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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:

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-03-679] GAO-03-679:

GAO Highlights:

Highlights of GAO-03-679, a report to the Chairman, Committee on 
Government Reform, U.S. House of Representatives 

Why GAO Did This Study:

Telework—work done at a location other than a traditional office—has 
gained widespread attention over the past decade as a human capital 
flexibility offering various potential benefits to employers, 
employees, and society. Using such flexibilities as management tools 
can help the federal government address its human capital challenges. 
GAO did this study in response to a congressional request to assess 
the federal government’s progress in implementing telework programs 
and to determine what else can be done to give federal employees the 
ability to telework under appropriate circumstances.

What GAO Found:

The statutory framework for federal telework requires agencies to take 
certain actions related to telework, provides agencies with tools for 
supporting telework, and provides both the Office of Personnel 
Management (OPM) and the General Services Administration (GSA) with 
lead roles and shared responsibilities for the federal telework 
initiative. Both agencies offer services and resources to support and 
encourage telework in the federal government. However, these agencies 
have not fully coordinated their telework efforts and have had 
difficulty in resolving their conflicting views on telework-related 
matters. As a consequence, agencies have not received consistent, 
inclusive, unambiguous support and guidance related to telework.

After we discussed the issues created by the lack of coordination 
between GSA and OPM with both agencies, a GSA official then indicated 
that GSA and OPM expressed a new commitment to coordination. 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.

GAO identified 25 key practices in telework-related literature and 
guidelines as those that federal agencies should implement in 
developing telework programs and grouped these practices under seven 
categories. While the four selected executive agencies we reviewed—the 
Department of Education (Education), GSA, OPM, and the Department of 
Veterans Affairs (VA)—have taken at least some steps to implement most 
of the key practices, only 7 of the 25 key practices, such as 
establishing a cross-functional project team and establishing an 
agencywide telework policy, had been fully implemented by all four 
agencies.

Although some telework-related resources from GSA and OPM provide 
federal agencies with information on how to implement several of the 
key practices we identified, agencies may need additional guidance, 
guidelines, and/or individualized technical support to fully implement 
these practices. 

What GAO Recommends:

GAO makes recommendations to the Director, OPM, and the Administrator, 
GSA, regarding further guidance and assistance they can provide to 
executive agencies in implementing telework programs. In joint 
comments, the administrator and director generally agreed with our 
recommendations and committed to taking steps towards their 
implementation. Both agencies disagreed with several findings on both 
their governmentwide and internal telework efforts. Comments from the 
Secretary, VA, and Director, Human Resources 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.

[End of section]

Contents:

Letter: 

Results in Brief:  

Background:  

Federal Laws and Their Requirements Cover a Gamut of Telework Issues:  

Lack of Clarity in OPM Guidance Led to Misleading Telework Data, but 
OPM Has Recently Taken Steps to Address This Issue:  

GSA and OPM Provide Services and Resources to Support Governmentwide 
Telework Implementation, but Their Efforts Have Not Been Well 
Coordinated:  

Selected Federal Agencies Are Not Fully Implementing Key Telework 
Practices:  

Agency Officials Identified Governmentwide Actions That Could Be Taken 
to Encourage Federal Agencies to Increase Telework Participation:  

Conclusions:  

Recommendations for Agency Action:  

Agency Comments:  

Appendixes:

Appendix I: Scope and Methodology:  

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

Program Planning:  

Telework Policy:  

Performance Management:  

Managerial Support:  

Training and Publicizing:  

Technology:  

Program Evaluation:  

Appendix III: Comments from the Department of Education:  

Appendix IV: Comments from the Department of Veterans Affairs:  

GAO Responses to Comments from VA:  

Appendix V: Comments from the General Services Administration and the 
Office of Personnel Management:  

GAO Responses to Comments from GSA and OPM:  

Table: 

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

Figures: 

Figure 1: Key Telework Practices for Implementation of Successful 
Federal Telework Programs: 

Figure 2: Extent to Which Selected Agencies Had Implemented Key 
Telework Practices: 

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:

Letter July 18, 2003:

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.[Footnote 1], 
[Footnote 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."[Footnote 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 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.[Footnote 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.):

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.[Footnote 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 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.):

Figure 1: Key Telework Practices for Implementation of Successful 
Federal Telework Programs:

[See PDF for image]

[End of figure]

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 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.

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,[Footnote 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).[Footnote 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.

Despite this level of importance, more than 59 percent of the 
respondents reported that this flexibility was not available to 
them.[Footnote 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.[Footnote 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 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.[Footnote 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,[Footnote 11] which is 5 percent of 
those agencies' 1,806,192 employees.[Footnote 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 
workers had a formal arrangement with their employer to be paid for the 
work they did at home.[Footnote 13]

Federal Laws and Their Requirements Cover a Gamut of Telework Issues:

Legislation related to telework began to emerge from Congress in 
1990.[Footnote 14] Since then, these provisions have typically, but not 
always, been included in a variety of appropriations acts and have 
covered a wide range of issues related to telework. The statutory 
framework for telework includes 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.

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."[Footnote 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.

