346, which  told agencies that employees who wanted to participate in teleworking  must be allowed that opportunity.  Without such a definition, we found that  the agencies we reviewed did not use equivalent interpretations of this  statement, resulting in their reporting incomparable data to OPM.  These  data were subsequently included in OPM’s 2003 report to Congress on the  status of telework in the federal government.  After we discussed this issue  with OPM officials, OPM reacted promptly by issuing new guidelines that  defined what it meant by allowing this opportunity.
Our discussions with officials at the four agencies we reviewed and  analysis of data in OPM’s January 2003 report to Congress revealed that,  without a definition from OPM regarding what constituted being allowed  the opportunity to telework, agencies had not always used equivalent  interpretations of this statement in reporting their data.  For example,  telework program officials at both GSA and OPM told us that, for their  internal programs, they considered eligible employees to have been  allowed the opportunity to telework if they chose to apply for telework or  discuss the option of teleworking with their managers, regardless of  whether they were actually approved for telework.  In keeping with this  interpretation, these two agencies reported, in response to OPM’s 2002  governmentwide telework survey, that essentially the same number of  employees who were eligible for telework had also been given that  opportunity.  On the other hand, Education and VA reported significant  differences between the number of employees who were eligible for  telework and those who were given the opportunity to telework, which  demonstrated that they were using different interpretations of opportunity  than GSA and OPM.  Because these agencies were not applying equivalent  interpretations of the term “opportunity,” the data that they provided in  response to OPM’s survey and that OPM included in its report to Congress  were not comparable across agencies.  Moreover, OPM’s 2003 report to  Congress showed these data as the number of eligible employees “offered”  telework, although OPM had not made it clear, in either the survey or in its  previously issued guidance, that agencies should interpret allowing the  opportunity to mean directly offering eligible employees the option to  telework.  Furthermore, characterizing all agencies’ data in this manner is  misleading because, as shown above, some agencies did not use that  interpretation in reporting the data.
We met with OPM officials in late April 2003 and informed them that the  lack of a written definition of what OPM meant when it asked agencies to  report how many eligible employees had been allowed the opportunity to  telework had resulted in incomparable telework data.  To its credit, OPM  reacted promptly by defining the statement in a set of frequently asked  questions that were distributed at its quarterly telework coordinators’  meeting on May 6, 2003, and in a new telework guide for managers,  supervisors, and telework coordinators that was released 2 days later.   Both the frequently asked questions and the guide indicate that agencies  should offer eligible employees the opportunity to telework by having  supervisors extend the option of teleworking to all employees they  determine are eligible, using established criteria.  To ensure that the  information contained in the guide reaches all federal telework  coordinators, an OPM official said that a hard copy of this guide would be  mailed to each coordinator.  In addition, the guide has been posted at  www.telework.gov.
OPM also further clarified the statement about allowing eligible employees  an opportunity to telework by including a definition in the draft survey it  plans to send to agencies in the fall to obtain data for its January 2004  status report to Congress.  Immediately following our meeting with OPM  officials, this draft survey was distributed at OPM’s May 2003 quarterly  telework coordinators meeting.  As in last year’s survey, respondents would  be asked for the number of eligible employees given the opportunity to  telework.  However, the following additional wording has been proposed  for that question:  “How many eligible employees are given the opportunity  to telework, i.e. are actively asked if they wish to telework or are able to  telework because their supervisor informed them they could telework on  some basis?”  If this new definition is properly applied by all agencies in  reporting data to OPM, this should address the issue we found.  Also  included in the draft survey are two new proposed questions related to  allowing employees the opportunity to telework.  These questions ask how  employees were presented with the option to telework and how many  turned it down.
The steps taken by OPM in response to our findings show a ready  willingness to address issues that are hindering telework implementation.   Continued efforts by OPM to publicize these new telework guidelines will  help to ensure that telework coordinators in federal agencies have a clear  understanding of the information they need to fully implement their own  telework programs.
section_title: GSA and OPM Provide Services and Resources to Support Governmentwide Telework Implementation, but Their Efforts Have Not Been Well Coordinated
paragraphs: As discussed earlier, the legislative framework for telework has provided  both GSA and OPM with lead roles in the implementation of telework in the  federal government, providing each agency with responsibilities for the  telework initiative.  Given these responsibilities, GSA and OPM provide  federal agencies with a range of services and resources related to this  initiative.  Table 1 summarizes their efforts in this regard.
As shown in table 1, some of the services and resources are offered jointly  by both agencies, while others are offered individually by both agencies or  uniquely by either GSA or OPM.  For example, each of these agencies  independently provides consulting, marketing, and training services, but  only OPM has undertaken an outreach effort to meet face to face with  agencies’ telework coordinators and GSA has sole responsibility for federal  telework centers.
In addition, although a GSA official told us that GSA has been promoting its  E-Connected Intelligent Remote Operations (EIRO) feature as a mobile  solution for government agencies, we found that this feature was not  functioning for a period of at least 5 months in 2003.  According to its Web  site, EIRO was supposed to have launched in March 2001 and was  intended to offer services and products from GSA Federal Supply  Schedules for mobile government work, including telework.  The EIRO  Web site also states that customers seeking mobile solutions could identify  providers that are highlighted as EIRO contractors by the EIRO logo at  “GSA Advantage!”, GSA’s online shopping and ordering system; however, a  GSA official told us that this function was never operational.  Also,  although this official told us that EIRO had launched on schedule, from a  period of at least January 2003 through May 2003, we observed that this  feature was not functional.  We asked numerous GSA officials about the  status of this feature, but they were all unaware of the problems we were  experiencing.  In fact, one official told us that GSA had been promoting  EIRO to federal agencies as if it were a functioning feature.  Ultimately, a  GSA official told us that changes to the agency’s Web portals must have  disabled the EIRO feature and assured us that GSA is pursuing solutions to  get it back online.
Although GSA and OPM share responsibilities for the governmentwide  telework initiative and a GSA official recently indicated that GSA and OPM  have expressed a new commitment to working together, their past efforts  did not always demonstrate coordination.  According to officials at both  agencies, GSA and OPM have not developed a Memorandum of  Understanding or other formal agreement regarding their responsibilities  for the federal government’s telework initiative or regarding which agency  will provide specific services, resources, and guidance.  Therefore, these  agencies have not established a delineation of their respective roles.  In  comments on a draft of this report, GSA and OPM said that they have  recognized the need to better outline separate and shared responsibilities  and that a Memorandum of Understanding was among the options they  were considering to clearly designate each agency’s responsibilities.
Despite the fact that GSA and OPM hold quarterly partnership meetings to  discuss telework-related issues in the federal government, officials from  both agencies told us that very little coordination has occurred at these  meetings.  Rather, the meetings have actually served as a means to raise  differences of opinion that have been identified by either agency, but the  resolution of those differences has proven to be difficult.  In addition,  according to the GSA and OPM officials, these meetings are used to present  updates on the status of the two agencies’ independent governmentwide  telework efforts, not to collaborate on these efforts.  On occasion, officials  from each agency have asked officials from the other agency to provide  comments on their independent draft guidelines or other information.
In addition, a GSA official told us that agencies had expressed concern  about conflicting messages they had received from GSA and OPM on  several topics, including dependent care and emergency government office  closings.  For example, officials from both GSA and OPM confirmed that  they had different positions with regard to dependent care.  GSA’s position  is that employees can care for dependents when teleworking, as long as it  does not interfere with accomplishing tasks, while OPM’s position was,  until recently, that dependents should not be in the home when an  employee is teleworking.  An OPM official told us that the agency held this  position because having dependents in the home while teleworking could  foster managerial resistance to telework.  In its recently released telework  guide for managers, supervisors, and telework coordinators, OPM revised  its position on this issue, stating that a teenager or elderly dependent might  be at home while the employee teleworks if those dependents are  independently pursuing their own activities.  It also said that teleworkers  should not generally be engaged in caregiving activities while working and  that dependent care arrangements should not typically change because the  employee is teleworking.
Also, despite the fact that both GSA and OPM shared responsibility for  developing the governmentwide telework information Web site  (www.telework.gov), a GSA official told us that OPM, which hosts the joint  Web site, independently changed the layout and content of the site in late  2002 without consulting with or informing GSA about the changes.  The  GSA official also said that GSA subsequently met with OPM and the  contractor that redesigned the site to try to resolve some of GSA’s  concerns.  According to the official, the contractor ultimately agreed with  GSA and recommended that OPM make changes to the site, because it  looked too much like an OPM site and not like the telework site for the  entire federal government.  While an OPM official confirmed this  information, she said that OPM has rejected these changes because of  “internal Web design policies.”  In their combined comments on a draft of  this report, however, GSA and OPM indicated that there was no  disagreement regarding the Web site and that “both agencies continue to  actively and successfully collaborate on www.telework.gov.”
Furthermore, a GSA official told us that GSA had asked OPM to place a link  to the Interagency Telework Issues Working Group report on the  governmentwide telework Web site, but OPM had refused to do so, despite  the fact that the working group was jointly formed by both agencies.  An  OPM official told us that OPM has been hesitant to post this report because  many of its recommendations were directed at OPM and could not be  readily implemented.  In their combined comments on a draft of this report,  however, GSA and OPM said that the two agencies had jointly determined it  would be inappropriate to post the “pre-decisional” Interagency Telework  Issues Working Group report on the federal telework information Web site  until they had had the opportunity to analyze its findings, address issues  contained therein, and fully consider all recommendations.  GSA, though,  has already independently posted this report on its own Web site with a  disclaimer, stating: “This final report does not in any way, specific or  implied, represent the official views, positions, or policies of the U.S.  Government, OPM, GSA, nor any of the agencies participating on the  Working Group.  This report is currently under review by both OPM and  GSA.”  Given that GSA and OPM co-led this group with participation from  15 federal agencies to identify policy actions needed to facilitate agency  use and expansion of telework and then make recommendations, we  believe that the report should be posted on www.telework.gov, with the  same or a similar disclaimer, in the interests of transparency.
After we discussed the issues created by the lack of coordination between  GSA and OPM with both agencies, a GSA official indicated that GSA and  OPM expressed a new commitment to coordination, especially with regard  to the governmentwide telework Web site.  Such a commitment reflects a  promising start for better assisting federal agencies in improved  implementation of their telework programs.  However, the key to success  will be sustained efforts by both agencies to work together in assisting  agencies and providing consistent and straightforward guidance, services,  and resources on the governmentwide telework initiative.  Conflicts that  have arisen from the lack of coordination in the past underscore the need  for GSA and OPM to work together to reach a formal agreement  establishing a delineation of their respective roles regarding the  governmentwide telework initiative in areas where their respective  responsibilities are not clear.  In areas where the responsibility is clearly  aligned with the mission of a particular agency, that agency should be  responsible for providing official guidance related to telework.  However,  the agencies should consult with each other and attempt to reach  consensus in providing that guidance.  Care should be taken to avoid  situations in which agencies are either left without needed guidance or  provided with conflicting guidance because GSA and OPM cannot reach  agreement.
section_title: Selected Federal Agencies Are Not Fully Implementing Key Telework Practices
paragraphs: We identified 25 key practices in telework-related literature and other  sources as those that federal agencies should implement in developing  their individual telework programs.  For the purposes of analysis, we  grouped the key practices into the following seven categories:  program  planning, telework policy, performance management, managerial support,  training and publicizing, technology, and program evaluation.  Based on our  interviews with agency officials at four selected agencies—Education,  GSA, OPM, and VA—and review of program documentation and other  information related to those agencies, we then determined the extent to  which the agencies had implemented each of the practices that were  identified in developing their telework programs.
