Human Capital: Further Guidance, Assistance, and Coordination Can
Improve Federal Telework Efforts (18-JUL-03, GAO-03-679).	 
                                                                 
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.					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-679 					        
    ACCNO:   A07591						        
  TITLE:     Human Capital: Further Guidance, Assistance, and	      
Coordination Can Improve Federal Telework Efforts		 
     DATE:   07/18/2003 
  SUBJECT:   Federal agencies					 
	     Telecommuting					 
	     Interagency relations				 
	     Personnel management				 
	     Human resources utilization			 

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GAO-03-679

                                       A

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

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

GAO- 03- 679

Contents Letter 1

Results in Brief 3 Background 8 Federal Laws and Their Requirements Cover
a Gamut of Telework Issues 11

Lack of Clarity in OPM Guidance Led to Misleading Telework Data, but OPM
Has Recently Taken Steps to Address This Issue 15 GSA and OPM Provide
Services and Resources to Support

Governmentwide Telework Implementation, but Their Efforts Have Not Been
Well Coordinated 17 Selected Federal Agencies Are Not Fully Implementing
Key Telework Practices 22

Agency Officials Identified Governmentwide Actions That Could Be Taken to
Encourage Federal Agencies to Increase Telework Participation 29
Conclusions 29 Recommendations for Agency Action 30 Agency Comments 31

Appendixes

Appendix I: Scope and Methodology 35

Appendix II: Descriptions of Efforts by the Selected Agencies to Implement
the 25 Key Practices 37 Program Planning 37 Telework Policy 42 Performance
Management 46 Managerial Support 47 Training and Publicizing 49 Technology
50 Program Evaluation 54

Appendix III: Comments from the Department of Education 57

Appendix IV: Comments from the Department of Veterans Affairs 58 GAO
Responses to Comments from VA 60

Appendix V: Comments from the General Services Administration and the
Office of Personnel Management 63 GAO Responses to Comments from GSA and
OPM 72

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

Figures Figure 1: Key Telework Practices for Implementation of Successful
Federal Telework Programs 5

Figure 2: Extent to Which Selected Agencies Had Implemented Key Telework
Practices 24

Abbreviations

CFO Chief Financial Officers DOE Department of Energy DOI Department of
the Interior EIRO E- Connected Intelligent Remote Operations EPA
Environmental Protection Agency GSA General Services Administration IT
information technology

ITAC International Telework Association and Council OPM Office of
Personnel Management MSPB U. S. Merit Systems Protection Board VA
Department of Veterans Affairs

This is a work of the U. S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

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. 1, 2 The term telework refers to work that is
performed at an employee*s home or at a work location

other than a traditional office. Using such readily available
flexibilities as management tools is critical to addressing the federal
government*s human capital challenges. In the Office of Personnel
Management*s (OPM) 2003 report to Congress on the status of telework in
the federal government, the Director of OPM described telework as *an
invaluable management tool which not only allows employees greater
flexibility to balance their

personal and professional duties, but also allows both management and
employees to cope with the uncertainties of potential disruptions in the
workplace, including terrorist threats.* 3 This report is in response to
your request that we assess various aspects of

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

1 Throughout this report, the terms telework, telecommuting, and
flexiplace are used interchangeably. 2 For more information on telework in
the federal government, see U. S. General Accounting Office, Federal
Workforce: Agencies* Policies and Views on Flexiplace in the Federal
Government, GAO/ GGD- 97- 116 (Washington, D. C.: July 3, 1997) and
Telecommuting: Overview of Challenges Facing Federal Agencies, GAO- 01-
1116T (Washington, D. C.: Sept. 6, 2001).

3 U. S. Office of Personnel Management, Report to the Congress: The Status
of Telework in the Federal Government (Washington, D. C.: Jan. 2003).

which selected federal agencies are implementing key practices in
developing telecommuting programs, and (4) identify additional
governmentwide actions that could be taken to encourage federal agencies
to increase telecommuting participation.

We took several steps to address these objectives. In order to
characterize the federal laws and their requirements that currently apply
to telecommuting within the federal agencies in the executive branch, we
identified and analyzed the relevant laws and discussed the requirements
of selected laws with agency officials. To determine what GSA and OPM are
doing to coordinate and promote telecommuting in the federal government,
we interviewed GSA and OPM officials regarding their governmentwide

telework efforts and analyzed documents related to these efforts. We
determined the extent to which selected federal agencies are implementing
key practices in developing telecommuting programs by first conducting a
review of literature and guidelines to identify these practices. Then, we
interviewed agency officials and analyzed documents related to telework

implementation at four agencies* the Department of Education (Education),
the Department of Veterans Affairs (VA), GSA, and OPM. These agencies were
selected for various reasons, including function, size,

and reported level of telework participation. 4 This agency selection
process was not designed to produce findings that could be considered
representative of telework implementation in the federal government as a
whole, but rather to provide illustrative examples of the extent to which
selected individual agencies had used the key practices identified in our
literature review. To identify additional governmentwide actions that
could be taken to encourage federal agencies to increase telecommuting
participation, we interviewed officials and union representatives from the
four selected agencies, as well as other unions representing federal
employees. Our review was conducted in accordance with generally accepted
government auditing standards. (See app. I for additional information on
our scope and methodology.)