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."[Footnote 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.[Footnote 17]

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.[Footnote 
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.[Footnote 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.[Footnote 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."[Footnote 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 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.[Footnote 22] In 1992, 
Congress established the first federal telework centers, which were to 
be maintained by GSA.[Footnote 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.[Footnote 
24]

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.[Footnote 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.[Footnote 26]

Lack of Clarity in OPM Guidance Led to Misleading Telework Data, but 
OPM Has Recently Taken Steps to Address This Issue:

Until recently, OPM had not defined a statement contained in its 
February 2001 guidance regarding the implementation of Pub. L. No. 106-
346, which told agencies that employees who wanted to participate in 
teleworking 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 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 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.[Footnote 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 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 [Hyperlink, www.telework.gov] 
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 Services and Resources to Support Governmentwide 
Telework Implementation, but Their Efforts Have Not Been Well 
Coordinated:

As discussed earlier, the legislative framework for telework has 
provided both GSA and OPM with lead roles in the implementation of 
telework in the federal government, providing each agency with 
responsibilities for the telework initiative. Given these 
responsibilities, GSA and OPM provide federal agencies with a range of 
services and resources related to this initiative. Table 1 summarizes 
their efforts in this regard.

Services and resources provided jointly by GSA and OPM: 

Run a Web site (www.telework.gov), which was designed to provide 
information and guidance; GSA and OPM: Yes.

Established and led the Interagency Telework Issues Working Group, 
which canvassed agencies to examine existing policies and produced a 
report with a series of recommendations in August 2002; GSA 
and OPM: Yes.

Services and resources provided individually by GSA and/or OPM: 

Provides guidelines for agencies implementing telework programs; 
GSA: Yes; OPM: Yes.

Conducts telework-related research and produces reports on telework 
issues; GSA: Yes; OPM: Yes.

Conducts and participates in seminars; GSA: Yes; OPM: Yes.

Develops telework training materials; GSA: Yes; OPM: Yes.

Provides customer support and consulting; GSA: Yes; OPM: Yes.

Provides general promotion, advocacy, and outreach (promotion of 
telework policy through publications, speaking engagements, brochures, 
conferences, etc.); GSA: Yes; OPM: Yes.

Is responsible for federal telework centers, including managing and 
encouraging other agencies to use the centers; GSA: Yes; OPM: No.

Offered agencies a free 60-day trial period of the telework centers 
from March through June 2002; GSA: Yes; OPM: No.

Established and maintains a mailing list server for telework 
coordinators; GSA: Yes; OPM: No.

Developed a list of agencies' telework coordinators; GSA: Yes; OPM: No.

Has an agency outreach initiative to assess program barriers and 
successes at federal agencies; GSA: No; OPM: Yes.

Hosts quarterly telework coordinators' meetings; GSA: Yes; OPM: Yes.

Source: GAO analysis of testimonial evidence and/or information and 
documentation collected.

[End of table]

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.

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,[Footnote 28] EIRO was supposed to have 
launched in March 2001 and was intended to offer services and products 
from GSA Federal Supply Schedules[Footnote 29] 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.

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 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 [Hyperlink, www.telework.gov] 
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 [Hyperlink, www.telework.gov] 
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 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 Agencies Are Not Fully Implementing Key Telework 
Practices:

We identified 25 key practices in telework-related literature and other 
sources as those that federal agencies should implement in developing 
their individual telework programs.[Footnote 30] For the purposes of 
analysis, we grouped the key practices into the following seven 
categories: program planning, telework policy, performance management, 
managerial support, 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 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.

Figure 2: Extent to Which Selected Agencies Had Implemented Key 
Telework Practices:

[See PDF for image]

[End of figure]

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 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.[Footnote 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 
those changes.[Footnote 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.[Footnote 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 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.

Agency Officials Identified Governmentwide Actions That Could Be Taken 
to Encourage Federal Agencies to Increase Telework Participation:

In addition to the key practices we identified as being integral to 
developing successful federal telework programs, we asked agency 
program officials and union representatives at GSA, Education, OPM, and 
VA for their views on what governmentwide actions could be taken to 
increase telework participation in federal agencies. We also spoke with 
officials representing federal employees governmentwide, such as the 
National Treasury Employees Union and the National Federation of 
Federal Employees, to obtain their views on potential governmentwide 
actions. In addition, OPM's November 2002 telework survey asked 
agencies about what OPM's governmentwide telework initiative could do 
to 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 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 Agency Action:

We recommend that the Administrator, GSA, 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). Once these determinations are made, GSA should issue 
guidance to the 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.[Footnote 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 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.

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.

:

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 [Hyperlink, http://www.gao.gov] 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:

Signed by J. Christopher Mihm: 

[End of section]

Appendixes: 

Appendix I: Scope and Methodology:

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 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.[Footnote 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.[Footnote 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.