While all four agencies we reviewed have taken at least some steps to  implement most of the key practices, we found that only 7 of the 25 key  practices had been fully implemented by all four agencies.  Our analysis  also revealed that almost half of the key practices had not been fully  implemented by at least three of the four agencies, demonstrating a need  for these agencies to focus greater attention on the remaining key practices  to develop successful telework programs.  Although some telework-related  resources from GSA and OPM, including GSA’s telework implementation  manual and OPM’s recently released telework guide for managers,  supervisors, and telework coordinators, already provide federal agencies  with information on how to implement several of the key practices we  identified, agencies may need additional guidance, guidelines, and/or  individualized technical support to fully implement these practices.
Regular attention to the practices we identified can help to foster program  growth and remove barriers to telework participation.  Figure 2 illustrates  the extent to which the agencies reviewed had implemented each of the  practices.
Importantly, the table above is intended to provide an overall summary of  the history and status of the telework programs at the respective agencies.   For some of the practices that are historical in nature, such as developing  an implementation plan and establishing a pilot program, we recognize that  agencies with existing telework programs cannot, and should not, attempt  to implement these practices at this point.  However, existing programs  that did not initially implement some of the more developmental practices  can still be successful with sustained attention to the other practices we  identified.  Below is a summary of the practices contained in each category  and an overview of what we found for each practice.  Appendix II also  includes a detailed discussion of the steps each agency has taken to  implement the practices.
subsections: section_title: Program Planning
paragraphs: In planning for an effective telework program, agencies need to take  several important steps.  Agencies should designate a telework  coordinator, establish a cross-functional project team, establish  measurable telework program goals, develop an implementation plan for  the telework program, develop a business case for implementing a  telework program, provide funding to meet the needs of the telework  program, and establish a pilot program.  As shown in figure 2, our analysis  of the telework programs at the four agencies reviewed revealed that only  two of the seven practices in the program planning category—designating a  telework coordinator and establishing a cross-functional project team— have been fully implemented by all of these agencies.  The remaining five  practices, including establishing measurable program goals and providing  funding to meet the needs of the telework program, still need to be  implemented by some or all of the agencies.
section_title: Telework Policy
paragraphs: According to Pub. L. No. 106-346, agencies must establish a telework policy  that allows eligible employees to participate in telework.  Telework-related  literature suggests that, in addition to or within an agencywide telework  policy, agencies should establish eligibility criteria to ensure that  teleworkers are selected on an equitable basis using criteria such as  suitability of tasks and employee performance; establish policies or  requirements to facilitate communication among teleworkers, managers,  and coworkers; develop a telework agreement for use between teleworkers  and their managers; and develop guidelines on workplace health and safety  issues to ensure that teleworkers have safe and adequate places to work  off-site.  As shown in figure 2, our analysis indicates that two of the five  practices in this category, including establishing an agencywide telework  policy, have been fully implemented by all of the agencies.  The remaining  three practices, including establishing eligibility criteria to ensure that  teleworkers are selected on an equitable basis, still need additional  attention to be fully implemented by some or all of the agencies we  reviewed.
section_title: Performance Management
paragraphs: Our recent work identified key practices that high-performing  organizations need to employ to develop effective performance  management systems.  Such a system should be designed, implemented,  and continually assessed by how well it helps the employees help the  organization achieve results and pursue its mission.  Using standards  derived from a modern, effective, credible, and validated performance  system, telework-related literature suggests that agencies need to take  steps to ensure that the same performance standards are used to evaluate  both teleworkers and nonteleworkers.  In addition, agencies need to  establish guidelines to minimize adverse impacts that telework can have on  nonteleworkers before employees begin to work at alternate worksites.   Figure 2 shows that two of the four agencies we reviewed have taken some  steps to implement the practice of setting the same performance standards  for teleworkers and nonteleworkers and three of the four agencies had  fully implemented the practice of establishing guidelines to minimize  adverse impacts of telework on nonteleworkers.
section_title: Managerial Support
paragraphs: Telework-related literature has shown that it is critical to obtain support  from top management and to address managerial resistance in establishing  an effective telework program.  As our earlier work has shown, and others  recognize, changes in an organization’s culture, such as the acceptance of  flexibilities like telework by managers throughout the organization, are  highly dependent on top management’s support for and commitment to  those changes.  In addition, our 1997 report on agencies’ policies and  views on telework in the federal government identified managerial  resistance as the largest barrier to implementing telework.  This  resistance can be attributed to several factors, including general resistance  to change, since telework requires managers to shift from managing by  observation to managing by results.  However, as shown in figure 2, both of  these practices still need attention by most of the agencies we reviewed.
section_title: Training and Publicizing
paragraphs: Because telework involves new ways of working, as well as supervising,  telework-related literature suggests that both employees and supervisors  should receive training to ensure a common understanding of the program.   The Interagency Telework Issues Working Group report highlighted the  need for telework training in its report.  In addition, the report states that  telework training should consist of two key components.  One of these  components should address policy issues and include general information,  such as policy updates and an orientation to telework, while the other  component should focus on telework program activities, including such  topics as information technology (IT) applications, performance  management, and time management.  Telework-related literature also  suggests that it is important to inform the workforce about the telework  program.  Despite their importance, figure 2 illustrates that both of these  practices still need attention by some or all of the agencies we reviewed.
section_title: Technology
paragraphs: OPM’s January 2003 report to Congress on the status of telework in the  federal government identified data security and IT issues as the two most  frequently cited barriers to telework, as reported by federal agencies.  In  addressing technology barriers, telework-related literature suggests that  agencies should conduct an assessment of teleworker and organization  technology needs; develop guidelines about whether the organization or  employee will provide necessary technology, equipment, and supplies for  telework; provide technical support for teleworkers; address access and  security issues related to telework; and establish standards for equipment  in the telework environment.  Generally, as shown in figure 2, the four  agencies we reviewed did better in this category than in any other.  One of  the agencies—Education—has fully implemented all of the technology  practices and the other three agencies each have only one practice out of  the five that had not been fully implemented.  However, given the rapidly  changing nature of technology and the fact that, in OPM’s 2002 telework  survey, many agencies governmentwide identified data security and IT as  barriers to growth in their telework programs, federal agencies should  provide specific and ongoing attention to these technology practices.
section_title: Program Evaluation
paragraphs: Telework-related literature recommends that agencies develop program  evaluation tools and use such tools from the very inception of the program  to identify problems or issues with the program and to develop an action  plan to guide any necessary changes for telework or for the organization.   The literature also emphasizes the need for tracking systems that can help  to accurately ascertain the status of telework implementation in the  agencies and, subsequently, the federal government.  Such a tracking  system should include, at the very least, a formal head count of regular and  episodic teleworkers, as well as nonteleworkers.  To this end, the  Interagency Telework Issues Working Group report recommended that  OPM require all federal agencies to establish a system for collecting the  information that OPM requests for its annual report to Congress on the  status of telework in the federal government.  It further recommended that  OPM provide agencies with the necessary specifications, guidance, and  technical assistance to establish these systems.
Despite the fact that accurate data are absolutely integral to assessing the  status of a telework program and identifying areas that require additional  attention, figure 2 shows that none of the agencies we reviewed have fully  implemented the practice of establishing processes, procedures, and/or a  tracking system to evaluate their telework programs.  In addition, all of the  four agencies still need to take at least some steps to fully implement the  practice of identifying problems and/or issues with their telework  programs and making appropriate adjustments.
section_title: Agency Officials Identified Governmentwide Actions That Could Be Taken to Encourage Federal Agencies to Increase Telework Participation
paragraphs: In addition to the key practices we identified as being integral to  developing successful federal telework programs, we asked agency  program officials and union representatives at GSA, Education, OPM, and  VA for their views on what governmentwide actions could be taken to  increase telework participation in federal agencies.  We also spoke with  officials representing federal employees governmentwide, such as the  National Treasury Employees Union and the National Federation of  Federal Employees, to obtain their views on potential governmentwide  actions.  In addition, OPM’s November 2002 telework survey asked  agencies about what OPM’s governmentwide telework initiative could do to  assist agencies in fully implementing telework policies.
Some agency and union officials identified governmentwide actions that  are closely related to the key practices we identified, such as the need for  funding of telework programs, the need for training, and the importance of  obtaining top-level support for telework.  In addition, several officials  identified the need for GSA and OPM to provide more guidance or  information about telework and the need for clarification regarding the  implementation of the telework provisions in Pub. L. No. 106-346.  In  particular, agency officials identified a need for additional guidance related  to their data reporting and collection methods for OPM.  Two agency  officials stated that OPM has changed the data that it requests from  agencies from year to year, which has made it difficult for them to establish  systems to collect the necessary data.
section_title: Conclusions
paragraphs: Telework has received significant attention in Congress and the executive  branch and is an increasingly popular flexibility among federal employees.   Not only is telework an important flexibility from the perspective of  employees, but it has also become a critical management tool for coping  with potential disruptions to the workplace, including terrorism.  However,  the federal government’s telework initiative needs further development to  become an effective human capital flexibility.
Congress’ most significant demonstration of support for telework was the  enactment of Section 359 of Pub. L. No. 106-346.  In guidance related to that  law, OPM told agencies that eligible employees who wanted to telework  must be allowed that opportunity, but did not provide a definition for what  constituted such an opportunity.  Although the lack of a definition for that  statement resulted in the reporting of incomparable telework data to  Congress, OPM promptly released publications defining the previously  ambiguous statement following a discussion in which we highlighted this  issue for OPM officials.
On the other hand, the relationship between two other provisions—one  that requires specified agencies to set aside $50,000 each year for the use of  GSA telework centers and one that prohibits some of the same agencies  and several others from spending funds on GSA telecommunication  centers—remains in need of clarification.  Although GSA telework centers  are not known by the term “GSA telecommunication centers,” GSA officials  believe that this term does in fact refer to GSA telework centers.  Despite  this belief, it has not been made clear to all applicable agencies that the  provision prohibiting certain agencies from spending appropriated funds  on GSA telecommunication centers applies to GSA telework centers.  This  was supported by the fact that two of the relevant agencies used  appropriated funds for GSA telework centers in fiscal year 2002, even  though the provision prohibiting them from spending appropriated funds  on GSA telecommunication centers was in effect.
Although GSA and OPM are lead agencies for the governmentwide  telework initiative, they have not fully coordinated their efforts in leading  the governmentwide telework initiative and have had difficulty in resolving  their conflicting views on telework-related matters.  This lack of  coordination created confusion for federal agencies in implementing their  individual telework programs.  Both GSA and OPM officials recently  indicated a willingness to work together to resolve this issue, but sustained  attention and actions that result in actual solutions will still be needed.
In addition, the key telework practices we identified are integral to the  success of the telework initiative in the federal government and need to be  considered individually by each federal agency within the context of its  own mission, programs, and telework programs.  However, as our work at  four agencies has shown, agencies face numerous difficulties in  implementing their individual agency programs.  Regular attention by  agencies to the key practices is important to foster program growth and  remove barriers to telework participation.
section_title: Recommendations for Agency Action
paragraphs: We recommend that the Administrator, GSA, work with Congress to  determine what was meant by the phrase “GSA telecommunication center”  in Section 314, Division F, title III of Pub. L. No. 108-7 and whether this  provision is in conflict with the provision contained in 40 U.S.C. 587(d)(2).   Once these determinations are made, GSA should issue guidance to the  relevant agencies to clarify these provisions and explain the impact of  these laws on agencies’ telework programs.