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

Results in Brief A statutory framework including legislation on a wide
range of issues related to telework began to emerge from Congress in 1990.
Within this

statutory framework, there are provisions that require agencies to take
certain actions related to telework, provide agencies with tools for
supporting telework, and provide both GSA and OPM with lead roles in the
implementation of telework in the federal government. The most significant
congressional action related to telework was the enactment of Sec. 359 of
Pub. L. No. 106- 346 in October 2000, which provides the current

mandate for telework in the executive branch of the federal government by
requiring each executive agency to establish a policy under which eligible
employees may participate in telework. 5 OPM issued guidance to agencies
in 2001 related to the implementation of this law. However, until
recently,

OPM had not defined a statement contained in that guidance which told
agencies that eligible employees who wanted to telework must be allowed
that opportunity. Without such a definition, we found that the agencies we
reviewed did not use equivalent interpretations of this statement,
resulting in their reporting incomparable data to OPM. These data were
subsequently included in OPM*s 2003 report to Congress on the status of
telework in the federal government. After we discussed this issue with OPM
officials, OPM reacted promptly by issuing new telework guidelines that
defined what it meant by allowing this opportunity. If this new definition
is properly applied by all agencies in reporting data to OPM, this should
address the issue we found.

As lead agencies for the governmentwide telework initiative, both GSA and
OPM offer services and resources to support and encourage telework in the
federal government. Some of the services and resources are offered jointly
by both GSA and OPM, while others are offered individually by both
agencies or uniquely by either GSA or OPM. Although GSA and OPM share
responsibilities for the governmentwide telework initiative and a GSA
official recently indicated that GSA and OPM have expressed a new
commitment to working together, their past efforts were not well
coordinated. For example, a GSA official told us that agencies had
expressed concern about conflicting messages they had received from GSA
and OPM on several topics, including dependent care and emergency
government office closings. With regard to dependent care, officials from
both GSA and OPM confirmed that they had different positions on this

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

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 Program planning

 Designate a telework coordinator.  Establish a cross- functional
project team, including, for example, information technology (IT), union
representatives, and other stakeholders.  Establish measurable telework
program goals.  Develop an implementation plan for the telework program.
 Develop a business case for implementing a telework program.  Provide
funding to meet the needs of the telework program.  Establish a pilot
program. Telework policy  Establish an agencywide telework policy.

 Establish eligibility criteria to ensure that teleworkers are selected
on an equitable basis using criteria such as suitability of tasks and
employee performance.  Establish policies or requirements to facilitate
communication among teleworkers, managers, and coworkers.  Develop a
telework agreement for use between teleworkers and their managers. 
Develop guidelines on workplace health and safety issues to ensure that
teleworkers have safe and adequate places to work off- site.

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

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

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

Technology  Conduct assessment of teleworker and organization technology
needs.  Develop guidelines about whether organization or employee will
provide necessary technology, equipment, and supplies for telework. 
Provide technical support for teleworkers.  Address access and security
issues related to telework.  Establish standards for equipment in the
telework environment.

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

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
crossfunctional 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, 6 along with telework- related literature, also suggests

that telework programs can facilitate emergency preparedness by helping
agencies to maintain continuity of operations in emergency situations,
thereby increasing agencies* effectiveness. In light of the uncertainties
facing the United States today, telework can be a particularly relevant
and useful tool. The importance of telework to federal employees has been
highlighted in recent studies. Based on its 2000 Merit Principles Survey,
the U. S. Merit

Systems Protection Board (MSPB) reported that, of all the family- friendly
programs studied, telework showed the greatest disparity between
importance and availability, potentially making it the most desired but
least available family- friendly program. In addition, the MSPB said that,
of all the work- life programs it asked about in the survey, only telework
appeared to have a relationship to employees* intentions regarding leaving
their employment in the coming year, with those who considered telework
important being more likely to plan to leave when it is not available (55

percent) than when it is available (44 percent). 7 According to OPM*s 2002
Federal Human Capital Survey, almost 74 percent of federal employee
respondents said that telework was at least somewhat important to them.

