oversight

Human Capital: Further Guidance, Assistance, and Coordination Can Improve Federal Telework Efforts

Published by the Government Accountability Office on 2003-07-18.

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

             United States General Accounting Office

GAO          Report to the Chairman, Committee on
             Government Reform, House of
             Representatives


July 2003
             HUMAN CAPITAL
             Further Guidance,
             Assistance, and
             Coordination Can
             Improve Federal
             Telework Efforts




GAO-03-679
             a
                                               July 2003


                                               HUMAN CAPITAL

                                               Further Guidance, Assistance, and
Highlights of GAO-03-679, a report to the
Chairman, Committee on Government
                                               Coordination Can Improve Federal
Reform, U.S. House of Representatives          Telework Efforts


Telework—work done at a location               The statutory framework for federal telework requires agencies to take
other than a traditional office—has            certain actions related to telework, provides agencies with tools for
gained widespread attention over               supporting telework, and provides both the Office of Personnel Management
the past decade as a human capital             (OPM) and the General Services Administration (GSA) with lead roles and
flexibility offering various potential         shared responsibilities for the federal telework initiative. Both agencies
benefits to employers, employees,
and society. Using such
                                               offer services and resources to support and encourage telework in the
flexibilities as management tools              federal government. However, these agencies have not fully coordinated
can help the federal government                their telework efforts and have had difficulty in resolving their conflicting
address its human capital                      views on telework-related matters. As a consequence, agencies have not
challenges. GAO did this study in              received consistent, inclusive, unambiguous support and guidance related to
response to a congressional request            telework.
to assess the federal government’s
progress in implementing telework              After we discussed the issues created by the lack of coordination between
programs and to determine what                 GSA and OPM with both agencies, a GSA official then indicated that GSA
else can be done to give federal               and OPM expressed a new commitment to coordination. Such a
employees the ability to telework              commitment reflects a promising start for better assisting federal agencies in
under appropriate circumstances.
                                               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,
GAO makes recommendations to                   services, and resources on the governmentwide telework initiative.
the Director, OPM, and the
Administrator, GSA, regarding                  GAO identified 25 key practices in telework-related literature and guidelines
further guidance and assistance                as those that federal agencies should implement in developing telework
they can provide to executive                  programs and grouped these practices under seven categories. While the
agencies in implementing telework
                                               four selected executive agencies we reviewed—the Department of
programs. In joint comments, the
administrator and director                     Education (Education), GSA, OPM, and the Department of Veterans Affairs
generally agreed with our                      (VA)—have taken at least some steps to implement most of the key
recommendations and committed                  practices, only 7 of the 25 key practices, such as establishing a cross-
to taking steps towards their                  functional project team and establishing an agencywide telework policy, had
implementation. Both agencies                  been fully implemented by all four agencies.
disagreed with several findings on
both their governmentwide and                  Although some telework-related resources from GSA and OPM provide
internal telework efforts.                     federal agencies with information on how to implement several of the key
Comments from the Secretary, VA,               practices we identified, agencies may need additional guidance, guidelines,
and Director, Human Resources                  and/or individualized technical support to fully implement these practices.
Services, Education, also generally
agreed with our report, but VA
disagreed with several findings.
Our characterizations were
generally accurate, but we made
changes in response to agencies’
comments, as appropriate.
www.gao.gov/cgi-bin/getrpt?GAO-03-679.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact J. Christopher
Mihm at (202) 512-6806 or mihmj@gao.gov.
Contents



Letter                                                                                                    1
                             Results in Brief                                                             3
                             Background                                                                   8
                             Federal Laws and Their Requirements Cover a Gamut of Telework
                               Issues                                                                    11
                             Lack of Clarity in OPM Guidance Led to Misleading Telework Data,
                               but OPM Has Recently Taken Steps to Address This Issue                    15
                             GSA and OPM Provide Services and Resources to Support
                               Governmentwide Telework Implementation, but Their Efforts
                               Have Not Been Well Coordinated                                            17
                             Selected Federal Agencies Are Not Fully Implementing Key
                               Telework Practices                                                        22
                             Agency Officials Identified Governmentwide Actions That Could Be
                               Taken to Encourage Federal Agencies to Increase Telework
                               Participation                                                             29
                             Conclusions                                                                 29
                             Recommendations for Agency Action                                           30
                             Agency Comments                                                             31


Appendixes
              Appendix I:    Scope and Methodology                                                       35
             Appendix II:    Descriptions of Efforts by the Selected Agencies to
                             Implement the 25 Key Practices                                              37
                             Program Planning                                                            37
                             Telework Policy                                                             42
                             Performance Management                                                      46
                             Managerial Support                                                          47
                             Training and Publicizing                                                    49
                             Technology                                                                  50
                             Program Evaluation                                                          54
             Appendix III:   Comments from the Department of Education                                   57
             Appendix IV:    Comments from the Department of Veterans Affairs                            58
                             GAO Responses to Comments from VA                                           60
              Appendix V:    Comments from the General Services Administration and the
                             Office of Personnel Management                                              63
                             GAO Responses to Comments from GSA and OPM                                  72




                             Page i                            GAO-03-679 Improving Federal Telework Efforts
          Contents




Table     Table 1: Summary of Services and Resources Provided or Offered
                   by GSA and OPM                                                                18


Figures   Figure 1: Key Telework Practices for Implementation of Successful
                    Federal Telework Programs                                                        5
          Figure 2: Extent to Which Selected Agencies Had Implemented Key
                    Telework Practices                                                           24