We also recommend that the Administrator, GSA, and the Director, OPM,  ensure that the offices in their agencies with responsibilities for the  governmentwide telework initiative improve coordination of their efforts  to provide federal agencies with consistent, inclusive, unambiguous  support and guidance related to telework.  To do so, they should clearly  delineate their responsibilities for this initiative and work together to  resolve existing areas of difference.  The Memorandum of Understanding  that the agencies are considering could be very helpful in making progress  on this key issue.
Furthermore, to enable agencies to more effectively implement the key  practices that we identified as those that should be used for successful  implementation of federal telework programs, we recommend that the  Administrator, GSA, and the Director, OPM, use their lead roles in the  federal telework initiative to assist agencies in implementing these  practices.  Using the key telework practices, GSA and OPM should identify  areas where more information about implementation of the practices may  be needed and provide agencies with the additional guidance, guidelines,  and/or individualized technical support necessary to assist them in  implementing those practices that are still in need of attention.   Additionally, OPM agreed with a recommendation included in our recent  report for OPM to serve as a clearinghouse in sharing and distributing  information about the broad range of human capital flexibilities available  to federal agencies.  In implementing that recommendation, OPM should  include information about telework, because it is such a flexibility.  To  provide agencies with the capabilities to effectively implement telework,  both GSA and OPM should continue to monitor agencies’ telework  programs and align their efforts with areas that are still in need of  attention.
section_title: Agency Comments
paragraphs: We provided a draft of this report in June 2003 to the Secretaries of  Education and VA, the Administrator, GSA, and the Director, OPM.  The  Director of Human Resources Services from Education provided  comments via e-mail (see app. III for a summary of these comments).  In  addition, we received written comments from the Secretary, VA, and joint  written comments from the Administrator, GSA, and the Director, OPM, in  response to a draft of this report (see app. IV and V).  Where appropriate,  we made changes in our report in response to these comments.
In its comments, Education generally agreed with the contents of the draft  report and stated that the department was pleased that we recognized its  efforts to advance telework.  Additionally, the comments stated that the  department’s “most significant comment” was, as our draft noted, the need  for a clear, unambiguous, and universally accepted definition for what it  means to allow employees the opportunity to telework.
VA agreed with our conclusion that there is a need for further guidance and  assistance from GSA and OPM regarding federal telework implementation  and suggested two areas where such guidance would be helpful.   Specifically, VA indicated that OPM needs to redefine participant eligibility  criteria and that OPM and GSA should provide guidance on how to  effectively use telework in emergency situations.  In addition, VA expressed  concern that the draft report, which stated that we used participation rate  as one of the criteria used in our selection of agencies, did not recognize  that VA’s mission is a significant factor accounting for its limited telework  participation rate.  VA also disagreed with several of our findings related to  the status of VA’s implementation of the telework practices we identified.   However, when we asked for documentation to support the statements that  VA made in its comments, VA was unable to provide such information.   Absent any evidence that would support VA’s comments, our assessment  remains unchanged.
In their combined comments, GSA and OPM agreed that telework is an  important tool for federal agencies and stated that they would encourage  and champion telework as a key human capital flexibility and do everything  possible to facilitate its acceptance and use.  The agencies also agreed to  implement our recommendation that they use their lead roles in the federal  telework initiative to assist agencies in implementing the key telework  practices we identified.  In this regard, GSA and OPM stated that they will  provide agencies with a checklist of the practices we identified and  recommend that agencies do a self-assessment of their telework programs  using our analytical framework.  Both GSA and OPM will then offer to help  agencies to improve in the identified areas of deficiency.  OPM will also  include the key telework practices that we identified in telework training,  which, as we had noted in the draft report, is being developed for launch on  its Web-based training site during fiscal year 2003.
In addition, GSA agreed with our recommendation that it work with  Congress to determine what was meant by the phrase “GSA  telecommunication center” in Section 314, Division F, title III of Pub. L. No.  108-7 and whether this provision is in conflict with the provision contained  in 40 U.S.C. 587(d)(2).  GSA stated that it will coordinate internally and  with the appropriate congressional committees to resolve the conflicting  language in the statutes and then provide clarification to its customer  agencies.
On the other hand, both GSA and OPM disagreed with several of our  findings relating to their lead roles in the governmentwide telework  initiative.  For example, GSA and OPM strongly disagreed with our finding  that they have not fully coordinated their governmentwide telework efforts  in the past.  This contradicts information that was conveyed to us by  agency officials during our review.  However, we have added to the report,  where appropriate, to reflect the agencies’ new position on the issue of  coordination.  Interestingly, despite the fact that GSA and OPM disagreed  with our finding relating to coordination, the agencies also said in their  comments that they have recognized the need to better outline separate  and shared responsibilities and that a Memorandum of Understanding was  among the options they were considering to clearly designate each agency’s  responsibilities.
OPM also raised a number of issues with our analysis of its internal  telework program.  In its comments, OPM stated “ach comment listed  was conveyed to GAO during the interview process.”  On the contrary,  OPM’s comments, for the most part, contain new information and/or  information that does not correspond with what was conveyed to us by  OPM officials during our review.  Much of this information contradicts  what was conveyed to us by agency officials during our review.  However,  we have changed the report where appropriate to reflect OPM’s new  positions on some issues.
GSA did not disagree with our findings pertaining to its internal telework  program. However, the agency did note several areas where it would like us  to revise statements relative to its implementation of the key practices we  identified.  We considered these comments and incorporated new language  into the report where appropriate.
As agreed with your office, unless you announce the contents of this report  earlier, we plan no further distribution until 30 days after its issue date.  At  that time, we will send copies to the Secretary of Education, the  Administrator of GSA, the Director of OPM, and the Secretary of VA.  We  will also provide copies of this report to other interested congressional  parties and make copies available to others upon request.  In addition, the  report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you have any questions about this report, please contact me or Boris  Kachura on (202) 512-6806.  Key contributors to this report were Joyce  Corry, Ellen Grady, Tiffany Tanner, and V. Bruce Goddard.
section_title: Scope and Methodology
paragraphs: The objectives of this report were to  characterize the federal laws and their requirements that currently apply  to telecommuting within the federal agencies in the executive branch;   determine what the General Services Administration (GSA) and the  Office of Personnel Management (OPM) are doing, as lead agencies, to  coordinate and promote telecommuting in the federal government;  determine what selected federal agencies are doing to implement key  practices in developing telecommuting programs; and   identify additional governmentwide actions that could be taken to  encourage federal agencies to increase telecommuting participation.
To address these objectives, we gathered information from a variety of  sources using several different data collection techniques and analyzed this  information.  In order to characterize the federal laws and their  requirements that currently apply to telecommuting within the federal  agencies in the executive branch, we identified and analyzed the relevant  laws and discussed the requirements of selected laws with agency officials.   To determine what GSA and OPM are doing to coordinate and promote  telecommuting in the federal government, we interviewed GSA and OPM  officials regarding their governmentwide telework efforts and analyzed  relevant documents related to these efforts.
We took several steps to determine what selected executive agencies are  doing to implement key practices in developing telecommuting programs.   First, we conducted a review of literature and guidelines related to  telework in the federal government to identify the key practices that  executive agencies should implement in developing telework programs.   These guidelines and this literature were obtained from both government  and nongovernment sources including studies and reports issued by  interest groups, associations, consulting firms, GSA, OPM, and other  federal government agencies.  A practice was considered to be “key” if it  was recommended in three or more sources as a practice that  organizations should use in implementing a telework program.
After identifying the key telework practices, we conducted semi-structured  interviews of selected telework program officials and other relevant agency  officials and analyzed documents related to telework implementation at  four agencies—the Department of Education (Education), GSA, OPM, and  the Department of Veterans Affairs (VA).  These agencies were selected  from the 24 executive agencies covered by the Chief Financial Officers  (CFO) Act of 1990 for various reasons, including function, size, and  reported level of telework participation.  GSA and OPM were selected  because of their lead roles in the governmentwide telework initiative.  In  addition, OPM was reported to have the highest telework utilization rate  among the CFO Act agencies.  Education was included because its reported  utilization rate was the second highest among the CFO Act agencies.  VA  was selected based on its distinction as the second largest CFO Act agency  combined with its having the lowest reported telework utilization rate  among the CFO Act agencies.  This agency selection process was not  designed to produce findings that could be considered representative of  telework implementation in the federal government as a whole, but rather  to provide illustrative examples of the extent to which selected individual  agencies with varied sizes, reported utilization rates, and missions had  implemented the key practices identified in our literature review.
We interviewed officials and union representatives from the four selected  agencies to obtain their views on additional governmentwide actions that  could be taken to encourage federal agencies to increase telecommuting  participation.  In addition, we contacted other unions representing federal  employees, including the National Treasury Employees Union, the  American Federation of Government Employees, and the National  Federation of Federal Employees, to solicit their views on such additional  actions.  (Officials for the American Federation of Government Employees  did not respond to our request.)  Our work was conducted from May 2002  through May 2003 in accordance with generally accepted government  auditing standards.
section_title: Descriptions of Efforts by the Selected Agencies to Implement the 25 Key Practices
paragraphs: We identified 25 key practices in telework-related literature and other  sources as those that agencies should implement in developing their  telework programs.  This appendix contains descriptions of how the four  agencies reviewed—the Department of Education (Education), the General  Services Administration (GSA), the Office of Personnel Management  (OPM), and the Department of Veterans Affairs (VA)—are implementing  each practice.  Although attention to each of these practices is integral to  the success of the federal telework initiative, the four agencies we  reviewed have not fully implemented many of them.  Regular attention to  the practices can help to foster program growth and remove barriers to  telework participation.
subsections: section_title: Program Planning
subsections: section_title: Designating a Telework Coordinator
paragraphs: Telework resources provided by both GSA and OPM in their roles as lead  agencies for the federal telework initiative state that, in implementing their  telework programs, federal agencies need to designate agency telework  coordinators and contacts.  All four of the agencies in our study have a  designated telework coordinator.  At Education, the coordinator works on  the agency’s telework program full time.  At the other three agencies, the  telework coordinator has other responsibilities in addition to telework.
section_title: Establishing a Cross- Functional Project Team, Including, for Example, IT, Union Representatives, and Other Stakeholders
paragraphs: Our 2002 report on the effective use of flexibilities identified stakeholder  input as a key practice for effectively using human capital flexibilities, such  as telework.  According to this report, agency leaders, managers,  employees, and employee unions need to work together to develop policies  and procedures, because such involvement helps in reaching agreement on  the need for change, the direction and scope that change will take, and how  progress will be assessed.  Stakeholder input should also be used to ensure  that the policies surrounding the use of flexibilities are clear and the  procedures to implement them are uncomplicated.  Telework-related  literature suggests that stakeholder involvement should be obtained by  establishing a committee with members from human resources,  information management, risk management, facilities management, and  senior management, as well as employee and union representatives.  All  four of the agencies we reviewed established cross-functional project  teams in implementing their telework programs.
section_title: Establishing Measurable Telework Program Goals
paragraphs: According to the International Telework Association and Council’s (ITAC)  e-Work Guide, research conducted by the American Management  Association in 2000 indicated that “68 percent of ‘highly successful’  telework programs felt it was ‘critical’ to develop clear and reasonable  program objectives for their program” and another 27 percent considered it  to be helpful.  None of the four agencies we examined have taken any  steps to implement this practice.