[End of section]

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

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 Coordinator:

Telework resources provided by both GSA and OPM in their roles as lead 
agencies for the federal telework initiative state that, in 
implementing their telework programs, federal agencies need to 
designate agency telework coordinators and contacts.[Footnote 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-Functional Project Team, Including, for Example, 
IT, Union Representatives, and Other Stakeholders:

Our 2002 report on the effective use of flexibilities identified 
stakeholder input as a key practice for effectively using human capital 
flexibilities, such as telework.[Footnote 38] According to this report, 
agency leaders, managers, employees, and employee unions need to work 
together to develop policies and procedures, because such involvement 
helps in reaching agreement on 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 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 Telework Program Goals:

According to the International Telework Association and Council's 
(ITAC) 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.[Footnote 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 Implementation Plan for the Telework Program:

Guidelines issued by OPM in its capacity as a leader of the 
governmentwide telework initiative suggest that agencies should 
establish a strategic plan with definitive timelines to accomplish 
implementation of telework 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.[Footnote 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 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 for Implementing a Telework Program:

ITAC's e-Work Guide states that "successful telework programs reside in 
organizations that understand why they support telework, address the 
relevant issues, minimize business risk and make the investment when it 
supports their objectives."[Footnote 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.[Footnote 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 the Needs of the Telework Program:

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

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.[Footnote 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 Telework Policy:

OPM's January 2003 report to Congress stated that of the 77 reporting 
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 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 Criteria to Ensure That Teleworkers Are 
Selected on an Equitable Basis Using Criteria Such as Suitability of 
Tasks and Employee Performance:

Several telework-related sources have emphasized the need for 
eligibility 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 of both the tasks and the employee 
for telework. According to the Interagency Telework Issues Working 
Group report, criteria for determining the suitability of the employee 
should be based on objective criteria that are equitable, reasonable, 
and clearly stated and not on general 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 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 Requirements to Facilitate Communication Among 
Teleworkers, Managers, and Coworkers:

Although telework-related sources suggest that establishing policies or 
requirements to facilitate communication among teleworkers, managers, 
and coworkers is helpful in addressing managerial concerns about 
telework, teleworker isolation, and morale issues that may arise with 
nonteleworkers, two of the four agencies, Education and OPM, have fully 
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, the telework policies at 
these agencies did not establish means of facilitating communication.

Developing a Telework Agreement for Use between Teleworkers and Their 
Managers:

Telework-related literature recommends that agencies develop a telework 
agreement to be signed by both teleworkers and their supervisors. 
According to ITAC's e-Work Guide, such an agreement should establish 
job duties and expectations, performance standards, and measurable 
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 Workplace Health and Safety Issues to Ensure 
That Teleworkers Have Safe and Adequate Places to Work Off-Site:

Telework-related literature describes several means for employers to 
ensure that teleworkers have safe and adequate alternate workplaces. 
These include specifically addressing health and safety issues related 
to telework in policies, including health and safety issues in telework 
training, having teleworkers fill out a safety checklist, and 
performing on-site inspections with adequate notice to the teleworker. 
Three of the four 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.

Performance Management:

Ensuring That the Same Performance Standards, Derived from a Modern, 
Effective, and Credible Performance System, Are Used to Evaluate Both 
Teleworkers and Nonteleworkers:

Although none of the agencies have fully implemented the practice of 
ensuring that the same performance standards are used to evaluate both 
teleworkers and nonteleworkers, Education and OPM have taken some steps 
to implement this practice. Education's telework policy states that 
employees participating in the telework program shall be treated 
equally with other employees in decisions that affect conditions of 
employment for awards, promotions, and/or any other condition of 
employment. A program official at OPM said that work performed by 
teleworkers is 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 Minimize Adverse Impact on Nonteleworkers 
Before Employees Begin to Work at Alternate Worksites:

Telework-related literature suggests that performance and morale issues 
can arise if guidelines are not established to address and minimize 
adverse impacts of telework on nonteleworkers. The literature describes 
several issues that can contribute to such issues among nonteleworkers, 
including eligibility criteria that are perceived as unfair and cause 
nonteleworkers to feel left out or discriminated against, teleworkers 
that allow their in-office 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 Management for a Telework Program:

Although program officials from all four agencies recognized support 
from 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, 
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 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 Resistance to Telework:

Our 1997 report identified managerial resistance as the largest barrier 
to 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.[Footnote 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 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, Including, at a Minimum, Managers and 
Teleworkers:

Three of the four agencies that we reviewed provide some telework 
training. At Education, training for teleworkers is mandatory before 
they can begin to telework. Training is available at monthly training 
sessions, by 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 [Hyperlink, www.golearn.gov] 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 about the Telework Program:

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

Since teleworkers often require the use of IT equipment to access 
files, internal networks, and e-mail, the Environmental Protection 
Agency (EPA) suggests that agencies assess both their own and their 
employees' technology needs for telework with a mind toward providing 
employees with access to equipment similar to what they have in the 
office.[Footnote 47] In addition, ITAC's e-Work Guide reports that 
research conducted by the American Management Association found that 73 
percent of "highly 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 about Whether the Organization or Employee Will 
Provide Necessary Technology, Equipment, and Supplies for Telework:

Guidelines issued by GSA for the governmentwide telework initiative 
indicate that, while agencies are permitted, but not required, to 
provide teleworkers with equipment for use at alternate worksites, each 
agency must establish its own policies on the provision and 
installation of equipment for telework. All of the agencies we reviewed 
have established policies in this regard, stating that the agency will 
make decisions about 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 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 for Teleworkers:

According to the Interagency Telework Issues Working Group report, 
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.