          Abbreviations

          CFO          Chief Financial Officers
          DOE          Department of Energy
          DOI          Department of the Interior
          EIRO         E-Connected Intelligent Remote Operations
          EPA          Environmental Protection Agency
          GSA          General Services Administration
          IT           information technology
          ITAC         International Telework Association and Council
          OPM          Office of Personnel Management
          MSPB         U.S. Merit Systems Protection Board
          VA           Department of Veterans Affairs


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          Page ii                                   GAO-03-679 Improving Federal Telework Efforts
A
United States General Accounting Office
Washington, D.C. 20548



                                    July 18, 2003                                                                              Leter




                                    The Honorable Tom Davis, Chairman
                                    Committee on Government Reform
                                    House of Representatives

                                    Dear Mr. Chairman:

                                    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, 2 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.”3

                                    This report is in response to your request that we assess various aspects of
                                    the progress federal agencies have made in implementing telecommuting
                                    initiatives. In this regard, and as agreed with your staff, the objectives of
                                    this report were to (1) characterize the federal laws and their requirements
                                    that currently apply to telecommuting within the federal agencies in the
                                    executive branch, (2) determine what the General Services Administration
                                    (GSA) and OPM are doing, as lead agencies, to coordinate and promote
                                    telecommuting in the federal government, (3) determine the extent to


                                    1
                                     Throughout this report, the terms telework, telecommuting, and flexiplace are used
                                    interchangeably.
                                    2
                                     For more information on telework in the federal government, see U.S. General Accounting
                                    Office, Federal Workforce: Agencies’ Policies and Views on Flexiplace in the Federal
                                    Government, GAO/GGD-97-116 (Washington, D.C.: July 3, 1997) and Telecommuting:
                                    Overview of Challenges Facing Federal Agencies, GAO-01-1116T (Washington, D.C.: Sept. 6,
                                    2001).
                                    3
                                     U.S. Office of Personnel Management, Report to the Congress: The Status of Telework in
                                    the Federal Government (Washington, D.C.: Jan. 2003).




                                    Page 1                                     GAO-03-679 Improving Federal Telework Efforts
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.4 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.)




4
 Size and level of telework participation were determined from survey data collected by
OPM for its January 2002 report to Congress, entitled The Status of Telework in the Federal
Government.




Page 2                                     GAO-03-679 Improving Federal Telework Efforts
Results in Brief   A statutory framework including legislation on a wide range of issues
                   related to telework began to emerge from Congress in 1990. Within this
                   statutory framework, there are 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. The most
                   significant congressional action related to telework was the enactment of
                   Sec. 359 of Pub. L. No. 106-346 in October 2000, which provides the current
                   mandate for telework in the executive branch of the federal government by
                   requiring each executive agency to establish a policy under which eligible
                   employees may participate in telework.5 OPM issued guidance to agencies
                   in 2001 related to the implementation of this law. However, until recently,
                   OPM had not defined a statement contained in that guidance which told
                   agencies that eligible employees who wanted to telework 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 telework guidelines
                   that defined what it meant by allowing this opportunity. If this new
                   definition is properly applied by all agencies in reporting data to OPM, this
                   should address the issue we found.

                   As lead agencies for the governmentwide telework initiative, both GSA and
                   OPM offer services and resources to support and encourage telework in the
                   federal government. Some of the services and resources are offered jointly
                   by both GSA and OPM, while others are offered individually by both
                   agencies or uniquely by either GSA or OPM. 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 were not well
                   coordinated. For example, 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. With regard to dependent care, officials from
                   both GSA and OPM confirmed that they had different positions on this


                   5
                    Section 359 of Pub. L. No. 106-346, October 23, 2000. Hereafter, this section of the law will
                   be referred to as Pub. L. No. 106-346.




                   Page 3                                       GAO-03-679 Improving Federal Telework Efforts
issue. 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. After we discussed these
conflicting messages with OPM officials, OPM revised its position on this
issue in the new telework guidelines it released shortly thereafter. These
guidelines state that while teleworkers should not generally be engaged in
caregiving activities when working at home, teenagers or elderly
dependents might be at home when the employee is teleworking, as long as
those dependents are independently pursuing their own activities. Because
such lack of coordination can create confusion for agencies and
employees, we are recommending that the Administrator, GSA, and the
Director, OPM, ensure that their offices with responsibilities for the
governmentwide telework initiative better coordinate efforts to provide
federal agencies with consistent, inclusive, unambiguous support and
guidance related to telework.

We identified 25 key practices in telework-related literature and guidelines
that federal agencies should implement in developing successful telework
programs. For purposes of analysis, we grouped these practices under
seven categories. (See fig. 1.)




Page 4                              GAO-03-679 Improving Federal Telework Efforts
Figure 1: Key Telework Practices for Implementation of Successful Federal Telework Programs
 Program planning
 • Designate a telework coordinator.
 • Establish a cross-functional project team, including, for example, information technology (IT), union representatives, and other
   stakeholders.
 • 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.
 • Establish a pilot program.

 Telework policy
 • Establish an agencywide telework policy.
 • 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.
 • Develop guidelines on workplace health and safety issues to ensure that teleworkers have safe and adequate places to work off-site.