In comments on a draft of this report, both OPM and VA said they had  established measurable telework program goals.  However, neither agency  was able to provide documentation of such goals.  Therefore, our  assessments of these agencies on this practice remain unchanged.
section_title: Developing an Implementation Plan for the Telework Program
paragraphs: Guidelines issued by OPM in its capacity as a leader of the governmentwide  telework initiative suggest that agencies should establish a strategic plan  with definitive timelines to accomplish implementation of telework  including an evaluation tool.  The ITAC e-Work Guide states that such a  plan should include, at a minimum, objectives and how their achievements  will be measured; definitions and policy details; a business case, including  start-up and ongoing costs; a technology plan; and an implementation  plan.  Two of the agencies reviewed, Education and OPM, have fully  implemented this practice in their internal telework programs, while VA  has not taken any steps to implement this practice.  However, in comments  on a draft of this report, VA said that it had developed an implementation  plan for the telework program.  When we requested documentation of such  a plan, VA responded that, in fact, it did not establish an implementation  plan for its current telework policy.  Therefore, our assessment of VA on  this practice remains unchanged.  During our review, GSA’s telework  coordinator told us that there was not a written implementation plan for  the telework program when it was first started.  However, in comments on  a draft of this report, GSA indicated that it had an implementation plan that  was utilized 10 years ago when the program was first developed, but this  plan was not kept in the files, because it was no longer in use.  Therefore,  we were unable to assess GSA’s implementation of this practice, and have  modified the report accordingly.
section_title: Developing a Business Case for Implementing a Telework Program
paragraphs: ITAC’s e-Work Guide states that “successful telework programs reside in  organizations that understand why they support telework, address the  relevant issues, minimize business risk and make the investment when it  supports their objectives.”  To achieve such success, the guide  recommends that organizations develop business cases for implementing  telework programs.  The April 2002 report issued by Booz Allen Hamilton  on home-based telework technology barriers also recommends that  agencies develop business cases for implementing telework in their  organizations, because such an approach has proven effective in engaging  management on the benefits of telework to an organization.  Through  business case analysis, organizations have been able to identify cost  reductions in the post-telework office environment that offset additional  costs incurred in implementing telework and the most attractive approach  to telework implementation.  Of the four agencies we reviewed, Education  was the only agency to have taken some steps to implement this practice.   A program official at this agency said that she has developed a PowerPoint  presentation of a business case for implementing a telework program at  Education.  However, she has never actually given this presentation to  anyone at Education.
section_title: Providing Funding to Meet the Needs of the Telework Program
paragraphs: Telework-related literature suggests that agencies should incorporate  requirements for home-based telework into their IT capital planning and  budgeting processes and provide for consistent allocation of the resources  necessary to establish telework arrangements, such as the equipment and  technology needed for remote access to agency networks.  However,  providing funding to meet the needs of the telework program is a practice  that the four agencies have only partially implemented.
Under the provisions of 40 U.S.C. 587(d)(2), the only legislated funding for  telework programs that applies to the executive agencies that we reviewed,  specified agencies are to make at least $50,000 of the funds appropriated  for salaries and expenses available each fiscal year for their employees’ use  of GSA telework centers.  However, the agencies covered under this  legislation are not required to spend the money made available.  While this  provision pertains to all four of the agencies in our study, neither VA nor  OPM actually spent at least $50,000 for telework center use in fiscal year  2002.  In contrast, both Education and GSA spent more than this minimum  set aside.
Although VA’s telework policy states that the agency’s telework  assignments may be established at community-based telework centers  when determined to be consistent with the agency’s mission, a program  official said that VA generally does not choose to support use of the  centers.  In fiscal year 2002, VA spent only $6,800 for two users at one  telework center.  OPM’s expenditures for telework center use in that year  were about $36,400.  At Education, the telework program requests at least a  10 percent increase in funds to be made available each year over those  requested the preceding year.  For example, for fiscal year 2002, $82,000  was requested and approved, while for fiscal year 2003, $125,000 was  requested and approved.  An Education program official said that the 2003  request was much greater than the 2002 request because, in 2002, the  agency actually spent over $87,000 for use of the centers and the demand  was far greater than she had anticipated or could fund.  The expenditures  for telework center use at GSA in 2002 were about $97,000.
In addition to the funds made available for employees to work at telework  centers, each of the four agencies pays the salaries of telework  coordinators.  In its comments on our draft report, GSA said that it did not  have a central telework fund.  Instead, it said that individual organizations  within GSA provided their own funding for telework.  We had considered  this information in our assessment of GSA’s level of implementation of this  practice.  OPM said in its comments that the agency funds staff time to  provide oversight and evaluation for the telework program, as well as  outreach and program promotion, but it is not clear whether such funding  would go beyond the already cited salary payment for OPM’s part-time  telework coordinator or would even be related to OPM’s internal telework  program as opposed to OPM’s governmentwide efforts.  In addition, OPM  stated that it had identified resources to accommodate “every employee  (who is otherwise eligible and wants to telecommute) with appropriate  computer equipment, technology support, and remote connections.”   However, OPM did not provide documentation of this funding.  Also, an IT  official at OPM said that there were times that the agency has been short on  the older computers it loans to teleworkers.  He said that the people who  absolutely need to telework get computers immediately, if they require one,  but that people who would like to telework, but do not have a “need” to do  so, have had to wait to begin teleworking until computers became  available.  According to this IT official, managers usually make the decision  about whether telework is a “need,” although employees will sometimes  decide for themselves that it is not necessary for them to telework.  Given  these considerations, we did not change our assessment that GSA and OPM  had taken some steps to implement this practice.
Beyond these situations, the four agencies have not directly allocated other  funds to meet the functional needs of their telework programs.  Moreover,  both Education and VA cited funding as a major barrier to their agencies’  telework programs in their responses to OPM’s November 2002 telework  survey.  Education’s response also characterized telework as an unfunded  mandate that agencies had to support with funds from their appropriations  for salaries and expenses.
Establishing a Pilot Program Booz Allen Hamilton’s April 2002 report on barriers to home-based  telework stated that well-structured pilot programs have led to successful  telework programs.  Guidelines issued by Commuter Connections, a  program coordinated through the Metropolitan Washington Council of  Governments, suggests that a telework pilot program may be the best way  to prove the concept and test the integration plan by demonstrating effects  on performance and productivity, evaluating policies and procedures,  testing remote access and technology support, identifying resource  requirements, evaluating new workplace concepts, testing training  effectiveness, and evaluating manager-team-remote worker relationships.   Of the four agencies we reviewed, only Education had a pilot related to the  implementation of its agencywide telework program.  Although GSA and  OPM did not have individual pilot programs for their internal telework  programs, both agencies were involved in the year-long governmentwide  telework pilot program that was implemented in 1990.
In comments on a draft of this report, VA said that it had two pilot  programs.  However, when we requested documentation of a pilot relating  to implementation of its current program, VA responded that, in fact, it did  not conduct a pilot program for its current telework policy.  Therefore, we  did not change our assessment of VA on this practice.
section_title: Telework Policy
subsections: section_title: Establishing an Agencywide Telework Policy
paragraphs: OPM’s January 2003 report to Congress stated that of the 77 reporting  agencies, 63 reported having approved and implemented their telework  policies, 9 were in the process of policy development, 3 were in the  implementation stages, and 2 reported no policies or policy development  activity.  All 4 of the agencies in our study have implemented telework  policies and, according to agency officials at all of these agencies, they  have given some consideration to updating their policies to reflect changes  within the agency and more recent trends in telework.  At VA, a program  official provided us with a draft for an updated policy, which was  developed to modernize the agency’s policy and expand the eligible  population at VA.  According to this official, the draft policy was going  through the approval process at that time.  Program officials at all 4 of the  agencies told us that revisions to their policies would involve obtaining  union input on those revisions.  Telework program officials at GSA and  OPM said that reaching such agreement with the unions can take a year or  more.
section_title: Establishing Eligibility Criteria to Ensure That Teleworkers Are Selected on an Equitable Basis Using Criteria Such as Suitability of Tasks and Employee Performance
paragraphs: Several telework-related sources have emphasized the need for eligibility  criteria to ensure that teleworkers are selected on an equitable basis.  Most  of these sources advise that these criteria should be based on the suitability  of both the tasks and the employee for telework.  According to the  Interagency Telework Issues Working Group report, criteria for  determining the suitability of the employee should be based on objective  criteria that are equitable, reasonable, and clearly stated and not on general  personal characteristics that are assessed using subjective measures, such  as being organized, conscientious, highly disciplined, and a self-starter.   The report went on to say that using such criteria can lead to subjective  supervisory assessments, which can inaccurately or inappropriately  impede telework participation.  To address this concern, the report  recommended that OPM establish a policy that all federal employees are  potentially eligible to participate in telework, unless excluded by their  agency based on objective criteria that are supportive of the intent of the  telework requirements in Public Law 106-346.  The group also  recommended that OPM require each individual agency to identify and  define, in its telework policy, positions excluded from telework  arrangements, based strictly on tasks performed in the excluded positions.
Education has included eligibility criteria in its policy that are similar to  those that the Interagency Telework Issues Working Group cautioned  against using.  Education’s policy states that an employee who is suitable to  telework should exhibit self-starter characteristics, good organizational  skills, and the ability to function independently.  Education and OPM also  require that teleworkers are performing at or above a specified rating level  such as “fully successful.”  In addition, OPM’s telework policy states that  employees approved for telework should be able to manage workloads  with minimum supervision and that generally, telework is not appropriate  for new employees such as those who need to be in the office to learn the  organization and those who require on-the-job training.  GSA’s policy does  not include eligibility criteria, but states that criteria for selecting  occupations and employees for telework are not hard and fast rules.   However, the policy also refers to a separate GSA Office of Human  Resources document for selection factors particularly relevant to telework.   A GSA program official said that she had been trying to locate that  document for a while, but to date has not been able to do so.  VA’s current  policy includes eligibility criteria based solely on position classifications.   However, a VA program official acknowledged that there is variation in the  application of eligibility requirements among parts of that agency, given the  subjective nature of the approval process.  She added that the proposed  revisions to VA’s current policy would require supervisors to give reasons  for denial on the application form, which she hoped would provide needed  information to help assess equitable treatment.  Because none of the four  agencies have yet taken steps to ascertain whether teleworkers are being  selected on an equitable basis, these agencies cannot ensure that their  eligibility criteria are being applied equitably.
section_title: Establishing Policies or Requirements to Facilitate Communication Among Teleworkers, Managers, and Coworkers
paragraphs: Although telework-related sources suggest that establishing policies or  requirements to facilitate communication among teleworkers, managers,  and coworkers is helpful in addressing managerial concerns about  telework, teleworker isolation, and morale issues that may arise with  nonteleworkers, two of the four agencies, Education and OPM, have fully  implemented this practice.  Education’s telework policy states that  supervisors should ensure that efforts are made to include teleworkers as  part of the team in order to reduce employee isolation and communication  problems, and to facilitate integration of the employee with those in the  office.  As a means of accomplishing this, the policy recommends that  teleworkers plan to work from the office at least 1 day per week in order to  be available for meetings or anything that needs to be handled face-to-face  and on days when staff meetings are scheduled.  The policy also suggests  that developing fixed times during the day for supervisor/employee  telephone conversations may be helpful to ensure ongoing communication.   OPM’s policy also includes language about the importance of  communication and recommends that employees plan to be in the office at  least 1 day per week.  In addition, OPM’s policy states that the telework  agreement must include means of communication with the employee when  telecommuting (phone, fax, e-mail, etc.).  OPM’s alternate worksite  agreement includes an area specifically addressing assignments and  communication.  It says that the information provided in the designated  space “should include work assignments, agreements on checking voice  mail and email or contacting the supervisor as well as the requirement for  employees to come into the office as needed.”  While program officials at  GSA and VA acknowledged that communication was an important issue,  the telework policies at these agencies did not establish means of  facilitating communication.