6 The Federal Emergency Management Agency has recently become part of the
new Department of Homeland Security under the department*s Emergency
Preparedness and Response Directorate.

7 U. S. Merit Systems Protection Board, Issues of Merit (Washington, D.
C.: Dec. 2000), 4.

Despite this level of importance, more than 59 percent of the respondents
reported that this flexibility was not available to them. 8 Since 1990,
Congress has supported the telework initiative by holding

hearings and passing a number of laws related to telework, including laws
that provided for the establishment and funding of the GSA telework
centers. 9 Most significant was the Department of Transportation and

Related Agencies Appropriations Act, 2001, Pub. L. No. 106- 346, October
23, 2000. Section 359 of this law provides the current mandate for
telework in the executive branch of the federal government. This law,
which was to be implemented in 25 percent increments over 4 years,
required each federal agency to *establish a policy under which eligible
employees of the

agency may participate in telecommuting to the maximum extent possible
without diminished employee performance* and instructed OPM to provide for
the law*s requirements to be met. Telework has also received significant
attention in the executive branch since 1990, when the President*s Council
on Management Improvement approved plans for the implementation of a
governmentwide pilot flexiplace program. In the executive branch, telework
has been proposed as a tool to address a number of issues, including
establishing a familyfriendly workplace, reducing traffic congestion and
pollution, and enabling people with disabilities to join the federal
workforce. Currently, GSA and OPM share responsibilities for the federal
government*s telework initiative, providing federal agencies with services
and resources related to this initiative. To this end, both GSA and OPM
have included strategies, goals,

and measures directly related to their efforts to support the
governmentwide telework initiative in their fiscal year 2003 annual
performance plans and their related strategic plans. For example, GSA*s
fiscal year 2003 performance plan includes a goal to increase the
percentage of federal employees that telework to 5 percent by the end of
fiscal year 2003 under its performance goal to increase the number of

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

agency programs meeting their social and environmental responsibilities in
areas of GSA*s Office of Governmentwide Policy responsibility. Also among
efforts in the executive branch was the formation of an

Interagency Telework Issues Working Group, with participants from 15
federal agencies. GSA and OPM jointly established and led this group,
which canvassed agencies to identify policy actions needed to facilitate

agency use and expansion of telework. A final report, issued in August
2002, contained a series of recommendations related to such policy
actions. 10

Interest in and implementation of telework programs has also occurred in
states and foreign countries. Several states piloted telework programs in
state government agencies in the mid- to late 1990s and have since
implemented telework in individual agencies or on a statewide basis. For
example, in Florida, telework became a permanent option for state
employees in October 1998 after two 3- year pilot studies. In Europe,
about 6 percent of the workforce was teleworking as of 1999 and, in some
countries, the participation rate for telework was higher. Finland, for
example, had a telework participation rate of about 17 percent of the
workforce in 1999. However, only 4 percent of all teleworkers in European
countries worked for government entities.

According to OPM*s January 2003 report to Congress on the status of
telework in the federal government, 77 executive agencies reported that,
as of November 2002, 90, 010 of their employees teleworked on either a
regular

or episodic basis, 11 which is 5 percent of those agencies* 1,806, 192
employees. 12 The U. S. Department of Labor reported that, in May 2001,
19. 8 million persons, accounting for 15 percent of total employment,
usually did some work at home as part of their job. However, only 17
percent of these

10 Interagency Telework Issues Working Group, Interagency Governmentwide
Policy Review on Telework and Telework- Related Issues (Washington, D. C.:
Aug. 2002). 11 Episodic telework refers to a situation in which a
teleworker does not telework on a regularly scheduled basis. This type of
arrangement is also referred to by a variety of names, including *ad hoc,*
*intermittent,* *occasional,* and *as needed.*

12 U. S. Office of Personnel Management, Report to the Congress: The
Status of Telework in the Federal Government (Jan. 2003).

workers had a formal arrangement with their employer to be paid for the
work they did at home. 13

Federal Laws and Their Legislation related to telework began to emerge
from Congress in 1990. 14 Requirements Cover a

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 Gamut of Telework

related to telework. The statutory framework for telework includes Issues

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.* 15 It
also directed OPM to provide that the law*s requirements were applied to
25 percent of the federal workforce by April 2001 and to an additional 25
percent of the federal workforce in each subsequent year, until 2004 when
the law is to be applied to 100 percent of the federal workforce. The
requirements of this law should also be considered in combination with its
conference report and guidance that has been issued by OPM. 13 U. S.
Department of Labor, Bureau of Labor Statistics, Work at Home in 2001,
USDL 02- 107