Addressing Access and Security Issues Related to Telework:

The Interagency Telework Issues Working Group report states that remote 
access is a key component of telework programs, because "low-tech" 
solutions, such as floppy disks, are inadequate for most situations. It 
goes 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 Equipment in the Telework Environment:

Booz Allen Hamilton's report on technology barriers to home-based 
telework recommends that federal organizations specifically define 
technical requirements, or standards, for the home environment to 
ensure 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, 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, Procedures, and/or a Tracking System to Collect 
Data to Evaluate the Telework Program:

Even though the four agencies we studied have processes and procedures 
to collect data on their telework programs, none of them currently does 
a survey specifically related to telework or has a tracking system that 
provides accurate participation rates and other information about 
teleworkers and the program. Such lack of information not only impedes 
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 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 Issues with the Telework Program and Making 
Appropriate Adjustments:

ITAC's e-Work Guide recommends that organizations choose an evaluation 
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 necessary changes for telework or for the 
organization. It states that 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.

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.

[End of section]

Appendix III: Comments from the Department of Education:

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. 

[End of section]

Appendix IV: Comments from the Department of Veterans Affairs:

THE SECRETARY OF VETERANS AFFAIRS:

WASHINGTON June 20, 2003:

Mr. J. Christopher Mihm Director, Strategic Issues U. S. General 
Accounting Office 441 G Street, NW Washington, DC 20548:

Dear Mr. Mihm:

The Department of Veterans Affairs (VA) has reviewed your draft report, 
HUMAN CAPITAL: Further Guidance, Assistance, and Coordination Can 
Improve Federal Telework Efforts (GAO-03-679). VA is pleased to see 
that telework has been recognized as a human capital flexibility.

VA agrees with the General Accounting Office's (GAO) conclusion that 
there is a need for further guidance and assistance from the two lead 
agencies, the General Services Administration (GSA) and the Office of 
Personnel Management (OPM).

Section 359 of the Department of Transportation and Related Agencies 
Appropriations Act for 2001 (P. L. 106-346) requires each Federal 
agency to establish a policy under which eligible employees may 
participate in telework. However, the definition for eligibility 
criteria is not clear. Although OPM issued a revised definition for 
opportunity to participate, the revision does not address the larger 
issue of participant eligibility. In VA's opinion, the decision to 
participate should be predicated on position suitability with specific 
focus on tasks and responsibilities, followed by employee suitability. 
For example, if the employee is an outstanding candidate but the 
position and responsibilities do not lend themselves to a telework 
agreement, the request to participate in telework would not be 
approved. VA strongly believes that OPM needs to redefine participant 
eligibility criteria.

The report states that VA was included in the review because it had the 
distinction of being the second largest Chief Financial Officers (CFO) 
Act agency combined with its having the lowest reported telework 
utilization rate among the CFO Act agencies. However, the report does 
not recognize that the Department's limited participation rate is due 
in large part to VA's mission. 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. 
Therefore, using VA's total employee population for reporting purposes, 
rather than the number of positions that may be suitable for telework, 
does not adequately describe VA's participation rate.

GAO asserts that telework ". . also allows management and employees to 
cope with the uncertainties of potential disruptions in the workplace, 
including terrorist attacks." VA agrees and believes OPM and GSA should 
provide guidance delineating 
respective responsibilities among Federal, State, and local governments 
on how to effectively use telework in emergency situations.

On page 17, there are several factual errors regarding the extent to 
which VA has implemented the 25 key telework practices.

* Program Planning - VA has conducted pilot programs, e.g., the Veterans 
Benefits Administration (VBA) and the Board of Veterans' Appeals. 
During the course of the audit, VA forwarded a copy of VBA's pilot to 
GAO.

* Program Planning - VA has also established measurable telework program 
goals and an implementation plan.

* Telework Policy - VA has included in its revised policy a "Self-
Certification Safety Checklist.":

VA has also developed a Telework Proposal form designed to facilitate 
communication among supervisors, employees, and managers. The Telework 
Proposal form allows VA to track and evaluate the effectiveness of its 
program as well as VA's success in achieving targeted participation 
goals. The Department consistently advises supervisors and managers 
that performance standards for teleworkers and non-teleworkers should 
be the same, which is consistent with the criteria under "Performance 
Management." Under "Technology," VA's ability to conduct an assessment 
is compromised by the lack of clear guidance regarding which positions 
are suitable to telework.

The Department of Veterans Affairs appreciates the opportunity to 
comment on your draft report.

Sincerely yours,

Anthony J. Principi:

Signed by Anthony J. Principi: 

GAO Responses to Comments from VA:

1. 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.

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:

* 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.

* 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.

* 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.

* 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.

* 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.

* 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.

* 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.

[End of section]

Appendix V: Comments from the General Services Administration and the 
Office of Personnel Management:

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT:

UNITED STATES GENERAL SERVICES ADMINISTRATION:

WASHINGTON, DC:

JUN 26 2003:

GSA

OFFICE OF THE ADMINISTRATOR:

The Honorable David M. Walker Comptroller General of the United States 
The U.S. General Accounting Office 441 G Street NW, 7TH Floor 
Washington, DC 20548:

Dear Mr. Walker:

Thank you for the opportunity to respond to the General Accounting 
Office's (GAO) recent report regarding the progress of Federal agencies 
in utilizing telework. The General Services Administration (GSA) and 
the Office of Personnel Management (OPM) believe that this is a 
sufficiently important issue as to merit a joint response.