 Performance management
 • Ensure that the same performance standards, derived from a modern, effective, credible, and validated performance system, are
   used to evaluate both teleworkers and nonteleworkers.
 • Establish guidelines to minimize adverse impact on nonteleworkers before employees begin to work at alternate worksites.

 Managerial support
 • Obtain support from top management for a telework program.
 • Address managerial resistance to telework.

 Training and publicizing
 • Train all involved, including, at a minimum, managers and teleworkers.
 • Inform workforce about the telework program.

 Technology
 • Conduct assessment of teleworker and organization technology needs.
 • Develop guidelines about whether 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.
 • Establish standards for equipment in the telework environment.

 Program evaluation
 • Establish processes, procedures, and/or a tracking system to collect data to evaluate the telework program.
 • Identify problems and/or issues with the telework program and make appropriate adjustments.
Source: GAO analysis of telework-related literature and guidelines.




                                                                      Page 5                   GAO-03-679 Improving Federal Telework Efforts
While all four agencies we reviewed have taken at least some steps to
implement most of the key practices, many practices remain in need of
attention. Seven of the key practices, such as establishing a cross-
functional project team and establishing an agencywide telework policy,
had been fully implemented by all four agencies. However, in each of the
categories, there were practices that some or all of the agencies had not
implemented or had only partially implemented. For example, none of the
agencies reviewed have established measurable program goals or fully
implemented the practice of training all involved. To enable agencies to
more effectively implement these practices, we are recommending that
GSA and OPM use their lead roles in the federal telework initiative to assist
executive agencies in implementing the key telework practices.

In addition to the key practices we identified as being integral to
developing successful federal telework programs, we asked agency and
union officials from the four agencies we reviewed to identify
governmentwide actions that could be taken to encourage federal agencies
to increase telework participation. Some of the actions they identified 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. Several officials also commented
on the need for clarification regarding the implementation of the telework
provisions in Pub. L. No. 106-346.

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.

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. 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. VA 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



Page 6                              GAO-03-679 Improving Federal Telework Efforts
evidence that would support VA’s comments, our assessment remains
unchanged.

In their combined comments, GSA and OPM 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 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. GSA and OPM 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 “[E]ach comment listed
was conveyed to GAO during the interview process.” On the contrary,
OPM’s written 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 revised the report where appropriate to reflect OPM’s new
positions on some issues. While GSA did not disagree with our findings
pertaining to its internal telework program, 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.




Page 7                               GAO-03-679 Improving Federal Telework Efforts
Background   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,6 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).7 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.




             6
              The Federal Emergency Management Agency has recently become part of the new
             Department of Homeland Security under the department’s Emergency Preparedness and
             Response Directorate.
             7
             U.S. Merit Systems Protection Board, Issues of Merit (Washington, D.C.: Dec. 2000), 4.




             Page 8                                    GAO-03-679 Improving Federal Telework Efforts
Despite this level of importance, more than 59 percent of the respondents
reported that this flexibility was not available to them.8

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.9 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


8
 U.S. Office of Personnel Management, What do Federal Employees Say: Results from the
2002 Federal Human Capital Survey (Washington, D.C.: Mar. 2003).
9
 See Pub. L. No. 102-393, October 6, 1992, and Sections 5 and 6 of title V of Pub. L. No. 104-
52, November 19, 1995. According to House Report No. 102-618, June 25, 1992, that
accompanied Pub. L. No. 102-393, telework centers make alternative office-like
environments available to federal employees to perform their office functions at a site
closer to their homes. These centers are intended to address traffic congestion issues, as
well as to confer other benefits, including reduced government real estate costs and a better
work/life balance for federal employees.




Page 9                                       GAO-03-679 Improving Federal Telework Efforts
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.10

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,11 which is 5 percent of those agencies’ 1,806,192
employees.12 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




10
 Interagency Telework Issues Working Group, Interagency Governmentwide Policy
Review on Telework and Telework-Related Issues (Washington, D.C.: Aug. 2002).
11
 Episodic telework refers to a situation in which a teleworker does not telework on a
regularly scheduled basis. This type of arrangement is also referred to by a variety of
names, including “ad hoc,” “intermittent,” “occasional,” and “as needed.”
12
 U.S. Office of Personnel Management, Report to the Congress: The Status of Telework in
the Federal Government (Jan. 2003).




Page 10                                     GAO-03-679 Improving Federal Telework Efforts
                         workers had a formal arrangement with their employer to be paid for the
                         work they did at home.13



Federal Laws and Their   Legislation related to telework began to emerge from Congress in 1990.14
                         Since then, these provisions have typically, but not always, been included
Requirements Cover a     in a variety of appropriations acts and have covered a wide range of issues
Gamut of Telework        related to telework. The statutory framework for telework includes
                         provisions that require agencies to take certain actions related to telework,
Issues                   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.”15 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.




                         13
                            U.S. Department of Labor, Bureau of Labor Statistics, Work at Home in 2001, USDL 02-107
                         (Washington, D.C.: Mar. 1, 2002), http://www.bls.gov/news.release/homey.nr0.htm
                         (downloaded July 1, 2003). Half of those who usually worked at home were wage and salary
                         workers who took work home on an unpaid basis. Another 30 percent of those who worked
                         at home were self-employed.
                         14
                          Congressional committees have also held hearings on telework. The House Education and
                         the Workforce Committee, Subcommittee on Oversight and Investigations, held a series of
                         hearings in 1999 and 2000 to examine barriers to telework implementation in federal
                         agencies. In 2001, the House Government Reform Committee, Subcommittee on
                         Technology and Procurement Policy, held two hearings to examine the efforts of federal
                         government agencies in creating and promoting telework programs. GAO testified at one of
                         these hearings in September 2001. (See GAO-01-1116T.)
                         15
                              Section 359 of Pub. L. No. 106-346, October 23, 2000.




