United States General Accounting Office Washington, DC 20548 March 11, 2003 Mr. Robert Gardner Assistant Administrator/CFO for Finance and Administration Transportation Security Administration 701 South 12th Street, Suite 518N Arlington, VA 22202 Subject: Transmittal of Comptroller General Decision on the Transportation Security Administration’s Time and Attendance Approval System Dear Mr. Gardner: This letter is to highlight for your attention and action internal control advice we offered in our December 2002 decision1 to four certifying officers of the Department of Transportation (DOT). Their July 24, 2002 letter had requested a Comptroller General decision related to certifying payroll payments.2 A copy of the decision is enclosed. Pursuant to 31 U.S.C. § 3529(a), the four certifying officers asked us whether the method of approving an employee’s time and attendance (T&A) information in the T&A system, to which the Transportation Security Administration (TSA) is transitioning, meets the requirements of Title 6 of GAO’s Policy and Procedures Manual for Guidance of Federal Agencies (Policy and Procedures Manual). To assist you in implementing our internal control advice, we are enclosing a copy of our recently issued guidance Maintaining Effective Control Over Employee Time and Attendance Reporting, GAO-03-352G (Washington, D.C.: 3 January 2003). The certifying officers expressed three concerns with the new T&A approval system. In their view, (1) approval is not occurring at the appropriate level, (2) data will not be checked against independent sources, and (3) the proposed rounding of an employee’s start/stop time minutes will not provide a complete and accurate agency record. The certifying officers also asked whether GAO would relieve a certifying 1 See Comptroller General Decision B-291001 (Dec. 23, 2002). 2 Pursuant to 31 U.S.C. § 3529, disbursing or certifying officers or the head of an agency may request a decision from the Comptroller General in advance of payment when uncertain regarding authority to make or authorize particular payments. 3 This guidance replaces the 1996 revision to Title 6, “Pay, Leave, and Allowances” of GAO’s Policy and Procedures Manual. The requirements applied in the enclosed decision, which are from chapter 3, “Time and Attendance,” were not changed by this guidance. GAO-03-532R Title 6 Liability Relief (TSA) officer pursuant to 31 U.S.C. § 3528(b)(1)(A) if a certifying officer certified an improper or illegal payment in reliance on the new T&A approval system. To assist us in addressing the certifying officers’ three concerns, we discussed the new T&A system and related controls over T&A information with TSA officials. The enclosed Comptroller General decision addresses only the three specific concerns raised by the DOT certifying officers. We did not audit the system, otherwise, to determine whether the system contains flaws that might implicate the certifying officers’ liability in other ways. Based on our discussions with TSA officials, we determined that, in accordance with Title 6, first-line supervisors are approving T&A data. Because these supervisors will have personal knowledge of the time worked by the employees involved, they are not required to check the data against independent sources. We also determined that TSA will maintain actual original entry records along with a trail of all changes to data to support what we consider to be the immaterial rounding of employee time in and time out data. We have, however, identified additional control-related steps that TSA management should build into the T&A approval system as it further develops and implements it. To better support a future request for certifying officer relief should the T&A system, in fact, generate an improper payment, TSA officials should implement the T&A approval system as described to us and build the following control-related steps into it: 1. Conduct Federal Managers’ Financial Integrity Act reviews with a focus on ensuring that the new system is working as designed, the accuracy of the T&A data is maintained, and certifying officers are provided with assurances to this effect. 2. Specify in detail in TSA guidance the specific roles and responsibilities of first- line supervisors. 3. Communicate rounding rules for T&A time data to all affected staff. 4. Ensure the rounding rules for T&A time data are consistently applied. 5. Ensure that rounded and actual T&A data can be compared and tested once the T&A system is fully implemented. Page 2 GAO-03-532R Title 6 Liability Relief (TSA) We have discussed the contents of this letter with Jeffrey Bobich, of your staff, and he has informed us that TSA will build these steps into its T&A process. If you or your staff have any questions, please contact me at (202) 512-6906 or Mary Mohiyuddin, Assistant Director, at (202) 512-3087. Sincerely yours, McCoy Williams Director Financial Management and Assurance Enclosures Page 3 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 4 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 5 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 6 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 7 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 8 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 9 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure Page 10 GAO-03-532R Title 6 Liability Relief (TSA) Enclosure (195003) Page 11 GAO-03-532R Title 6 Liability Relief (TSA)
Transmittal of Comptroller General Decision on the Transportation Security Administration's Time and Attendance Approval System
Published by the Government Accountability Office on 2003-03-11.
Below is a raw (and likely hideous) rendition of the original report. (PDF)