oversight

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)

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.




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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

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