                         Page 11                                        GAO-03-679 Improving Federal Telework Efforts
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.”16 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.17




16
     Section 359 of H.R. Report No. 106-940, October 5, 2000.
17
 U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for
Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003), 2, 25.




Page 12                                        GAO-03-679 Improving Federal Telework Efforts
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.18 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.19

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.20 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.”21 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



18
     40 U.S.C. 587(c)(2).
19
     Section 623, Division B, title VI of Pub. L. No. 108-7, February 20, 2003.
20
     40 U.S.C. 587(d)(2).
21
 See Section 323 of Pub. L. No. 106-291, October 11, 2000; Section 319 of Pub. L. No. 107-63,
November 5, 2001; and Section 314, Division F, title III of Pub. L. No. 108-7, February 20,
2003. A similar provision was also included in Section 324 of title III of the Appendix to Pub.
L. No. 106-113, November 29, 1999.




Page 13                                          GAO-03-679 Improving Federal Telework Efforts
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 1995.22 In 1992, Congress established the first
federal telework centers, which were to be maintained by GSA.23 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.24




22
     Section 620 of Pub. L. No. 104-52, November 19, 1995, 31 U.S.C. 1348 note.
23
     Pub. L. No. 102-393, October 6, 1992.
24
 See, for example, Pub. L. No. 103-123, October 26, 1993; Sections 5 and 6 of title V of Pub. L.
No. 104-52, November 19, 1995; Section 407 of Pub. L. No. 104-208, September 30, 1996; and
Section 411 of Pub. L. No. 105-277, October 21, 1998.




Page 14                                        GAO-03-679 Improving Federal Telework Efforts
                         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.25 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.26



Lack of Clarity in OPM   Until recently, OPM had not defined a statement contained in its February
                         2001 guidance regarding the implementation of Pub. L. No. 106-346, which
Guidance Led to          told agencies that employees who wanted to participate in teleworking
Misleading Telework      must be allowed that opportunity. Without such a definition, we found that
                         the agencies we reviewed did not use equivalent interpretations of this
Data, but OPM Has        statement, resulting in their reporting incomparable data to OPM. These
Recently Taken Steps     data were subsequently included in OPM’s 2003 report to Congress on the
to Address This Issue    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


                         25
                              H.R. Report No. 108-10, February 13, 2003, p. 1352.
                         26
                              Pub. L. No. 102-393, October 6, 1992; 40 U.S.C. 587(b)(1) and (c)(3).




                         Page 15                                         GAO-03-679 Improving Federal Telework Efforts
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.27
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


27
 U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for
Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).




Page 16                                GAO-03-679 Improving Federal Telework Efforts
                         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.



GSA and OPM Provide      As discussed earlier, the legislative framework for telework has provided
                         both GSA and OPM with lead roles in the implementation of telework in the
Services and             federal government, providing each agency with responsibilities for the
Resources to Support     telework initiative. Given these responsibilities, GSA and OPM provide
                         federal agencies with a range of services and resources related to this
Governmentwide           initiative. Table 1 summarizes their efforts in this regard.
Telework
Implementation, but
Their Efforts Have Not
Been Well Coordinated

                         Page 17                             GAO-03-679 Improving Federal Telework Efforts
Table 1: Summary of Services and Resources Provided or Offered by GSA and OPM

Services and resources provided jointly by GSA and OPM                                         GSA and OPM
Run a Web site (www.telework.gov), which was designed to provide                                     X
information and guidance
Established and led the Interagency Telework Issues Working Group,                                   X
which canvassed agencies to examine existing policies and produced
a report with a series of recommendations in August 2002


Services and resources provided individually by GSA and/or OPM                                 GSA       OPM
Provides guidelines for agencies implementing telework programs                                  X        X
Conducts telework-related research and produces reports on telework                              X        X
issues
Conducts and participates in seminars                                                            X        X
Develops telework training materials                                                             X        X
Provides customer support and consulting                                                         X        X
Provides general promotion, advocacy, and outreach (promotion of                                 X        X
telework policy through publications, speaking engagements,
brochures, conferences, etc.)
Is responsible for federal telework centers, including managing and                              X
encouraging other agencies to use the centers
Offered agencies a free 60-day trial period of the telework centers from                         X
March through June 2002
Established and maintains a mailing list server for telework                                     X
coordinators
Developed a list of agencies’ telework coordinators                                              X
Has an agency outreach initiative to assess program barriers and                                          X
successes at federal agencies
Hosts quarterly telework coordinators’ meetings                                                           X
Source: GAO analysis of testimonial evidence and/or information and documentation collected.


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.




Page 18                                                       GAO-03-679 Improving Federal Telework Efforts
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,28 EIRO was supposed to have launched in March 2001 and was
intended to offer services and products from GSA Federal Supply
Schedules29 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.




28
     www.eiro.gsa.gov.
29
 GSA’s Federal Supply Schedules are contracts that allow federal customers to acquire
services and products directly from commercial suppliers.




Page 19                                   GAO-03-679 Improving Federal Telework Efforts
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



Page 20                              GAO-03-679 Improving Federal Telework Efforts
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



Page 21                            GAO-03-679 Improving Federal Telework Efforts
                         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.