In the June 2003 draft report, Further Guidance, Assistance, and 
Coordination Can Improve Telework Efforts, the General Accounting 
Office (GAO) offered several recommendations concerning the need for 
further guidance and assistance from OPM and GSA, if we are to continue 
making progress on this important government-wide initiative. We have 
commented on each of the specific suggestions below. The response to 
GAO's evaluation of the OPM and GSA internal implementation of the 
telework program is provided at Appendices A and B.

The draft GAO report notes confusion at the implementation level 
regarding the policy guidance we have put forth to date. We were 
particularly taken aback by this finding, given the efforts we have 
made in promoting telework. For example, other GAO reports highlight 
positive results with regard to OPM's stewardship of Federal work-life 
programs, including telework. The 9-May-03 report, Human Capital. OPM 
Can Better Assist Agencies in Using Personnel Flexibilities (GAO-03-
428) states: "According to the agency officials and union 
representatives we interviewed, existing flexibilities that are most 
effective in managing the workforce are work-life policies and 
programs, such as alternative and flexible work schedules, transit 
subsidies, and child-care assistance." Issued just a month ago, the 
report goes onto note that OPM "held one-on-one meetings with more than 
30 agencies to discuss telework, learn about agency initiatives in this 
area, and find out how OPM can assist agencies in expanding telework 
opportunities."

Moreover, we have found that utilization of GSA's metropolitan 
Washington, D.C., telework centers has increased by more than 60 
percent. The joint GSA/OPM web site (www.telework.gov) has achieved 
great success since going live in August 2001. To date, more than 3,000 
customers have signed up for GSA's telework list serve as a result of 
these efforts. In the June report, GAO found a lack of clarity in OPM's 
telework guidelines regarding the legal definition of "opportunity to 
telework," and that the lack of clarity resulted in inconsistent agency 
reporting to OPM and Congress. As a result, OPM has issued immediate 
clarification in Telework: A Management Priority -A Guide for Managers, 
Supervisors, and Telework 
Coordinators, on the Frequently Asked Questions (FAQs) on the telework 
web site, and in the upcoming 2003 telework survey. OPM did this to 
ensure that the agencies clearly understand the definition, and as the 
report acknowledges, the clarified definition should now be properly 
applied by agencies in reporting data to OPM.

The GAO report also asserts that although both GSA and OPM have policy 
responsibility for telework, they have not fully coordinated efforts in 
the past. We strongly disagree with this statement. OPM and GSA work 
together as a team while recognizing our respective areas of 
responsibility. However, with the February 20, 2003, passage of Section 
623, Division B, Title V of Public Law 108-7, we revisited those areas 
of responsibility and concluded that they needed to be clarified to 
reflect new statutory direction. We had already begun that process and 
recognized the need to better outline separate and shared 
responsibilities. Among the options we are currently considering is a 
Memorandum of Understanding to clearly designate each agency's roles 
and responsibilities.

In addition, we have found a number of inaccuracies in the June report 
that were cited as indicators of a lack of coordination between our two 
agencies. For example, GAO asserts that when OPM asked GSA to review 
the OPM draft telework guide for managers, OPM revised the document 
without sharing the final draft with GSA before its release. Since OPM 
incorporated GSA's comments into the final guide, it was unnecessary to 
re-coordinate the document prior to release.

The report also states that there are unresolved disagreements between 
OPM and GSA on telework policy issues concerning dependent care and 
emergency closing of government offices. There are no such 
disagreements; rather, OPM and GSA have addressed different facets of 
these specific situations. While the responses were not in conflict, 
they have been clarified to avoid any confusion.

Similarly, the GAO report noted that GSA had expressed concerns about 
OPM's changes to the joint OPM/GSA web site. According to GSA's senior 
program executive for telework, that finding is simply inaccurate; both 
agencies continue to actively and successfully collaborate on www 
.telework.gov:

Finally, the report asserts that OPM refused to post the Interagency 
Telework Issues Working Group (ITIWG) Report on www.telework.gov 
because it raised unresolved issues relating to the program. This is 
factually incorrect. GSA and OPM jointly determined that it would be 
inappropriate to post a pre-decisional report of a working group on 
www.telework.gov until the two agencies with primary responsibility for 
the activity had an opportunity to analyze its findings, address issues 
contained therein, and fully consider all recommendations. We have 
begun that process. However, OPM and GSA continue to believe that 
posting of the ITIWG report on www.telework.gov before we have 
concluded that process is premature.

One recommendation of the ITIWG report was that OPM require all Federal 
agencies to establish a common system for collecting the data used in 
the annual report to Congress on the 
status of telework in the Federal Government. 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.

Based upon OPM's government-wide leadership role in telework, and as 
GAO points out, OPM received an FY 2003 appropriation to fund training 
for those agencies with less than two percent telework participation. 
Implementation plans are well underway. During FY 2003, OPM will launch 
a free e-training telework module for Federal managers and employees 
available on www. olg earn.gov. This summer, OPM will be conducting 
focus groups for managers in four locations across the country. The 
focus groups will be designed to identify reasons why some managers 
resist permitting telework. OPM will use the focus group data to tailor 
agency telework training. OPM plans to train the agencies' Human 
Resources Directors and telework coordinators and provide them 
promotional telework materials.