(Washington, D. C.: Mar. 1, 2002), http:// www. bls. gov/ news. release/
homey. nr0. htm (downloaded July 1, 2003). Half of those who usually
worked at home were wage and salary workers who took work home on an
unpaid basis. Another 30 percent of those who worked at home were self-
employed. 14 Congressional committees have also held hearings on telework.
The House Education and the Workforce Committee, Subcommittee on Oversight
and Investigations, held a series of hearings in 1999 and 2000 to examine
barriers to telework implementation in federal agencies. In 2001, the
House Government Reform Committee, Subcommittee on Technology and
Procurement Policy, held two hearings to examine the efforts of federal
government agencies in creating and promoting telework programs. GAO
testified at one of these hearings in September 2001. (See GAO- 01-
1116T.)

15 Section 359 of Pub. L. No. 106- 346, October 23, 2000.

The conference report accompanying Pub. L. No. 106- 346 stated that
agencies shall *develop criteria to be used in implementing [a
telecommuting] policy* and *ensure that managerial, logistical,
organizational, or other barriers to full implementation and successful
functioning of the policy are removed.* 16 Furthermore, it stated that
agencies *should also provide for adequate administrative, human
resources, technical, and logistical support for carrying out the policy.*
It

also clarified what constitutes eligibility for telework by defining an
eligible employee as *any satisfactorily performing employee of the agency
whose job may typically be performed at least one day per week [by
telecommuting].*

On February 9, 2001, OPM sent a memorandum to department and agency heads
containing guidance on the requirements of Pub. L. No. 106- 346 that
directed agencies to examine the barriers that inhibit the use of
telecommuting, act to remove them, and increase participation. This
memorandum went on to say, *The law recognizes that not all positions are
appropriate for telecommuting; therefore, each agency must identify
positions that are appropriate in a manner that focuses on broad objective
criteria. Once an agency has established eligibility criteria, subject to
any applicable agency policies or bargaining obligations, employees who
meet them and want to participate must be allowed that opportunity if they
are satisfactory performers.* OPM recently clarified this statement in a
publication entitled, Telework: A Management Priority* A Guide for
Managers, Supervisors, and Telework Coordinators. This guide, which was
released on May 8, 2003, indicates that agencies should offer eligible
employees the opportunity to telework by having supervisors extend the
option of teleworking to all employees they determine are eligible, using
established criteria. 17 16 Section 359 of H. R. Report No. 106- 940,
October 5, 2000.

17 U. S. Office of Personnel Management, Telework: A Management Priority*
A Guide for Managers, Supervisors, and Telework Coordinators (Washington,
D. C.: May 2003), 2, 25.

Congress also passed other laws that require agencies to take certain
actions related to telework. One such provision requires executive
agencies to consider whether needs for additional space can be met using
alternative workplace arrangements, such as telework. 18 Another recent

provision, contained in the fiscal year 2003 appropriations for the
Departments of Commerce, Justice, and State, the Judiciary, and the Small
Business Administration, makes $100, 000 available to each of the
departments and agencies covered by this provision only for the
implementation of telecommuting programs. These departments and agencies
are required to provide the committees on appropriations with a

report on the status of their telecommuting programs every 6 months and to
designate a *Telework Coordinator* to oversee the implementation of
telecommuting programs. 19

In addition to these provisions, another provision directs executive
agencies to make a minimum of $50,000 available annually for the necessary
expenses to carry out telecommuting programs, which would permit employees
of 20 specified federal departments and agencies, including Education,
GSA, OPM, VA, the Department of the Interior (DOI),

and the Department of Energy (DOE), to perform all or a portion of their
duties at GSA telework centers. 20 However, a provision has been included
in the appropriations acts for DOI and related agencies since fiscal year
2001 prohibiting several departments and agencies, including DOI and

DOE, from using appropriated funds for the use of *GSA telecommunication
centers.* 21 GSA officials believe that the provisions contained in these
appropriations laws were intended to apply to GSA telework centers.
However, this remains unclear, because these statutes pertain to *GSA
telecommunication centers,* which is not a title by which the GSA telework
centers are known. At least in some instances, though, this provision has
not been applied to the telework centers. OPM*s January 2003 report to
Congress identified two of the agencies prohibited from

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

using funds as described by this provision* DOI and DOE* as having
provided funds for telework center usage fees in fiscal year 2002.