Selected Federal         We identified 25 key practices in telework-related literature and other
                         sources as those that federal agencies should implement in developing
Agencies Are Not Fully   their individual telework programs.30 For the purposes of analysis, we
Implementing Key         grouped the key practices into the following seven categories: program
                         planning, telework policy, performance management, managerial support,
Telework Practices       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




                         30
                           The 25 key practices identified for telework programs are also closely aligned with 6 key
                         practices we have identified in our earlier work for effectively using human capital
                         flexibilities. See U.S. General Accounting Office, Human Capital: Effective Use of
                         Flexibilities Can Assist Agencies in Managing Their Workforces, GAO-03-2 (Washington,
                         D.C.: Dec. 6, 2002) and Managing for Results: Building on the Momentum for Strategic
                         Human Capital Reform, GAO-02-528T (Washington, D.C.: Mar. 18, 2002).




                         Page 22                                     GAO-03-679 Improving Federal Telework Efforts
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.




Page 23                             GAO-03-679 Improving Federal Telework Efforts
Figure 2: Extent to Which Selected Agencies Had Implemented Key Telework Practices




                                                                                                                                                          on
                                                                                                                                                      at i
                                                                                                                                                     uc



                                                                                                                                                                M
                                                                                                                                                           A
                                                                                                                                                          GS

                                                                                                                                                               OP
                                                                                                                                                    Ed




                                                                                                                                                                    VA
Categories and practices
Program planning
Designate a telework coordinator.
Establish a cross-functional project team, including, for example, IT, union representatives, and other stakeholders.
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.
Establish a pilot program.
Telework policy
Establish an agencywide telework policy.
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.
Develop guidelines on workplace health and safety issues to ensure that teleworkers have safe and adequate places to work off-site.
Performance management
Ensure that the same performance standards, derived from a modern, effective, credible, and validated performance system, are used to
evaluate both teleworkers and nonteleworkers.
Establish guidelines to minimize adverse impact on nonteleworkers before employees begin to work at alternate worksites.
Managerial support
Obtain support from top management for a telework program.
Address managerial resistance to telework.
Training and publicizing
Train all involved, including, at a minimum, managers and teleworkers.
Inform workforce about the telework program.
Technology
Conduct assessment of teleworker and organization technology needs.
Develop guidelines about whether 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.
Establish standards for equipment in the telework environment.
Program evaluation
Establish processes, procedures, and/or a tracking system to collect data to evaluate the telework program.
Identify problems and/or issues with the telework program and make appropriate adjustments.
                                                                       Agency has fully implemented this practice
                                                                       Agency has taken some steps to implement this practice
                                                                       Agency has not taken any steps to implement this practice
                                                                       Could not assess
Source: GAO analysis of testimonial evidence and/or information and documentation collected.




                                                                   Page 24                                               GAO-03-679 Improving Federal Telework Efforts
                   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.



Program Planning   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.



Telework Policy    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


                   Page 25                            GAO-03-679 Improving Federal Telework Efforts
                         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.



Performance Management   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.31 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.



Managerial Support       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




                         31
                          U.S. General Accounting Office, Results-Oriented Cultures: Creating a Clear Linkage
                         between Individual Performance and Organizational Success, GAO-03-488 (Washington,
                         D.C.: Mar. 14, 2003).




                         Page 26                                 GAO-03-679 Improving Federal Telework Efforts
                           those changes.32 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.33 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.



Training and Publicizing   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.



Technology                 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


                           32
                            See, for example, the following GAO products: Human Capital: Effective Use of
                           Flexibilities Can Assist Agencies in Managing Their Workforces, GAO-03-2 (Washington,
                           D.C.: Dec. 6, 2002); A Model of Strategic Human Capital Management—Exposure Draft,
                           GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); Managing for Results: Next Steps To
                           Improve the Federal Government’s Management and Performance, GAO-O2-439T
                           (Washington, D.C.: Feb. 15, 2002); and Human Capital: Practices That Empowered and
                           Involved Employees, GAO-01-1070 (Washington, D.C.: Sept. 14, 2001). Also see Booz Allen
                           Hamilton, Analysis of Home-Based Telework Technology Barriers: Final Report on
                           Technology Barriers to Home-Based Telework (Washington, D.C.: Apr. 5, 2002) and U.S.
                           Environmental Protection Agency, Telecommuting/Telework Programs: Implementing
                           Commuter Benefits under the Commuter Choice Leadership Initiative (Washington, D.C.:
                           Sept. 2001).
                           33
                                GAO/GGD-97-116.




                           Page 27                                  GAO-03-679 Improving Federal Telework Efforts
                     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.



Program Evaluation   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.




                     Page 28                             GAO-03-679 Improving Federal Telework Efforts
Agency Officials        In addition to the key practices we identified as being integral to
                        developing successful federal telework programs, we asked agency
Identified              program officials and union representatives at GSA, Education, OPM, and
Governmentwide          VA for their views on what governmentwide actions could be taken to
                        increase telework participation in federal agencies. We also spoke with
Actions That Could Be   officials representing federal employees governmentwide, such as the
Taken to Encourage      National Treasury Employees Union and the National Federation of
Federal Agencies to     Federal Employees, to obtain their views on potential governmentwide
                        actions. In addition, OPM’s November 2002 telework survey asked
Increase Telework       agencies about what OPM’s governmentwide telework initiative could do to
Participation           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.