Although the "Key Telework Practices for Implementation of Successful 
Telework Programs" that GAO cites in the report are generally known 
(for example many have been included in previous OPM and GSA 
issuances), we will include GAO's list with those already incorporated 
into the training. We will also provide the GAO checklist to agencies 
and recommend that they self-assess their telework programs using the 
GAO analytical framework. Both GSA and OPM will offer to help agencies 
to improve in the identified areas of deficiency.

GAO recommends the GSA Administrator work with Congress to determine 
what was meant by the phrase "GSA telecommunications center" in Section 
314, Division F, title III of Pub.L.No.108-7 and whether there is a 
conflict with the provision contained in 40 U.S.C.587(d)(2) and issue 
guidance to relevant agencies once determinations are made. GSA will 
coordinate internally and with the appropriate congressional committees 
to resolve the conflicting language in the aforementioned statutes and 
then provide clarification to our customer agencies.

To that end, OPM and GSA's joint support of the telework program will 
continue to increase awareness and usage of this important resource. It 
is clear we all agree on the importance of telework and encouraging its 
usage in the Federal Government. We assure you we will continue to 
champion telework a key human capital flexibility and do everything 
possible to facilitate its acceptance and use.

Sincerely,

Kay Coles James, 
Director

Stephen A. Perry, 
Administrator:

Signed by Kay Coles James and Stephen A. Perry: 

Appendices:

Appendix A:

Comments on GAO Draft Report re OPM's Internal Telework Program:

This purpose of this document is to respond to GAO's Draft Report Human 
Capital: Further Guidance, Assistance, and Coordination Can Improve 
Federal Telework Efforts. GAO identified 25 key practices in telework-
related literature and other sources as those that Federal agencies 
should implement in developing their individual telework programs. GAO 
indicated that 12 of those key practices still need to be implemented 
in OPM. Comments that reflect our view of these assessments are 
provided below for each of those practices.

The categories are UNDERLINED, the practices are in italic text, and 
comments are in normal text. Each comment listed was conveyed to GAO 
during the interview process.

CATEGORIES AND PRACTICES:

PROGRAM PLANNING:

Establish measurable telework program goals.

GAO indicated that OPM has not taken any steps to implement this 
practice. This is inaccurate.	OPM has met the requirements of section 
359 of Public Law 106-346 stating that the section's requirements are 
to be applied to 25% of the federal workforce by April 2001 and to an 
additional 25% of the workforce each year thereafter. In effect, the 
legislation has provided the program goals for Federal agencies through 
2004. For 2001 and 2002, OPM has exceeded these program goals, and we 
fully expect to meet or exceed these goals in 2003 and 2004. Therefore, 
measurable telework program goals have been established for OPM.

Develop a business case for implementing a telework program.

OPM's Governmentwide guidance states that it is a business imperative 
that Telework be adopted to achieve mission goals. During training 
sessions for our managers, OPM stated that business needs are the 
driver for Telework implementation. Specifically we highlighted 
Telework's benefits towards reducing sick leave, improving morale and 
productivity, and aiding in retaining and recruiting high quality 
employees. In addition, we refer our managers to the OPM/GSA Telework 
website where the guidance on a business case for Telework is 
available. Therefore, the business case for implementing Telework has 
been developed.

Provide funding to meet the needs of the telework program.

GAO indicated that OPM has taken "some" steps to implement this 
practice. This is inaccurate. OPM earmarks specific funding each year 
to support telecenter usage ($50,000 in FY 2003). In addition, OPM has 
identified resources that have allowed us to accommodate every employee 
(who is otherwise eligible and wants to telecommute) with appropriate 
computer equipment, technology support, and remote connections. In 
addition, the agency funds staff time to provide oversight 
and evaluation for the telework program, as well as outreach and 
program promotion. In our estimation, we provide full funding to 
support our telecommuting program.

Establish a pilot program.

We question the validity of assessing us against this "practice." The 
founding legislation contained specific timelines for implementing 
telecommuting programs and did not include a requirement for 
establishing pilot programs. Although a pilot program may provide 
valuable information to be used in determining whether and how to 
implement a telecommuting program in the first place, OPM did not need 
such information to make a decision to implement a program. This point 
is strengthened by the fact that OPM had already implemented a Telework 
program within the agency and had learned valuable lessons from its use 
years before the enactment of the legislation. Thus, while our use of 
Telework was not labeled a "pilot," in effect, we learned from our 
years of experience. That experience was used to establish and redefine 
our Telework policies and procedures when the law was enacted.

The fact of the matter is that OPM carefully planned and coordinated a 
comprehensive rollout of its internal telecommuting program and 
executed the implementation of our program promptly after the 
legislation was issued. As a result of the success of these efforts, we 
boast significant numbers of telecommuters within our agency and are 
confident that a pilot program would not have added significant value 
to our program.

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.