section_title: Developing a Telework Agreement for Use between Teleworkers and Their Managers
paragraphs: Telework-related literature recommends that agencies develop a telework  agreement to be signed by both teleworkers and their supervisors.   According to ITAC’s e-Work Guide, such an agreement should establish job  duties and expectations, performance standards, and measurable  outcomes and deliverables.  All four agencies reviewed have developed  telework agreements, but have different requirements for their use.  For  example, GSA does not require the use of these agreements for ad hoc  telework arrangements.  In contrast, OPM’s telework policy states that  “employees must sign a work agreement with their supervisor.”  Despite  this requirement, an OPM program official told us that this does not always  happen in practice and she does not require them to do so.  However, she  does accept e-mail agreements between employees and supervisors when  she receives them.
section_title: Developing Guidelines on Workplace Health and Safety Issues to Ensure That Teleworkers Have Safe and Adequate Places to Work Off-Site
paragraphs: Telework-related literature describes several means for employers to  ensure that teleworkers have safe and adequate alternate workplaces.   These include specifically addressing health and safety issues related to  telework in policies, including health and safety issues in telework training,  having teleworkers fill out a safety checklist, and performing on-site  inspections with adequate notice to the teleworker.  Three of the four  agencies we reviewed, Education, GSA, and OPM, have developed safety  checklists, which are to be completed along with the telework agreement,  to ensure that teleworkers have certified the safety of their alternate  workplaces.  However, Education is the only agency that requires all  teleworkers to complete and sign such a checklist before they begin  teleworking.  GSA includes a safety checklist with the telework agreement,  but episodic teleworkers are not required to complete an agreement or,  therefore, a checklist.  OPM’s telework policy recommends that the  telework agreement include a safety checklist, but such a checklist is not  required.  According to a program official from VA, the agency’s current  policy does not contain health and safety guidelines, but the revised draft  policy, which is currently going through the agency’s approval process,  includes a safety checklist.
section_title: Performance Management
subsections: section_title: Ensuring That the Same Performance Standards, Derived from a Modern, Effective, and Credible Performance System, Are Used to Evaluate Both Teleworkers and Nonteleworkers
paragraphs: Although none of the agencies have fully implemented the practice of  ensuring that the same performance standards are used to evaluate both  teleworkers and nonteleworkers, Education and OPM have taken some  steps to implement this practice.  Education’s telework policy states that  employees participating in the telework program shall be treated equally  with other employees in decisions that affect conditions of employment for  awards, promotions, and/or any other condition of employment.  A  program official at OPM said that work performed by teleworkers is  supposed to be evaluated using the same performance standards used for  nonteleworkers and that managers are supposed to communicate this.   Although such a statement was not included in OPM’s telework policy, the  policy does state that the employees’ current performance standards will  be used to govern all telecommuting assignments as well as those in the  telecommuters’ current traditional federal offices.  A GSA program official  told us that the agency incorporated this concept into its telework policy  and reiterated it in counseling sessions with managers and staff.  We did  not find any support of this in GSA’s policy, although it did indicate that  “ime spent and quality of products will be measured by correlation with  previous and similar efforts.”  VA’s current telework policy does not contain  any statements related to using the same performance standards for both  teleworkers and nonteleworkers.  In comments on a draft of this report, VA  stated that the department consistently advises supervisors and managers  that performance standards for teleworkers and nonteleworkers should be  the same.  However, VA could not provide us with any information to  support this comment.  In fact, VA responded that it provides such advice  “on an as-requested basis,” which does not constitute “consistently  advising.”  Therefore, our assessment of VA on this practice remains  unchanged.
section_title: Establishing Guidelines to Minimize Adverse Impact on Nonteleworkers Before Employees Begin to Work at Alternate Worksites
paragraphs: Telework-related literature suggests that performance and morale issues  can arise if guidelines are not established to address and minimize adverse  impacts of telework on nonteleworkers.  The literature describes several  issues that can contribute to such issues among nonteleworkers, including  eligibility criteria that are perceived as unfair and cause nonteleworkers to  feel left out or discriminated against, teleworkers that allow their in-office  responsibilities to fall on the shoulders of nonteleworkers, and reduced  communication between the teleworker and nonteleworker.  To mitigate  these situations, care should be taken to establish fair and equitable  eligibility criteria and means of distributing work.
Three of the four agencies, Education, OPM, and VA, have fully  implemented this practice by including specific guidelines in their policies.   Education’s telework policy states that telework should not affect the  performance of other employees and that it shall not put a burden on staff  remaining in the office.  It also says that an equitable distribution of work  must be maintained and methods should be instituted to ensure that  employees working in the office do not have to handle the teleworker’s  work.  OPM’s policy says that supervisors should consider the effect of  telework on all employees in the work unit, especially if it means there are  fewer employees in the office to handle customer requests.  At VA,  supervisors are charged with ensuring that participating and  nonparticipating employees are treated equitably.  According to a program  official at GSA, the agency’s policy sets out guidelines for effective use of  telework, including that a unit should use whatever systems it deems  necessary to ensure that there is a balance of work between those  teleworking and those in the office.  However, we did not see any support  of this in GSA’s policy.
section_title: Managerial Support
subsections: section_title: Obtaining Support from Top Management for a Telework Program
paragraphs: Although program officials from all four agencies recognized support from  top management as being critical to the success of a program such as  telework, a program official at OPM was the only one to state,  unequivocally, that telework has the full support of that agency’s top  management.  She said that the agency’s director leads by example, since  she and various members of her staff telework.  The director has also  demonstrated support by sending e-mails encouraging telework in  response to certain events, such as Green Day.  A GSA program official  believes support for telework from that agency’s top management has  varied by administration.  However, she said that, although the current  administrator has not made a statement specifically supporting telework,  he has made several overtures in support of the program, including  teleworking occasionally himself, supporting GSA’s promotional free trial  offer for use of the telework centers, and attending meetings related to  telework.  Officials at the other two agencies cited lack of support from top  management as a challenge in implementing the telework program.  An  Education program official also specifically discussed the difficulties that  frequently changing administrations and leadership can create because of  having to repeatedly work to overcome the barriers that new top managers  bring to the agency.
section_title: Addressing Managerial Resistance to Telework
paragraphs: Our 1997 report identified managerial resistance as the largest barrier to  implementing telework, attributing it to several factors, including general  resistance to change, since telework requires managers to shift from  managing by observation to managing by results.  Officials from three of  the four agencies that we spoke with—Education, GSA, and VA—also cited  this as a challenge that they face and identified it as a barrier to telework in  their responses to OPM’s November 2002 telework survey.  Current and  former program officials at OPM stated that managers at that agency do not  exhibit signs of managerial resistance to telework and thus this practice  has been fully implemented.  A former program official directly linked the  presence of top management support for telework at OPM to the  prevention of managerial resistance, because managers were told that they  have to allow telework and that they must give a business case for rejecting  an employee’s request to telework.
Program officials at two of the agencies presented some ideas for  addressing managerial resistance.  A VA program official would like to  bring in outside consultants to hold an information forum or educational  briefings for supervisors and managers, which would tie telework to the  shift from the industrial age to the information age and walk managers  through the process of approving a telework arrangement.  VA’s draft  Telework Proposal form, included in its revised draft telework policy, will  help to address managerial resistance, if it is implemented in its current  form, by requiring that supervisors provide a written reason if a telework  application is not approved.  In its response to OPM’s 2002 telework survey,  VA also said that it is using initiatives to gain top management support to  overcome barriers that include managerial resistance.  According to a  program official, GSA has considered handling the approval process for  telework agreements by committee instead of by individual supervisors as  a means of alleviating managerial resistance, but this has not yet happened  because of managerial resistance to such a change.
section_title: Training and Publicizing
subsections: section_title: Training All Involved, Including, at a Minimum, Managers and Teleworkers
paragraphs: Three of the four agencies that we reviewed provide some telework  training.  At Education, training for teleworkers is mandatory before they  can begin to telework.  Training is available at monthly training sessions, by  telephone, or by requesting the telework coordinator’s training slides.   These training opportunities are also available, but optional, for managers  and nonteleworkers.  GSA’s telework policy states that new program  participants, including employees and immediate supervisors, must receive  training except for those participating in episodic arrangements.  However,  a program official said that while GSA trained all employees when its  telework program was first implemented, currently the agency only does  occasional briefings on the telework program, usually in town hall  meetings or on an as-needed basis with individuals.
A former program official at OPM told us that all managers were required  to attend telework briefings when the program first started in 2001.  These  sessions addressed performance management, office coverage and work  unit issues, equipment issues, providing business reasons for denials, and  handling Privacy Act implications.  Other employees were offered the  opportunity to attend briefings about the roles and responsibilities of a  teleworker, but they were not required to attend.  However, a current OPM  program official told us that the agency does not currently offer telework  training, that there has been no discussion of offering such training, and  that she does not see a need for it at this time.
Although a program official at VA believes training is very important and is  critically needed for supervisors and new employees, she said that  telework training has never been done at the agency.  She noted that VA has  considered developing an interactive training program for supervisors, but  it is waiting for the release of an Internet training package that OPM’s office  with responsibility for the governmentwide telework initiative has  developed before making any decisions.  It is anticipated that this training  for managers and teleworkers will be available to all federal government  employees from OPM during fiscal year 2003 at no charge on  www.golearn.gov—an OPM-provided on-line learning center.  The  availability of such training may help to address any disparity in the  provision of telework training among agencies.
section_title: Informing the Workforce about the Telework Program
paragraphs: Telework-related literature suggests that it is important to inform the  workforce about opportunities to telework.  Two of the agencies, GSA and  OPM, have fully implemented this practice for their internal telework  programs, using means such as intranet sites, newsletters, posters, and  brochures to disseminate information about the telework program.  At  Education, a program official told us that she stopped actively marketing  the telework program in response to pressure from top management.   However, Education’s internal Web site has information on telework,  including forms for participation and e-mail links.  Education also  publicizes information about telework training opportunities in its internal  weekly newsletter.  A program official from VA indicated that she would  like to do more to market the program, but is limited by budgetary  constraints.  Currently the only means of publicizing VA’s telework program  is through its intranet site, which includes a copy of the telework policy,  helpful hints for supervisors and employees, information about telecenters,  telework questions and answers, and guidance about what would make a  good teleworker.  However, the program official acknowledged that this  form of communication has a drawback in that only those employees with  access to computers can retrieve this information.
section_title: Technology
subsections: section_title: Conducting an Assessment of Teleworker and Organization Technology Needs
paragraphs: Since teleworkers often require the use of IT equipment to access files,  internal networks, and e-mail, the Environmental Protection Agency (EPA)  suggests that agencies assess both their own and their employees’  technology needs for telework with a mind toward providing employees  with access to equipment similar to what they have in the office.  In  addition, ITAC’s e-Work Guide reports that research conducted by the  American Management Association found that 73 percent of “highly  successful” telework programs regarded it as “critical” to do an analysis  and review of the organization’s technology base and its compatibility with  teleworker requirements.  According to Booz Allen Hamilton’s report on  technology barriers to home-based telework, the technologies acquired in  response to such assessments, including document management systems,  collaboration tools, and performance measurement systems, can result in  benefits for both teleworkers and those in the office environment as well.