Conclusions             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



                        Page 29                              GAO-03-679 Improving Federal Telework Efforts
                      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.



Recommendations for   We recommend that the Administrator, GSA, work with Congress to
                      determine what was meant by the phrase “GSA telecommunication center”
Agency Action         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



                      Page 30                              GAO-03-679 Improving Federal Telework Efforts
                  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.34 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.



Agency Comments   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

                  34
                   U.S. General Accounting Office, Human Capital: OPM Can Better Assist Agencies in
                  Using Personnel Flexibilities, GAO-03-428 (Washington, D.C.: May 9, 2003).




                  Page 31                                 GAO-03-679 Improving Federal Telework Efforts
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.



Page 32                             GAO-03-679 Improving Federal Telework Efforts
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 “[E]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.




Page 33                              GAO-03-679 Improving Federal Telework Efforts
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.

Sincerely yours,




J. Christopher Mihm
Director, Strategic Issues




Page 34                              GAO-03-679 Improving Federal Telework Efforts
Appendix I

Scope and Methodology                                                                        AA
                                                                                              ppp
                                                                                                ep
                                                                                                 ned
                                                                                                   n
                                                                                                   x
                                                                                                   id
                                                                                                    e
                                                                                                    x
                                                                                                    Iis




             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



             Page 35                             GAO-03-679 Improving Federal Telework Efforts
Appendix I
Scope and Methodology




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.35 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.36 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.




35
 Size and level of telework participation were determined from survey data collected by
OPM for its January 2002 Report to Congress, entitled The Status of Telework in the Federal
Government.
36
  In its comments, VA noted 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,” which it considers to be a significant factor accounting for its
limited telework participation rate.




Page 36                                      GAO-03-679 Improving Federal Telework Efforts
Appendix II

Descriptions of Efforts by the Selected
Agencies to Implement the 25 Key Practices                                                                              Appendx
                                                                                                                              Ii




                              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.



Program Planning

Designating a Telework        Telework resources provided by both GSA and OPM in their roles as lead
Coordinator                   agencies for the federal telework initiative state that, in implementing their
                              telework programs, federal agencies need to designate agency telework
                              coordinators and contacts.37 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.



Establishing a Cross-         Our 2002 report on the effective use of flexibilities identified stakeholder
Functional Project Team,      input as a key practice for effectively using human capital flexibilities, such
                              as telework.38 According to this report, agency leaders, managers,
Including, for Example, IT,
                              employees, and employee unions need to work together to develop policies
Union Representatives, and    and procedures, because such involvement helps in reaching agreement on
Other Stakeholders            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

                              37
                               In the fiscal year 2003 appropriations for the Departments of Commerce, Justice, and
                              State, the Judiciary, and the Small Business Administration, these departments and agencies
                              are required, amongst other things, to designate a telework coordinator to oversee the
                              implementation of their telecommuting programs. See Section 623, Division B, title VI of
                              Pub. L. No. 108-7, February 20, 2003.
                              38
                                   GAO-03-2, 32.




                              Page 37                                    GAO-03-679 Improving Federal Telework Efforts
                              Appendix II
                              Descriptions of Efforts by the Selected
                              Agencies to Implement the 25 Key Practices




                              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.



Establishing Measurable       According to the International Telework Association and Council’s (ITAC)
Telework Program Goals        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.39 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.



Developing an                 Guidelines issued by OPM in its capacity as a leader of the governmentwide
Implementation Plan for the   telework initiative suggest that agencies should establish a strategic plan
                              with definitive timelines to accomplish implementation of telework
Telework Program
                              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.40 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


                              39
                               International Telework Association and Council, e-Work Guide: How to Make Telework
                              Work for Your Organization (Washington, D.C.: 2000), 3.
                              40
                                   International Telework Association and Council, e-Work Guide, 22.




                              Page 38                                       GAO-03-679 Improving Federal Telework Efforts
                             Appendix II
                             Descriptions of Efforts by the Selected
                             Agencies to Implement the 25 Key Practices




                             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.



Developing a Business Case   ITAC’s e-Work Guide states that “successful telework programs reside in
for Implementing a           organizations that understand why they support telework, address the
                             relevant issues, minimize business risk and make the investment when it
Telework Program             supports their objectives.”41 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.42 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.



Providing Funding to Meet    Telework-related literature suggests that agencies should incorporate
the Needs of the Telework    requirements for home-based telework into their IT capital planning and
                             budgeting processes and provide for consistent allocation of the resources
Program
                             necessary to establish telework arrangements, such as the equipment and
                             technology needed for remote access to agency networks. However,

                             41
                                  International Telework Association and Council, e-Work Guide, 15.
                             42
                                  Booz Allen Hamilton, ES-8 and V-2.




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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.43 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.44

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


43
 Section 623, Division B, title VI of Pub. L. No. 108-7 also provides $100,000 to the
Departments of Commerce, Justice, and State, the Judiciary, and the Small Business
Administration for the implementation of telecommuting programs.
44
 Expenditures for fiscal year 2002 telework center use at the four agencies were included in
OPM’s January 2003 report to Congress, entitled The Status of Telework in the Federal
Government. OPM used data gathered by GSA for reporting these expenditures.




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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.




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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.45
                               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.



Telework Policy

Establishing an Agencywide     OPM’s January 2003 report to Congress stated that of the 77 reporting
Telework Policy                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


                               45
                                Commuter Connections, A Practical Approach to Implementing Telework Programs
                               (Washington, D.C.: 2002), 81.




