USDA T&A System Controls

GAO provided information on the internal control requirements in Title 6, "Pay, Leave, and Allowances," of GAO's Policy and Procedures Manual for Guidance of Federal Agencies, as they relate to the Department of Agriculture's Marketing and Regulatory Programs' staff time and attendance (T&A) records, focusing on: (1) if employees are required to sign for their arrival/departure time when recording deviations from their preapproved declared schedule; and (2) in lieu of signing in/out times for deviations to the preapproved work schedule, whether employees could use electronic mail (e-mail) or phone in their actual pay period schedule.

GAO noted that: (1) section 3.8 of Title 6 states that when employees' arrival and departure times for a pay period are established, these schedules become the basis for recording T&A data unless material variance or deviations occur; (2) material deviations must be approved by the supervisor and are required to be recorded; (3) Title 6 provides for flexibility in establishing what are material deviations; (4) it states that unless otherwise designated by management, a material deviation from an established schedule is one that differs by one hour or more during a workday; (5) management can establish the amount of time at which a material deviation from a preapproved work schedule occurs; (6) the deviation established by management should be based on an assessment of the risks involved and the needs of the agency; the work environment, including the type of work performed and the internal control existing to assess productivity and record work times and absences; and the work habits of the employees; (7) immaterial deviations need not be recorded; (8) the supervisor should be aware of such deviations and should verify that the employee has adequately compensated the agency for the deviation; (9) it should be noted that although immaterial deviations need not be recorded in most instances, supervisors may find it necessary from time-to-time for all deviations to be recorded for certain employees or under certain situations and should be permitted to require such recordings; (10) for the purposes of simply notifying a supervisor of a material deviation, Title 6 would allow an employee to communicate the change in any manner that management approved, including by e-mail or phone; (11) however, if the e-mail or phone communication is to become an actual T&A record to serve as documentation for the employees' pay, then the e-mail should be archived or the phone conversation documented; (12) the e-mails should contain adequate details of the material deviation and be retained for the proper period and stored under adequate procedures as required in Title 8, "Records Management" of the GAO Policy and Procedures Manual; and (13) the phoned in material deviations can become an actual T&A record if: (a) the timekeeper, supervisor, or other official records the details of the conversation; (b) the employee or other official subsequently attests to the recorded information by signature or initials, when management requires attestation; (c) the supervisor approves such record; and (d) the record is retained under the procedures and for the period required by Title 8.