USDA T&A System Controls: Recording Deviations From Preapproved Work Schedules

Published by the Government Accountability Office on 1999-09-14.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

United States General Accounting     Office                             Accounting and Information
Washington, DC 20548                                                           Management Division


           September 14,1999

           Ms. Mary Lynn Horst
           Director, Marketing and Regulatory Programs
           Human Resources
           Department of Agriculture
           4700 River Road
           Riverdale, MD 20737

           Subject:       USDA T&A Svstem Controls: Recording Deviations From
                          Prearmroved Work Schedules

           Dear Ms. Horstz

           This letter responds to your May 17,1999, request for a clarification on the internal
           control requirements in Title 6, “Pay, Leave, and Allowances,” of GAO’s Policv and
           Procedures Manual for Guidance of Federal Agencies, as they relate to the
           Department of Agriculture’s (USDA) Marketing and Regulatory Programs’staff time
           and attendance (T&A) records. Specifically, you asked (1) if employees are required
           to sign for their arrival/departure time (in/out times) when recording deviations from
           their preapproved declared schedule and (2) in lieu of signing in/out times for
           deviations to the preapproved work schedule, whether employees could use e-mail or
           phone in their actual pay period schedule.

           Your request was initiated because your office would like to establish a
           departmentwide policy on recording deviations from preapproved flexible work
           schedules of employees to ensure that adequate records of-work and absent times are
           made and maintained. To supplement the information contained in your letter, we
           contacted your staff to discuss the questions in more detail. Our responses to your
           questions are provided in detail in the following sections.

           Recording    Deviations      to Preammoved   Schedules

           Your first question asks whether employees are required to sign for deviations to
           their preapproved work schedules. Section 3.8 of Title 6 states that when employees’
           arrival and departure times for a pay period are established, these schedules become
           the basis for recording T&A data unless material variance or deviations occur.
           Material deviations must be approved by the supervisor and are required to be
           recorded. Title 6 provides for flexibility in establishing what are material deviations.

                                                   GAO/ATMD-99-282RUSDA T&A System Controls

It states that unless otherwise designated by management, a material deviation from
an established schedule is one that differs by one hour or more during a workday.

However, management can establish the amount of time at which a material deviation
from a preapproved work schedule occurs-15 minutes, 30 minutes, or any time
different from the preapproved schedule. The deviation established by management
should be based on an assessment of the risks involved and the needs of the agency;
the work environment, including the type of work performed and the internal control
existing to assess productivity and record work times and absences; and the work
habits of the employees. Immaterial deviations need not be recorded. However, the
supervisor should be aware of such deviations and should verify that the employee
has adequately compensated the agency for the deviation. It should be noted that
although immaterial deviations need not be recorded in most instances, supervisors
may find it necessary from time-to-time for all deviations to be recorded for certain
employees or under certain situations and should be permitted to require such

Nevertheless, all material deviations must be recorded in some manner to become
part of an employee’s T&A record. The deviations can be recorded in any one of
several different ways. For example, recording arrival and departure times directly
on an employee’s time sheet, recording arrival and departure times on a centrally
maintained time-in/time-out log used by many employees, or noting the number of
hours and minutes of the deviation in a ledger that the supervisor maintains. The
method selected by management to record the deviations should be the most efficient
and effective one under the circumstances.

Regardless of which method is used to record deviations from preapproved
schedules, supervisors, before submitting T&A data for pay purposes, are required to
approve the data, containing a record of material deviations, for each pay period.
Approval could be evidenced by the supervisor’s hand written signature or initials, or
other means such as an automated signature. Title 6 does not require the employee
to attest to his or her T&A data unless management has established such a policy.
Section 3.5 of Title 6 does require, however, that the T&A system be able to identify
the individual responsible for recording the T&A data

T&A Data E-mailed      and Phoned In

Your second question asked whether employees can e-mail or phone in deviations
from preapproved work schedules in lieu of signing for arrival or departure times.
Regarding immaterial deviations, as explained in the prior section, normally no
record need be made of such deviations. For the purposes of simply notifying a
supervisor of a material deviation, Title 6 would allow an employee to communicate
the change in any manner that management approved, including by e-mail or phone.
However, if the e-mail or phone communication is to become an actual T&A record to
serve as documentation for the employees’pay, then the e-mail should be archived or
the phone conversation documented.

 Page 2                                GAOMMD-99-282R USDA T&A System Controls

The e-mails should contain adequate details of the material deviation and be retained
for the proper period and stored under adequate procedures as required in Title 8,
“Records Management,” of the GAOPolicv and Procedures Manual The details to be
included in the e-mails should account for the employee’s work and absent times.
The e-mails should therefore include (1) the times absent and at work either by
noting arrival and departure times or total time (such as two hours and 30 minutes)
and (2) the hours and type of leave to be charged, if applicable.

While the T&A information in the e-mails may need to be attested to by the employee
if so required by management, it must be approved by the supervisor, whether the
attestation and approval occur on some other record containing the e-mail
information or on the e-mail itself. If the employee generated the e-mail, such
generation would be considered an attestation. If the supervisor forwards the
employee’s e-mail to the timekeeper or unit where the data are sent to payroll
processing with an indication of approval, that e-mail would suffice as a T&A record
so long as it is retained under Title 8 procedures and retention period.

The phoned in material deviations can become an actual T&A record if (1) the
timekeeper, supervisor, or other official records the details of the conversation,
(2) the employee or other official subsequently attests to the recorded information by
signature or initials, when management requires an attestation, (3) the supervisor
approves such record, and (4) the record is retained under the procedures and for the
period required by Title 8.

We have discussed the contents of this letter with Ms. Nella Kusmenko of your staff.
We hope our views are helpful to you. If you or your staff have any questions, please
contact Assistant Director, Bruce Michelson, of my staff at (202) 512-9406.

Sincerely yours,

Robert W. Gramling            w
Director, Corporate Audits
 and Standards

Page 3                               GAO/AIMD-99-282R USDA T&A System Controls
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