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                               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.



Establishing Eligibility       Several telework-related sources have emphasized the need for eligibility
Criteria to Ensure That        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
Teleworkers Are Selected
                               of both the tasks and the employee for telework. According to the
on an Equitable Basis Using    Interagency Telework Issues Working Group report, criteria for
Criteria Such as Suitability   determining the suitability of the employee should be based on objective
of Tasks and Employee          criteria that are equitable, reasonable, and clearly stated and not on general
Performance                    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



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                             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.



Establishing Policies or     Although telework-related sources suggest that establishing policies or
Requirements to Facilitate   requirements to facilitate communication among teleworkers, managers,
                             and coworkers is helpful in addressing managerial concerns about
Communication Among
                             telework, teleworker isolation, and morale issues that may arise with
Teleworkers, Managers, and   nonteleworkers, two of the four agencies, Education and OPM, have fully
Coworkers                    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,




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                               the telework policies at these agencies did not establish means of
                               facilitating communication.



Developing a Telework          Telework-related literature recommends that agencies develop a telework
Agreement for Use between      agreement to be signed by both teleworkers and their supervisors.
                               According to ITAC’s e-Work Guide, such an agreement should establish job
Teleworkers and Their          duties and expectations, performance standards, and measurable
Managers                       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.



Developing Guidelines on       Telework-related literature describes several means for employers to
Workplace Health and           ensure that teleworkers have safe and adequate alternate workplaces.
                               These include specifically addressing health and safety issues related to
Safety Issues to Ensure That   telework in policies, including health and safety issues in telework training,
Teleworkers Have Safe and      having teleworkers fill out a safety checklist, and performing on-site
Adequate Places to Work        inspections with adequate notice to the teleworker. Three of the four
Off-Site                       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.




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Performance
Management

Ensuring That the Same       Although none of the agencies have fully implemented the practice of
Performance Standards,       ensuring that the same performance standards are used to evaluate both
                             teleworkers and nonteleworkers, Education and OPM have taken some
Derived from a Modern,
                             steps to implement this practice. Education’s telework policy states that
Effective, and Credible      employees participating in the telework program shall be treated equally
Performance System, Are      with other employees in decisions that affect conditions of employment for
Used to Evaluate Both        awards, promotions, and/or any other condition of employment. A
Teleworkers and              program official at OPM said that work performed by teleworkers is
Nonteleworkers               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
                             “[t]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.



Establishing Guidelines to   Telework-related literature suggests that performance and morale issues
Minimize Adverse Impact on   can arise if guidelines are not established to address and minimize adverse
                             impacts of telework on nonteleworkers. The literature describes several
Nonteleworkers Before
                             issues that can contribute to such issues among nonteleworkers, including
Employees Begin to Work at   eligibility criteria that are perceived as unfair and cause nonteleworkers to
Alternate Worksites          feel left out or discriminated against, teleworkers that allow their in-office



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                             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.



Managerial Support

Obtaining Support from Top   Although program officials from all four agencies recognized support from
Management for a Telework    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,
Program                      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



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                         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.



Addressing Managerial    Our 1997 report identified managerial resistance as the largest barrier to
Resistance to Telework   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.46 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




                         46
                              GAO/GGD-97-116, 14.




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                           a means of alleviating managerial resistance, but this has not yet happened
                           because of managerial resistance to such a change.



Training and
Publicizing

Training All Involved,     Three of the four agencies that we reviewed provide some telework
Including, at a Minimum,   training. At Education, training for teleworkers is mandatory before they
                           can begin to telework. Training is available at monthly training sessions, by
Managers and Teleworkers
                           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


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                           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.



Informing the Workforce    Telework-related literature suggests that it is important to inform the
about the Telework         workforce about opportunities to telework. Two of the agencies, GSA and
                           OPM, have fully implemented this practice for their internal telework
Program
                           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.



Technology

Conducting an Assessment   Since teleworkers often require the use of IT equipment to access files,
of Teleworker and          internal networks, and e-mail, the Environmental Protection Agency (EPA)
                           suggests that agencies assess both their own and their employees’
Organization Technology    technology needs for telework with a mind toward providing employees
Needs                      with access to equipment similar to what they have in the office.47 In
                           addition, ITAC’s e-Work Guide reports that research conducted by the
                           American Management Association found that 73 percent of “highly

                           47
                            Environmental Protection Agency, Telecommuting/Telework Programs: Implementing
                           Commuter Benefits Under the Commuter Choice Leadership Initiative (Washington, D.C.:
                           Sept. 2001), 8.




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                             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.



Developing Guidelines        Guidelines issued by GSA for the governmentwide telework initiative
about Whether the            indicate that, while agencies are permitted, but not required, to provide
                             teleworkers with equipment for use at alternate worksites, each agency
Organization or Employee
                             must establish its own policies on the provision and installation of
Will Provide Necessary       equipment for telework. All of the agencies we reviewed have established
Technology, Equipment, and   policies in this regard, stating that the agency will make decisions about
Supplies for Telework        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



                             Page 51                                      GAO-03-679 Improving Federal Telework Efforts
                              Appendix II
                              Descriptions of Efforts by the Selected
                              Agencies to Implement the 25 Key Practices




                              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.



Providing Technical Support   According to the Interagency Telework Issues Working Group report,
for Teleworkers               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.