GAO indicated that OPM has taken some steps to implement this practice. 
We believe this is inaccurate, as we have fully implemented this 
practice. Our internal policy chapter (OPM Human Resources Handbook 
Chapter 368, Subchapter 2-3 (b)), provides objective eligibility 
criteria to help ensure that teleworkers are selected on an equitable 
basis. Our policy states that employees must be performing at least at 
the Fully Successful level to participate in the Telework program. In 
addition, we adhere to the Governmentwide guidance that it is 
inappropriate to look at positions in determining whether they are 
suitable for Telework; rather, positions must be broken down into tasks 
so that a determination can be made as to which aspects of the position 
are suitable for Telework. This method allows for an increase in 
participation. Managers were informed of this during the training 
sessions, and we refer managers to the OPM/ GSA website where this is 
noted. Therefore, it would have been inappropriate and limiting to 
include specific positions by title in our Telework policy. Rather, we 
state that positions must be looked at on a case-by-case basis to 
determine what aspects of the job may be suitable for Telework. Where 
disputes have arisen, we have been able to refer to our policy 
guidelines to substantiate the 
objectivity and consistency of teleworker approval decisions. 
Therefore, we believe this assessment should be changed to reflect that 
OPM has fully implemented this practice.

Establish policies or requirements to facilitate communication among 
teleworkers, managers, and co-workers.

GAO indicated that OPM has taken some steps to implement this practice. 
This is inaccurate. OPM's telecommuting policy contains specific forms 
that serve as the basis for communication and document that roles and 
responsibilities are communicated and understood. Our policy and 
associated forms go as far as to require specific documentation of the 
types of work assignments to be accomplished and means of communication 
to be used with the employee when telecommuting (phone numbers, fax 
numbers, e-mail, etc.).	In addition, our policy specifically calls for 
supervisors to consider the impact of telecommuting on those who report 
to the office and to incorporate those considerations into the 
decision-making process (e.g., not allowing everyone to telecommute on 
Fridays; or balancing telecommuting days with other types of leave 
requests). In addition to the requirements in our Telework policy, 
managers are required to communicate with their employees during 
performance meetings, mid-year evaluations, and performance appraisals 
sessions. The importance of communication was also addressed during our 
training sessions for managers and employees. Therefore, this should be 
changed to reflect that OPM has fully implemented this practice.

Develop guidelines on workplace health and safety issues to ensure that 
teleworkers have safe and adequate places to work off-site.

GAO indicated that OPM has taken some steps to implement this practice. 
This is inaccurate. Our Telework policy provides full and specific 
guidelines on workplace health and safety issues [Subchapter 2-3(g) of 
Chapter 368 states, "Employees approved to telework must have a work 
space that is free from personal distractions and safety hazards (See 
Appendix B)."] Furthermore, Appendix B provides a Safety Checklist, 
which is used to assist in the assessment of the overall safety and 
adequacy of alternate worksites. The importance of workplace health and 
safety was also addressed during our training sessions for managers. 
Therefore, the assessment should be changed to reflect that OPM fully 
implemented this practice.

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 non-teleworkers.

GAO indicated that OPM has not taken any steps to implement this 
practice. This is inaccurate. Each employee has performance standards 
by which they are evaluated annually. The performance standards are 
based on the duties and 
responsibilities of the employee's position and are not based on 
whether the employee is a teleworker or non-teleworker-the performance 
standards are the same regardless of where the work is performed. GAO's 
assessment would imply that we use different performance standards to 
evaluate teleworkers and non-teleworkers, and this is simply not the 
case. Furthermore, this would be contrary to OPM Telework and 
Performance Management guidance which states that employees should be 
appraised based on the results of their work whether they work in a 
traditional office setting or at an alternate worksite. In addition, in 
our supervisory training, we covered the issue of performance 
management and the need to be attentive to avoiding any adverse impact 
that might be associated with not working in the traditional worksite. 
We have also provided managers with the OPM handbook on measuring 
employee performance, which specifically states that managers should 
focus on outcomes and results in appraising their employees whether 
they work traditionally in an office or at a remote location. 
Therefore, this should be changed to reflect that OPM has fully 
implemented this practice.

TRAINING AND PUBLICIZING:

Train all involved, including, at a minimum, managers and teleworkers.

GAO indicated that OPM has not taken any steps to implement this 
practice. This is inaccurate. OPM has provided extensive training to 
both managers and employees-including a mandatory training session for 
all OPM managers and supervisors. We also held other training seminars 
and briefings for employees and provided full briefings to the key 
representatives in our major program offices. In addition, our Telework 
Coordinator provides ongoing individual assistance and consultation to 
employees and managers. We also have plans for continued outreach and 
training now that our agency restructuring has been put into place. The 
positive outcome of these efforts is supported by the fact that our 
employees' response to the 2002 Federal Human Capital Survey indicate 
their satisfaction with telecommuting was significantly higher-by more 
than 14%--than the Governmentwide average. In addition, OPM sponsored a 
satellite broadcast for managers and employees hosted in the OPM 
Auditorium, which a number of OPM employees and managers attended. OPM 
also sponsored other Telework conferences/sessions in the OPM 
Auditorium attended by OPM managers and employees. Therefore, this 
assessment should be changed to reflect that OPM has fully implemented 
this practice.

TECHNOLOGY:

Establish standards for equipment in the telework environment.