Two of the four agencies we reviewed, Education and OPM, have fully  implemented this practice and GSA has partially implemented the practice.   According to an IT official at Education, the department did an engineering  analysis to determine both current and future infrastructure needs for  telework.  In addition, a program official from Education told us that each  applicant for telework must complete a technology assessment worksheet.   OPM conducted a technology assessment as part of its program planning.   As part of this effort, OPM’s IT staff chose the technologies to be used for  remote access and decided that government-issued equipment was  preferred to personal equipment for security purposes.  OPM’s IT  department also distributes virus software to employees who use their  personal computers for telework.  GSA has not conducted an agencywide  assessment of teleworker and organization technology needs.  According  to a GSA program official, this is done on a case-by-case basis at the  organization level because each organization is responsible for its own  budget and for providing its workers with the appropriate tools for doing  the job.  According to another GSA official, GSA’s Office of  Governmentwide Policy is conducting a pilot with laptops and docking  stations to minimize the agency’s costs of maintaining two workstations for  teleworkers.  According to an IT official, VA has not conducted an  assessment of technology needs with respect to teleworkers.  As it  currently stands, the process at VA is handled individually between the  supervisor and employees.
section_title: Developing Guidelines about Whether the Organization or Employee Will Provide Necessary Technology, Equipment, and Supplies for Telework
paragraphs: Guidelines issued by GSA for the governmentwide telework initiative  indicate that, while agencies are permitted, but not required, to provide  teleworkers with equipment for use at alternate worksites, each agency  must establish its own policies on the provision and installation of  equipment for telework.  All of the agencies we reviewed have established  policies in this regard, stating that the agency will make decisions about  providing equipment for telework on a case-by-case basis in light of funding  and other considerations, such as the work to be performed at the alternate  site, the type of equipment and software that is needed, and the availability  of equipment.  For those agencies that allow employees to use personal  equipment for telework, one program official acknowledged that such a  policy can result in a “digital divide” between those employees who have  the option of using or acquiring personal equipment for telework when the  agency is not able to provide them with equipment and those who do not  have such equipment available to them.
section_title: Providing Technical Support for Teleworkers
paragraphs: According to the Interagency Telework Issues Working Group report,  establishing technical support for both government-owned and personal  equipment used to perform official duties for remote users, especially for  teleworkers, is a relatively new issue for agencies.  Some concerns  associated with this issue focus on the availability and consistency of such  support for teleworkers.  To address these concerns, the report  recommends that GSA establish a policy requiring that telework  arrangements are covered in each agency’s IT technical support policies  and that agencies refer to relevant sources of information on technical  support in their telework policies.
All four of the agencies reviewed have fully implemented this practice.   According to an IT official at Education, the same technical assistance is  available to all Education employees, whether they are in the office or  teleworking.  There is no special technical support for teleworkers.  A  program official from Education also said that customer service center  staff can provide technical support for nongovernment-owned equipment,  but this support is limited to whatever help can be provided over the  telephone.  An IT official at GSA said that the agency has two levels of  technical support for users.  The first level of technical support for all  users, regardless of where they are working, is from their own unit’s  support staff.  The second level of support for remote access users,  including teleworkers, is the Remote Access Team in the Chief Information  Officer’s office.  This level of support is called upon when the first level  cannot resolve the problem.  According to an IT official at OPM, the agency  has a telework group that manages the servers, the virtual private network,  and communication software.  There is a separate phone number for  people to call with computer problems associated with personal or agency- provided computers encountered while teleworking.  At VA, teleworkers  have remote access to the same technical support as office-based workers.
section_title: Addressing Access and Security Issues Related to Telework
paragraphs: The Interagency Telework Issues Working Group report states that remote  access is a key component of telework programs, because “low-tech”  solutions, such as floppy disks, are inadequate for most situations.  It goes  on to say that remote access solutions, especially the speed of the  connection, are necessary to maintain productivity in a telework  arrangement.  However, both the Interagency report and Booz Allen  Hamilton’s report on technology barriers to home-based telework  identified concerns among managers about security and the protection of  agency information when systems are accessed remotely.  Although the  Booz Allen Hamilton report stated that the need to provide information  security was not seen by any of the organizations they analyzed as a reason  to inhibit home-based telework, OPM’s January 2003 report to Congress on  the status of telework in the federal government identified data security as  the most frequently cited barrier to telework.  All four of the agencies we  reviewed said they had addressed access and security issues related to  telework by using remote access systems with adequate safeguards.
section_title: Establishing Standards for Equipment in the Telework Environment
paragraphs: Booz Allen Hamilton’s report on technology barriers to home-based  telework recommends that federal organizations specifically define  technical requirements, or standards, for the home environment to ensure  that sufficient systems and support services are available to teleworkers.   According to the report, such requirements should also be included in the  longer-term IT and capital planning processes at each agency.  Three of the  four agencies we reviewed, Education, GSA, and VA, have fully  implemented this practice and OPM has taken some steps to implement  this practice.
According to IT officials at both Education and GSA, these agencies use the  same standards for equipment in both the home and office environments.   Neither agency has established separate standards for equipment in the  telework environment.  If an employee wants to use his own equipment at  home, the equipment would have to meet the network standards.   According to a program official at Education, the department’s Web site  identifies the minimum technology requirements and is regularly updated  with the latest information on viruses, security issues, and other  information.  According to an IT official at VA, the department has  established a standard for its IT equipment, whether at a VA locale or not.   This official reported that all IT investments and procurements are required  to undergo review and concurrence from VA’s Enterprise Architecture  Service.  In addition, the draft policy includes a security checklist,  including security requirements for equipment, which must be completed,  reviewed, and certified by the Information Security Officer before a  telework arrangement can begin.
OPM has taken some steps to implement this practice.  In comments on a  draft of this report, OPM stated that it has a standard platform for  connectivity and has established a protocol for requesting necessary  equipment and connectivity.  However, an IT official from OPM reported  that, while OPM has a target standard machine, this standard has not been  fully applied.  In addition, this IT official also told us that OPM does not  really have a standard for employee-provided equipment and that  employees are only made aware of the need to upgrade to the standard  when they raise an issue about their current equipment.
section_title: Program Evaluation
subsections: section_title: Establishing Processes, Procedures, and/or a Tracking System to Collect Data to Evaluate the Telework Program
paragraphs: Even though the four agencies we studied have processes and procedures  to collect data on their telework programs, none of them currently does a  survey specifically related to telework or has a tracking system that  provides accurate participation rates and other information about  teleworkers and the program.  Such lack of information not only impedes  the agencies in identifying problems or issues related to their telework  programs, it also prevents these agencies from providing OPM, and  subsequently Congress, with complete and accurate data.
Education’s process to collect data provides some useful information, but it  is not complete.  To compile information on telework at Education, a  database was developed, which uses information from telework  agreements and the department’s payroll system.  Using this database,  Education can produce reports on a number of topics, including the  number of teleworkers, whether they telework on a regularly scheduled or  ad hoc basis, what regions or offices they work for, who their supervisors  are, and their grade levels.  However, an Education program official  acknowledged that although this system is designed to track telework  agreements, some agreements are not accounted for, such as informal  agreements that are unbeknownst to her or agreements that have not gone  through the whole process.  Furthermore, because it tracks agreements  and not actual usage, the system cannot measure telework utilization.  VA  currently does not have a database for telework and uses decentralized  data collection methods, but a program official indicated that the agency  plans to implement telework tracking via the time and attendance system.   Although this official said that she hopes this new tracking system will  address data inconsistency issues within the agency, she could not provide  a time frame for its implementation.
OPM tracks its teleworkers by counting telework agreements and recently  developed a database to keep track of these agreements, although a  program official acknowledged that informal e-mailed telework  agreements that are sometimes used at OPM might not all be included in  the database because she did not receive them.  As stated above, systems  that rely on agreements to track telework participation do not actually  provide information about utilization rates.  At OPM this weakness is  compounded by the fact that the agency does not ensure that telework  agreements are used in all cases.  GSA does not have an agencywide  tracking system.  Coordinators for individual units at GSA calculate  telework data from telework agreements once a year in order to provide  the information GSA submits for OPM’s annual governmentwide telework  survey.  However, no documentation is required for intermittent telework  arrangements at GSA, and, as a result, a program official acknowledged  that the number of these types of arrangements reported to OPM for its  2002 telework survey was a rough estimate.  She also said that the survey  instruments and reporting mechanisms used by OPM’s governmentwide  telework initiative for its annual report on telework in the federal  government were a challenge in this area because of changes in the data  requested from year to year, which made it difficult to determine the kind  of system an agency needed to develop to best track the requested data.
section_title: Identifying Problems and/or Issues with the Telework Program and Making Appropriate Adjustments
paragraphs: ITAC’s e-Work Guide recommends that organizations choose an evaluation  design that 1) allows the clearest judgment of the program’s effectiveness  and 2) uses the evaluation results to develop an action plan to guide any  necessary changes for telework or for the organization.  It states that  organizations should use reliable and valid measures of all outcomes and  processes, including benchmarking and follow-up assessment  questionnaires, interviews, behavioral observations and ratings, or  organizational data, because the quality of measurement is extremely  important to enabling one to draw the proper conclusions regarding the  effectiveness of telework and whether or not it has met the original  objectives.
Despite the importance of using data to evaluate and improve telework  programs, none of the four agencies we reviewed had fully implemented  this practice.  A program official at Education told us she had collected  data on the telework program and used these data to identify some  potential problem areas.  For example, she identified offices that had low  telework program participation rates and an office that had teleworkers  working only on an as-needed schedule and no one working on a fixed  schedule.  She used this information to target marketing efforts until she  was told to stop actively marketing the program.  In addition, a private  contractor conducted a survey about Education’s telework program in  1999.  Although the survey’s response rate was very low due, in part, to  technology incompatibilities across the department and a lack of support  by union officials, the survey yielded four recommendations, none of which  have been fully implemented.  According to a GSA program official, GSA  does not collect data to identify problems or make adjustments to its  telework program.
An OPM program official stated that she does not use the telework data she  collects to identify issues with the program.  Rather, she relies on  employees to bring problems to her attention and responds accordingly.  At  VA, a program official identified an issue with the data collected for OPM’s  2003 report to Congress on the status of telework.  She believed the data  collected within VA was inconsistent and needed to be reexamined.  For  example, 102,000 positions were identified as being eligible for telework for  the January 2003 report, as opposed to 80,000 that had been identified for  the January 2002 report.  Since the program official thinks VA’s true eligible  population is between 55,000 and 75,000 employees, she asked the local  human resources representatives to reexamine the numbers they reported.
section_title: Comments from the Department of Education
paragraphs: The Director of Human Resources Services from the Department of  Education provided comments on a draft of this report via e-mail.  In these  comments, Education generally agreed with the contents of the draft report  and stated that the department was pleased that we recognized its efforts  to advance telework.  Additionally, the comments stated that the  department’s “most significant comment” was, as our draft noted, the need  for a clear, unambiguous, and universally accepted definition for what it  means to allow employees the opportunity to telework.
section_title: Comments from the Department of Veterans Affairs
subsections: section_title: GAO Responses to Comments from VA
paragraphs: 1. VA agreed with our conclusion that there is a need for further guidance  and assistance from GSA and OPM regarding federal telework  implementation and suggested two areas where such guidance would  be helpful.  Specifically, VA indicated that OPM needs to redefine  participant eligibility criteria and that OPM and GSA should provide  guidance on how to effectively use telework in emergency situations.   2. VA expressed concern that the draft report, which stated that we used  participation rate as one of the criteria used in our selection of  agencies, did not recognize what VA considers to be a significant factor  accounting for its limited telework participation rate.  In this regard, VA  stated that a “significant number of VA employees are engaged in direct  patient care and benefit service delivery to veterans, which precludes  large-scale participation in telework.”  As our draft noted, agencies  were selected to provide illustrative examples of the extent to which  individual agencies with varied sizes, reported utilization rates, and  missions had implemented the key practices identified in our literature  review.  Nonetheless, we have added additional language to our scope  and methodology section regarding the service delivery focus of VA’s  mission.  3. VA also had several comments on our findings related to the status of  VA’s implementation of the telework practices that we identified.  The  specific issues that VA raised and our response to each are summarized  as follows:  a. In its comments, VA noted that it had conducted two pilot programs.