                              Page 52                                      GAO-03-679 Improving Federal Telework Efforts
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                             Descriptions of Efforts by the Selected
                             Agencies to Implement the 25 Key Practices




Addressing Access and        The Interagency Telework Issues Working Group report states that remote
Security Issues Related to   access is a key component of telework programs, because “low-tech”
                             solutions, such as floppy disks, are inadequate for most situations. It goes
Telework                     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.



Establishing Standards for   Booz Allen Hamilton’s report on technology barriers to home-based
Equipment in the Telework    telework recommends that federal organizations specifically define
                             technical requirements, or standards, for the home environment to ensure
Environment                  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,



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                             Descriptions of Efforts by the Selected
                             Agencies to Implement the 25 Key Practices




                             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.



Program Evaluation

Establishing Processes,      Even though the four agencies we studied have processes and procedures
Procedures, and/or a         to collect data on their telework programs, none of them currently does a
                             survey specifically related to telework or has a tracking system that
Tracking System to Collect   provides accurate participation rates and other information about
Data to Evaluate the         teleworkers and the program. Such lack of information not only impedes
Telework Program             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



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                              Descriptions of Efforts by the Selected
                              Agencies to Implement the 25 Key Practices




                              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.



Identifying Problems and/or   ITAC’s e-Work Guide recommends that organizations choose an evaluation
Issues with the Telework      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
Program and Making            necessary changes for telework or for the organization. It states that
Appropriate Adjustments       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.




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Descriptions of Efforts by the Selected
Agencies to Implement the 25 Key Practices




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.




Page 56                                      GAO-03-679 Improving Federal Telework Efforts
Appendix III

Comments from the Department of Education                                                     Appendx
                                                                                                    iI




               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.




               Page 57                            GAO-03-679 Improving Federal Telework Efforts
Appendix IV

Comments from the Department of Veterans
Affairs                                                                        Appendx
                                                                                     iIV




Note: GAO comments
supplementing those in
the report text appear
at the end of this
appendix.




See comment 1.




See comment 2.




See comment 1.




                         Page 58   GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the Department of Veterans
                  Affairs




See comment 3a.


See comment 3b.

See comment 3c.


See comment 3d.

See comment 3e.

See comment 3f.

See comment 3g.




                  Page 59                                    GAO-03-679 Improving Federal Telework Efforts
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                   Comments from the Department of Veterans
                   Affairs




GAO Responses to   1. VA agreed with our conclusion that there is a need for further guidance
                      and assistance from GSA and OPM regarding federal telework
Comments from VA      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.




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Comments from the Department of Veterans
Affairs




   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.



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Appendix IV
Comments from the Department of Veterans
Affairs




   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.




Page 62                                    GAO-03-679 Improving Federal Telework Efforts
Appendix V

Comments from the General Services
Administration and the Office of Personnel
Management                                                                     Append
                                                                                    x
                                                                                    i
                                                                                    V




Note: GAO comments
supplementing those in
the report text appear
at the end of this
appendix.




See comment 3a.




See comment 3a.




                         Page 63   GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 3b.




See comment 3c.




See comment 3b.




See comment 3d.




See comment 3e.




See comment 4k.




                  Page 64                                      GAO-03-679 Improving Federal Telework Efforts
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                 Comments from the General Services
                 Administration and the Office of Personnel
                 Management




See comment 1.




See comment 2.




See comment 1.




                 Page 65                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 4.




See comment 4a.




See comment 4b.




See comment 4c.




                  Page 66                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 4d.




See comment 4e.




                  Page 67                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 4f.




See comment 4g.




See comment 4h.




                  Page 68                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 4i.




See comment 4j.




                  Page 69                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 4k.




See comment 4l.




                  Page 70                                      GAO-03-679 Improving Federal Telework Efforts
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                  Comments from the General Services
                  Administration and the Office of Personnel
                  Management




See comment 5.




See comment 5a.




See comment 5b.




See comment 5c.



See comment 5d.




                  Page 71                                      GAO-03-679 Improving Federal Telework Efforts
                    Appendix V
                    Comments from the General Services
                    Administration and the Office of Personnel
                    Management




GAO Responses to    1. In their combined comments, GSA and OPM agreed that telework is an
                       important tool for federal agencies and stated that they would
Comments from GSA      encourage and champion telework as a key human capital flexibility
and OPM                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



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Comments from the General Services
Administration and the Office of Personnel
Management




        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. 48
        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.




48
 U.S. General Accounting Office, Human Capital: OPM Can Better Assist Agencies in
Using Personnel Flexibilities, GAO-03-428 (Washington, D.C.: May 9, 2003).




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Comments from the General Services
Administration and the Office of Personnel
Management




   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



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Comments from the General Services
Administration and the Office of Personnel
Management




        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 “[E]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, “[i]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,49 OPM discusses the importance of establishing
        program goals and objectives for telework because they will be


49
 U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for
Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).




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          helpful in conducting program evaluations of a telework program.
          OPM’s guide notes that “[k]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.50 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


50
     Booz Allen Hamilton, V-2.




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       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



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       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



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       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.




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   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 “[c]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.



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     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.51 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.



51
 U.S. Office of Personnel Management, Telework: A Management Priority—A Guide for
Managers, Supervisors, and Telework Coordinators (Washington, D.C.: May 2003).




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              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.




(450126)   Page 82                                      GAO-03-679 Improving Federal Telework Efforts
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