GAO indicated that OPM has not taken any steps to implement this 
practice. This is inaccurate. OPM has a standard platform for 
connectivity and has established a protocol for requesting necessary 
equipment and connectivity. Given the agency's continuous process of 
upgrading computer equipment, we have been able to identify an adequate 
supply of recently-surplused equipment that is in an appropriate 
condition to be re-issued to meet teleworker needs. Furthermore, 
some offices have opted to purchase laptop computers and docking 
stations for their employees. Accordingly, this assessment should 
reflect that OPM has taken steps to fully implement this practice.

PROGRAM EVALUATION:

Establish processes, procedures, and/or tracking system to collect data 
to evaluate the telework program.

GAO indicated that OPM has taken some steps to implement this practice. 
This is inaccurate. We collect and track a variety of data that is used 
to evaluate and report on our telework program. For example, the 
biennial customer service survey conducted by the Human Capital 
Management Services (HCMS) Group provides data that allows us to assess 
satisfaction with our telework program. In addition, we track 
participation rates and require each office to submit annually specific 
information about their teleworkers for tracking by our Telework 
Coordinator. We also collect data about barriers to telecommuting. We 
use all these data to evaluate our program and inform enhancements.

The statement on this subject made on page 39 of the draft report is 
inaccurate. Section 3-1 (a) of our policy states, "Completed work 
agreements must be forwarded to the organizational telecommuting 
contact for recordkeeping purposes." Telework agreements are required 
to be in place for all teleworkers and copies of those agreements are 
maintained in a central file; reminders are sent quarterly to 
administrative contacts to provide copies of these agreements. 
Therefore, this should be changed to state that OPM has fully 
implemented this practice.

Identify problems and/or issues with the telework program and make 
appropriate adjustments.

GAO indicated that OPM has not taken any steps to implement this 
practice. This is inaccurate; the various surveys and data we collect 
are used not only to report on the number of employees teleworking in 
the agency, but also to help inform enhancements to our program. For 
example, data from our HCMS biennial survey solicits information about 
satisfaction with our program-both from employee and management 
perspectives. In addition, the Federal Human Capital Survey provides an 
indication of the success of our program. We also systematically 
solicit our supervisors' views to identify barriers to teleworking. 
Further, our Telework Coordinator receives daily comments and 
suggestions from managers and employees. All of these data sources are 
used to help shape enhancements to our telework program. Therefore, 
this should be changed to reflect that OPM has fully implemented this 
practice.

Appendix B:

Comments on GAO Draft Report re GSA's Internal Telework Program:

The following comments pertain to the GAO assessment of GSA telework 
practices in its' internal program. We believe that certain findings 
should be revised as follows:

Program Planning Practices:

-Develop an implementation plan for the telework program. "Since the 
GSA program has been in place for more than 10 years, we do not have or 
need a current "implementation plan". Instead, we have a successfully 
operating ongoing plan. The original implementation plan was utilized 
ten years ago and was not kept in the files because it is no longer in 
use."

-Provide funding to meet the needs of the telework program. "We do not 
have a central telework fund at GSA, however, individual organizations 
provide their own funding, such as is evident in the Office of 
Governmentwide Policy. Also, we have set aside the required central 
funding for telecenter utilization."

-Establish a pilot program. "As mentioned above, many years ago, we 
completed an initial pilot program. Telework, at GSA, is now an 
operational program and, consequently, there is no further need for 
piloting."

Telework Policv Practices:

Establish eligibility criteria. "GSA has specifically kept the 
eligibility criteria very broad, which we recognize lowers our 
percentage rate of participants, in order to ensure that the widest 
possible population within the agency is allowed to consider 
telework."

-Establish policies or requirements to facilitate communication among 
teleworkers, managers, and co-workers. "Although we do not have formal 
policies and requirements, we have a strong network of telework 
coordinators throughout our regions and central office organizations.	We 
also continuously provide information to our workforce on-line and 
through e-mail distribution of the GSA Update publication. We place a 
strong emphasis on communication among teleworkers, managers, and co-
workers."

Performance Management Practices:

-"GSA consistently emphasizes the importance of fairness toward 
teleworkers and others."

GAO Responses to Comments from GSA and OPM:

1. 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.

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:

* 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 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.[Footnote 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.

* 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.

* 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.

* 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.

* 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 
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 [Hyperlink, www.telework.gov] 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:

* 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,[Footnote 49] OPM discusses the importance of establishing 
program goals and objectives for telework because they will be 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.

* 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.[Footnote 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.

* OPM disputed our finding that it has only taken some steps to provide 
funding to meet the needs of the telework program. The 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.

* 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.

* OPM disagreed with our finding that it had taken some steps to 
establish eligibility criteria to ensure that teleworkers are selected 
on 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.

* 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.

* 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.

* 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 
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.

* 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.

* 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.

* 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.

* 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.[Footnote 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:

* 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.

* 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.

* 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.

* 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):

FOOTNOTES

[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).

[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.

[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.

[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.

[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.

[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).

[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.

[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.

[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.

[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.

[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).

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

[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.

[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).

[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).

[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.

[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).

[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.

[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.

[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.

[41] International Telework Association and Council, e-Work Guide, 15.

[42] Booz Allen Hamilton, ES-8 and V-2.

[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.

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

[46] GAO/GGD-97-116, 14.

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

[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).

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

[50] Booz Allen Hamilton, V-2.

[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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