When we requested additional information from VA to support its  comment, VA provided us with information about two pilot programs  that did not relate to their current telework program.  VA also stated  that it did not conduct a pilot program for its current telework policy.   Because VA could not provide information about a pilot program for  its current telework policy, we did not change our assessment that  VA has not taken any steps to implement this practice. b. VA said it had established measurable telework program goals and an  the course of our work that VA did not have any measurable telework  goals or an implementation plan.  Therefore, we have not changed  our assessment that VA has not taken any steps to implement these  practices. c. VA commented, as our draft report had noted, that its revised  telework policy has a “Self-Certification Safety Checklist.”  However,  as we also noted in our draft report, this policy is still in draft form  and was not in use during our review.  Because VA’s current telework  policy does not contain a safety checklist and the draft checklist is  not in use, we have not changed our assessment that VA has not  taken any steps to ensure that teleworkers have safe and adequate  places to work off-site. d. VA indicated that it had developed a Telework Proposal form that  was designed to facilitate communication among supervisors,  employees, and managers.  However, that form is part of VA’s revised  telework policy, which, as noted in our draft report, has not yet been  approved for use at VA and, therefore, was not considered in our  evaluation.  Moreover, this form, once approved, will not serve to  establish policies or requirements to facilitate communication  between managers and teleworkers, such as detailing the methods of  communication that should be used or the frequency with which  communication should occur while teleworking.  More importantly,  VA’s existing telework policy does not establish such policies or  requirements to facilitate communication.  Given these  considerations, our assessment that VA has not taken any steps to  implement this practice remains unchanged. e. VA stated that the Telework Proposal form, which, as we noted, is  still a draft, allows it to track and evaluate the effectiveness of its  program as well as VA’s success in achieving targeted participation  goals.  This form simply allows VA to count how many employees  have applied for telework and how many have been approved for  such an arrangement. Such information will be important and  valuable.  However, the form would not fully enable VA to evaluate  the effectiveness of its program or its success in achieving  participation goals in terms of the number of employees actually  teleworking and, equally important, the extent to which telework is  being used.  As we had noted in our draft report, a VA program  official had indicated to us that the agency plans to implement  telework tracking via the time and attendance system, which she  hopes will address data inconsistency issues within the agency.  Such  a tracking mechanism, if implemented, could be helpful in tracking  telework participation.  Based on these considerations, our  assessment that VA has taken some steps to implement this practice  remains unchanged.  f. VA also stated that the department consistently advises supervisors  and managers that performance standards for teleworkers and  nonteleworkers should be the same and said that this was consistent  with the criteria under our category of “Performance Management.”   However, VA could not provide us with any information to support  this comment.  In fact, VA responded that it provides such advice “on  an as-requested basis,” which does not constitute “consistently  advising.”  Furthermore, VA’s current telework policy does not  contain any statements related to using the same performance  standards for both teleworkers and nonteleworkers.  Given these  considerations, we have not changed our assessment that VA has not  taken any steps to ensure that the same performance standards are  used to evaluate both teleworkers and nonteleworkers. g. In addition, VA noted that its ability to conduct a technology  assessment for telework is compromised by the lack of clear  guidance regarding which positions are suitable to telework.  This  further illustrates our finding, as stated in our draft report, that  agencies may need additional guidance, guidelines, and/or  individualized technical support to fully implement the practices we  have identified.  However, VA’s comment does not affect our  assessment that VA has not taken any steps to implement this  practice.
section_title: Comments from the General Services Administration and the Office of Personnel Management
subsections: section_title: GAO Responses to Comments from GSA and OPM
paragraphs: 1.
In their combined comments, GSA and OPM agreed that telework is an  important tool for federal agencies and stated that they would  encourage and champion telework as a key human capital flexibility  and do everything possible to facilitate its acceptance and use.  The  agencies also agreed to implement our recommendation that they use  their lead roles in the federal telework initiative to assist agencies in  implementing the key telework practices we identified.  In this regard,  GSA and OPM stated that they will provide agencies with a checklist of  the practices we identified and recommend that agencies do a self- assessment of their telework programs using our analytical framework.   Both GSA and OPM will then offer to help agencies to improve in the  identified areas of deficiency.  OPM will also include the key telework  practices that we identified in telework training, which, as we had  noted in the draft report, is being developed for launch on its Web- based training site during fiscal year 2003.
2.
In addition, GSA agreed with our recommendation that it work with  Congress to determine what was meant by the phrase “GSA  telecommunication center” in Section 314, Division F, title III of Pub. L.  No. 108-7 and whether this provision is in conflict with the provision  contained in 40 U.S.C. 587(d)(2).  GSA stated that it will coordinate  internally and with the appropriate congressional committees to  resolve the conflicting language in the statutes and then provide  clarification to its customer agencies.   3. GSA and OPM disagreed with several of our findings relating to their  lead roles in the governmentwide telework initiative.  Below are  summaries of GSA’s and OPM’s comments and our responses: a. These agencies stated that, given the efforts they have made in  promoting telework, they were “taken aback” by language in the draft  that noted confusion at the “implementation level” throughout the  federal government regarding the policy guidance that they had put  forth to date.  However, as detailed in our draft report, our finding  was actually that conflicting messages from GSA and OPM on certain  telework-related matters had created confusion.  Apart from this  finding, we recognize GSA’s and OPM’s efforts to promote telework  and had included in our draft report many of the examples of those  efforts that GSA and OPM cited in their response, such as jointly  running the telework Web site to provide information and guidance,  OPM’s rapid issuance of guidance in response to our finding related  to the lack of a definition for providing employees with the  opportunity to telework, and GSA’s management and promotion of  the telework centers.  Also, our draft report discussed OPM’s  outreach effort to meet face to face with agencies’ telework  coordinators and, as GSA’s and OPM’s comments noted, this effort  was also described in our May 2003 report entitled Human Capital:  OPM Can Better Assist Agencies in Using Personnel Flexibilities.   However, while such promotional efforts can be constructive, they  do not address the confusion we identified as a result of GSA’s and  OPM’s conflicting messages.  b. GSA and OPM strongly disagreed with our finding that they have not  fully coordinated their governmentwide telework efforts in the past.   In one instance, they said that the draft report stated there were  unresolved disagreements between GSA and OPM on telework policy  issues concerning dependent care and emergency closing of  government offices, and that they believed there were no such  disagreements.  However, GSA and OPM also stated that, while they  believed that their responses to the dependent care and emergency  closing issues were not in conflict, they clarified them to avoid any  confusion.  We believe this is a noteworthy development because, as  stated in our draft report, agencies had expressed concern about  conflicting messages they had received from GSA and OPM on  several topics, including dependent care and emergency closings.
More generally, we also indicated in our draft report that, because  GSA and OPM have not developed a Memorandum of Understanding  or other formal agreement regarding their responsibilities for the  governmentwide telework initiative, they should work together to  reach a formal agreement establishing a delineation of these  responsibilities.  In their comments, the agencies said that they have  recognized the need to better outline separate and shared  responsibilities and that a Memorandum of Understanding was  among the options they were considering to clearly designate each  agency’s responsibilities.  We have added language to reflect GSA’s  and OPM’s commitment to address these areas. c. In addition, GSA’s and OPM’s comments said that it was unnecessary  for OPM to re-coordinate with GSA on the final version of the  telework guide for managers, supervisors, and telework coordinators  because GSA’s comments had already been incorporated into the  guide.  Although we found that OPM had made substantive changes  to the guide subsequent to GSA’s review, we now believe that, given  the concerns expressed by agencies, and underscored by Education’s  and VA’s comments on our draft report, it was sufficiently important  to issue the guide in a timely fashion, without a final review by GSA.   Relevant changes have been made to our report. d. According to GSA’s and OPM’s comments, GSA’s senior program  executive for telework disputed our finding that GSA had expressed  concerns about OPM’s changes to the joint OPM/GSA telework Web  site (www.telework.gov).  However, this statement varies from  information provided to us both by GSA and OPM officials during the  course of our review and by the senior OPM official for the  governmentwide telework initiative at our exit conference with OPM.   For example, during our exit conference, the senior OPM official for  the governmentwide telework initiative acknowledged changing the  telework Web site without GSA being informed or OPM getting input  from GSA.  She said that GSA was not very happy with the new look,  adding that GSA felt the changes were imposed on it by OPM without  any consultation.  Nonetheless, we have adjusted the report to reflect  the view of the GSA senior program executive. e. In their comments, GSA and OPM also said that the two agencies had  jointly determined it would be inappropriate to post the “pre- decisional” Interagency Telework Issues Working Group report on  the federal telework information Web site (www.telework.gov) until  they had had the opportunity to analyze its findings, address issues  contained therein, and fully consider all recommendations.   However, GSA has already independently posted this report on its  own Web site with a disclaimer, stating: “OPM and GSA co-led the  Interagency Telework Issues Working Group by offering technical  guidance, support, and resources.  The findings and  recommendations made in this final report reflect the opinions of the  Working Group members.  This final report does not in any way,  specific or implied, represent the official views, positions, or policies  of the U.S. Government, OPM, GSA, nor any of the agencies  participating on the Working Group.  This report is currently under  review by both OPM and GSA.”  Given that GSA and OPM co-led this  group with participation from 15 federal agencies to identify policy  actions needed to facilitate agency use and expansion of telework  and then make recommendations, we believe that the report should  be posted on www.telework.gov, with the same or a similar  disclaimer, in the interests of transparency. 4. OPM also raised issues with our analysis of its internal telework  program.  OPM stated that our draft report indicated that 12 of our 25  identified key practices still needed to be implemented at OPM.  While  our draft report showed that OPM had “fully implemented” 13 of the  practices, it went on to say that OPM had “taken some steps to  implement” 5 of the remaining practices and had “not taken any steps  to implement” the other 7 practices.  OPM’s comments related to its  internal telework program maintained that it has fully implemented 24  of the 25 practices, stating that the 25th practice should not apply to it.   As we clarified in this report, some of the practices, such as developing  an implementation plan and establishing a pilot program, are historical  in nature and cannot be implemented at this time by agencies with  existing telework programs.  However, as we also clarified in the  report, agencies with existing programs that did not initially implement  some of the more developmental practices can still be successful with  sustained attention to the other practices we identified.
In its comments, OPM stated that “ach comment listed was  conveyed to GAO during the interview process.”  On the contrary,  OPM’s comments, for the most part, contain new information and/or  information that does not correspond with what was conveyed to us  during our meetings with OPM officials.  Summaries of OPM’s  comments, and our responses, are discussed below:   a. OPM disputed our finding that the agency had not established  measurable telework program goals, saying that it had done so by  meeting, even exceeding, the requirements of Section 359 of Pub. L.  No. 106-346.  OPM said that, “n effect, the legislation has provided  the program goals for Federal agencies through 2004.”  However, in  its May 2003 telework guide for managers, supervisors, and telework  coordinators, OPM discusses the importance of establishing  program goals and objectives for telework because they will be  helpful in conducting program evaluations of a telework program.   OPM’s guide notes that “ey issues for evaluation for most agencies  include the effect of telework on productivity, operating costs,  employee morale, recruitment, and retention” and that the evaluation  plan “should be based on quantifiable program goals and objectives  to allow for ease of measurement.”  Section 359 of Pub. L. No. 106- 346 refers broadly to the federal workforce and OPM has not  provided any documentation illustrating how it has converted the  law’s requirements into program goals to measure the effect of  telework on productivity, operating costs, employee morale,  recruitment, retention, or any other such desirable outcome.   Moreover, OPM’s telework coordinator told us during the course of  our review that goals have not been set for OPM’s internal program.   Given these considerations, our assessment of OPM for this practice  remains unchanged. b. OPM disagreed with our finding that it had not established a business  case for implementing a telework program, stating that the business  case for telework has been developed through various means,  including statements made in its governmentwide guidance,  information provided in training sessions for its managers, and by  referring its managers to the OPM/GSA telework Web site.  As  described in a source from which we drew our key practices, a  comprehensive business case for a telework program entails  identifying full costs and benefits to the extent practicable, prior to  implementation of the program, that are specific to the organization,  including IT components, facilities, recruiting, retention, contingency  support, and security and risk assessments.  The business case that  OPM refers to in its comments does not fully meet these criteria.   Furthermore, this comment does not correspond with what was  conveyed to us during our meetings with OPM officials.  Instead,  OPM’s telework coordinator at the time its current program was  developed in 2001 told us that a business case for telework had not  been developed prior to implementing the telework program.  Given  these considerations, our assessment of OPM for this practice  remains unchanged.  c. OPM disputed our finding that it has only taken some steps to  provide funding to meet the needs of the telework program.  The  agency said that it has provided “full funding” for its telework  program and that it has identified resources that have allowed it to  accommodate “every employee (who is otherwise eligible and wants  to telecommute) with appropriate computer equipment, technology  support, and remote connections.”  OPM did not provide  documentation of this funding.  As our draft report indicated, OPM  has taken important steps to implement this practice, by paying the  salary for a telework coordinator and setting aside $50,000 in fiscal  year 2002 for telework center use, as required by law.  However, an IT  official at OPM said that there were times that the agency has  experienced shortages of the older computers it loans to  teleworkers.  He said that the people who absolutely need to  telework get computers immediately, if they require one, but that  people who would like to telework, but do not have a “need” to do so,  have had to wait to begin teleworking until computers become  available.  According to this IT official, managers usually make the  decision about whether telework is a “need,” although employees  will sometimes decide for themselves that it is not necessary for  them to telework.  Given these considerations, we did not change our  assessment that OPM had taken some steps to implement this  practice. d. OPM questioned the validity of our having assessed its telework  program against the practice of establishing a pilot program because  “the founding legislation” did not include a requirement for  establishing pilot programs and because OPM is confident that a pilot  would not have added significant value to its program.  As noted in  our draft, we used a variety of sources, including GSA’s and OPM’s  telework guidance, to identify key practices.  Successful telework  experiences and related telework literature suggest that pilot  programs can be valuable at the outset of telework initiatives by  providing a means to test the concept and its integration within a  particular organization’s environment.  However, as we recognize in  this report, agencies with existing telework programs that did not  implement this practice when the program was initially developed  can still have successful telework programs with sustained attention  to the other practices.  Because OPM did not establish a pilot  program at the outset of its telework program, our assessment of  OPM for this practice remains unchanged. e. OPM disagreed with our finding that it had taken some steps to  establish eligibility criteria to ensure that teleworkers are selected on  an equitable basis using criteria such as suitability of tasks and  employee performance, stating that it had fully implemented this  practice by providing objective eligibility criteria in its telework  policy.  Our draft report noted the progress OPM had made in this  area and that guidance was in place on eligibility criteria.  However,  OPM’s telework coordinator also told us that the eligibility criteria  varied by OPM unit and may not be consistently applied.  Therefore,  while the OPM guidance is an important step, its consistent  application is not being ensured.  Thus, we continue to believe that  OPM has taken some steps to implement this practice. f. OPM disagreed with our finding that it had taken some steps to  establish policies or requirements to facilitate communication among  teleworkers, managers, and coworkers, stating that its policy and  associated forms serve to facilitate communication.  Based on  further analysis of the policy and its associated forms, we have  changed the report to reflect that OPM has fully implemented this  practice.   g. OPM disagreed with our finding that it has taken some steps to  develop guidelines on workplace health and safety issues to ensure  that teleworkers have safe and adequate places to work off-site,  because one of the appendixes included with OPM’s telework policy  is a safety checklist for the alternate worksite.  As we noted in our  draft report, OPM’s telework policy states that the telework  agreement should include a safety checklist.  Importantly, however,  the suggested checklist, included as an appendix to OPM’s policy,  states that the employee “may use” it to “assist them in a survey of  the overall safety and adequacy of their alternate worksite.”  It goes  on to say “the following are only recommendations and do not  encompass every situation that may be encountered.”  Moreover, the  checklist does not have a signature line or any way for it to be  certified by the employee.  Because this checklist is only  recommended, not required, and does not need to be certified by the  employee, it is not sufficient to ensure that teleworkers have a safe  and adequate place to work off-site.  Therefore, we continue to  believe that OPM has taken some steps to implement this practice. h. OPM disagreed with our finding that it has not taken any steps to  ensure that the same performance standards, derived from a modern,  effective, credible, and validated performance system, are used to  evaluate both teleworkers and nonteleworkers, saying that the  performance standards that employees are evaluated against  annually are based on the duties and responsibilities of the  employee’s position and not on whether the employee is a teleworker  or nonteleworker.  OPM further stated that the performance  standards are the same, regardless of where the work is performed.   As we stated in the draft report, although OPM’s policy does state  that the employees’ current performance standards will be used to  govern all telecommuting assignments, as well as those in the  telecommuters’ current traditional federal offices.  However, it does  not include a statement requiring that the same performance  standards be used for teleworkers and nonteleworkers.  Without  such a statement, at a minimum, OPM cannot fully ensure that the  same performance standards are used to evaluate both teleworkers  and nonteleworkers.  Nonetheless, we have revised the report to  acknowledge that OPM has taken some steps to implement this  practice.  While these steps are important, there are steps that OPM  can take to more fully ensure that the criteria have been consistently  applied, such as periodically checking the performance appraisals for  consistency.   i. OPM disagreed with our finding that it had not taken any steps to  train all involved in its telework program, including, at a minimum,  managers and teleworkers, saying that it has provided extensive  training to both managers and employees.  However, this comment  does not correspond with what was conveyed to us during our  meetings with OPM officials.  According to both the current and past  OPM telework coordinators, OPM had provided mandatory training  to managers and optional training to employees when the telework  program began, more than 2 years ago.  In addition, they told us that  OPM has not provided any training since then.  Even the initial  training would not have been sufficient to train “all involved” in the  telework program, because employees were not required to attend.   In response to OPM’s comments, we have revised our report to  reflect OPM’s initial training efforts by indicating that OPM has taken  some steps to implement this practice.  We are also pleased that OPM  indicated in its comments that, now that its agency restructuring has  been completed, it plans to provide continued outreach and training  on telework.  However, OPM cannot be considered to have fully  implemented the practice of training all involved in its telework  program until this training is actively provided to and required of all  relevant parties. j. OPM disputed our finding that it had not taken any steps to establish  standards for equipment in the telework environment, saying that  OPM has a standard platform for connectivity and has established a  protocol for requesting necessary equipment and connectivity.   During our review, an IT official from OPM told us that the equipment  standards had not yet been fully applied to agency-owned equipment,  but he expected this to be done between July and October 2003.   Based on OPM’s more recent comments, we have revised our report  to reflect that OPM has taken some steps to implement this practice.   However, the IT official also told us that OPM does not have a  standard for employee-provided equipment.  Until OPM establishes  and applies its standards to employee-provided equipment, it will not  have fully implemented this practice. k. OPM disputed our finding that it had taken some steps to establish  processes, procedures, and/or a tracking system to collect data to  evaluate the telework program, stating that it collects and tracks a  variety of data that is used to evaluate and report on its telework  program.  According to OPM, because its policy states “ompleted  work agreements must be forwarded to the organizational  telecommuting contact for record keeping purposes,”  the agency has  fully implemented this practice.  In our draft report, we recognize  OPM’s policy that employees sign a work agreement with their  supervisor.  However, OPM’s telework coordinator told us that work  agreements, whether in hard copy or e-mail form, are not always  completed and forwarded to her.  Additionally, while OPM endeavors  to track participation rates through these work agreements, the  agreements only provide information on how many employees have  been approved to telework, not how many are actually participating.   Without a tracking and evaluation system that accurately measures  program participation, OPM cannot be considered to have taken  more than some steps to implement this practice.  One such system  was suggested by OPM itself in the section of GSA’s and OPM’s  comments on our draft report that is related to those agencies’  governmentwide leadership roles.  These comments said, “OPM has  concluded from research that the best telework data is collected  through time and attendance tracking systems.  OPM will be issuing  guidance to agencies later this year on the use of this data source for  its next survey.”  Such guidance will be an important step toward  helping all agencies to more accurately track and report such data  and so that they can use the data for evaluation and program  improvement purposes. l. OPM disputed our finding that it had not taken any steps to identify  problems and/or issues with the telework program and make  appropriate adjustments, indicating that the various surveys and data  it collects are used, not only to report on the number of employees  teleworking in the agency, but also to help inform enhancements to  its program.  However, OPM’s telework coordinator indicated that  she does not actively seek to identify issues using any evaluation  tools.  Instead, as OPM pointed out in its comments, she relies on  employees to bring issues to her attention.  While employees can be  an important source of information, such data sources are  complements to, and not substitutes for, formal feedback  mechanisms and well-designed evaluations, as described in OPM’s  recently released telework guide to managers, supervisors, and  telework coordinators.  Nonetheless, given these considerations,  we have revised our assessment of OPM for this practice to reflect  that it has taken some steps to implement this practice.  5. GSA did not disagree with our findings pertaining to its internal  telework program.  However, the agency did note several areas where it  would like us to revise statements relative to its implementation of the  key practices we identified.  Below is a summary of GSA’s comments  and our responses:   a. GSA said that, since its program has been in place for more than 10  years, it does not have or need a current implementation plan.   Furthermore, GSA indicated that it had an implementation plan that  was utilized 10 years ago, when the program was first developed.   However, GSA stated that this plan was not kept in the files, because  it is no longer in use.  We agree that GSA should not develop an  implementation plan for a program that is already in place.  Our  analysis was focused on whether an agency had developed an  implementation plan to shape the design and implementation of its  program to ensure future success.  In this regard, GSA’s telework  coordinator had told us that there was not a written implementation  plan for the telework program when it was first started.   Nevertheless, we have revised our report to indicate that we were  unable to assess GSA on this practice. b. GSA indicated that it does not have a central telework fund and that  individual organizations within GSA provide their own funding.  We  had considered this information in our analysis of the level of GSA’s  implementation of this practice.  However, we have added GSA’s  statement to our report to provide additional context.  Also, as  already noted in our draft report, GSA said that it had set aside the  required central funding for telecenter utilization. c. GSA noted that it has an operational telework program and,  consequently, there is no further need for piloting.  We agree with  GSA that there is no further need for piloting.  Our analysis in this  regard assessed whether or not an agency had established a pilot at  the beginning of its individual telework program.  GSA did not  establish a pilot program prior to implementation of its telework  program.  Therefore, our assessment of GSA for this practice remains  unchanged. d. In addition, GSA provided comments related to several other areas,  including:  1) its position on establishing telework eligibility criteria,  2) its emphasis on fairness toward teleworkers and others, and 3) its  existing lines of communication regarding telework, including its  network of telework coordinators in regions and organizations  throughout the agency, its provision of e-mail and on-line information  on telework, and its “strong emphasis on communication.”  While  these comments were helpful in setting the context for GSA’s internal  telework program, they were not relevant to our analysis and,  therefore, are not reflected in the body of our report.
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