Generally, when statutory provisions in separate laws are in conflict, as
may be the case with the laws detailed above, the requirements of the most
recently passed law supercede the requirements of the earlier law. In this
case, the provision prohibiting the use of funds for *GSA
telecommunication centers* would take precedence over the provision that

requires specified agencies to make $50,000 available annually for use of
the GSA telework centers, but only for those departments or agencies that
are common to both provisions. However, because of the lack of a
definition or explanation for *GSA telecommunication centers* in the
appropriations law and the fact that the legislative history does not
provide any insight, it is not clear whether the provisions are in
conflict. Given that both of these provisions refer to one or more types
of GSA operations, GSA should work with Congress to determine what was
meant by the phrase *GSA telecommunication centers* and then issue
guidance to the relevant agencies to clarify these provisions and explain
the impact of these laws on agencies* telework programs.

Congress has also provided agencies with several tools to support
telework. For example, federal agencies were authorized to spend money for
installation of telephone lines, related equipment, and monthly charges
for federal teleworkers through legislation that was originally enacted in
1990 and made permanent in 1995. 22 In 1992, Congress established the
first federal telework centers, which were to be maintained by GSA. 23
Since then, Congress has passed several laws to continue funding the
centers, change the formula for funding the centers, and add new telework
center locations. 24

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

The legislative framework for telework also contains provisions that
provide both GSA and OPM with lead roles in the implementation of telework
in the federal government. As stated above, Pub. L. No. 106- 346 directs
OPM to provide that the requirements of the law are applied as specified
with regard to the federal workforce. In addition, $500,000 of the money
appropriated for OPM*s salaries and expenses for fiscal year 2003 is

intended to be used by OPM to provide a telecommuting training program to
educate managers in executive branch agencies, where less than 2 percent
of employees telework, about the benefits and logistics of

telework. 25 According to OPM*s comments on a draft of this report, the
agency plans to conduct focus groups for managers in four locations across
the country this summer to identify reasons why some managers resist
permitting telework. OPM plans to use the focus group data to tailor
agency telework training. OPM indicated that it plans to train agencies*
human resources directors and telework coordinators and provide them
promotional telework materials. Congress has also provided GSA with a lead
role in the federal government*s telework initiative, giving the agency
responsibility for maintaining the federal telework centers and the

authority to provide guidance, assistance, and oversight regarding the
establishment and operation of telework and other distributive work
arrangements. 26

Lack of Clarity in OPM Until recently, OPM had not defined a statement
contained in its February

Guidance Led to 2001 guidance regarding the implementation of Pub. L. No.
106- 346, which

told agencies that employees who wanted to participate in teleworking
Misleading Telework

must be allowed that opportunity. Without such a definition, we found that
Data, but OPM Has

the agencies we reviewed did not use equivalent interpretations of this
Recently Taken Steps

statement, resulting in their reporting incomparable data to OPM. These
data were subsequently included in OPM*s 2003 report to Congress on the

to Address This Issue status of telework in the federal government. After
we discussed this issue

with OPM officials, OPM reacted promptly by issuing new guidelines that
defined what it meant by allowing this opportunity.

Our discussions with officials at the four agencies we reviewed and
analysis of data in OPM*s January 2003 report to Congress revealed that,
without a definition from OPM regarding what constituted being allowed

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

the opportunity to telework, agencies had not always used equivalent
interpretations of this statement in reporting their data. For example,
telework program officials at both GSA and OPM told us that, for their

internal programs, they considered eligible employees to have been allowed
the opportunity to telework if they chose to apply for telework or discuss
the option of teleworking with their managers, regardless of whether they
were actually approved for telework. In keeping with this interpretation,
these two agencies reported, in response to OPM*s 2002 governmentwide
telework survey, that essentially the same number of employees who were
eligible for telework had also been given that

opportunity. On the other hand, Education and VA reported significant
differences between the number of employees who were eligible for telework
and those who were given the opportunity to telework, which demonstrated
that they were using different interpretations of opportunity than GSA and
OPM. Because these agencies were not applying equivalent interpretations
of the term *opportunity,* the data that they provided in response to
OPM*s survey and that OPM included in its report to Congress

were not comparable across agencies. Moreover, OPM*s 2003 report to
Congress showed these data as the number of eligible employees *offered*
telework, although OPM had not made it clear, in either the survey or in
its previously issued guidance, that agencies should interpret allowing
the opportunity to mean directly offering eligible employees the option to
telework. Furthermore, characterizing all agencies* data in this manner is
misleading because, as shown above, some agencies did not use that
interpretation in reporting the data.

We met with OPM officials in late April 2003 and informed them that the
lack of a written definition of what OPM meant when it asked agencies to
report how many eligible employees had been allowed the opportunity to
telework had resulted in incomparable telework data. To its credit, OPM
reacted promptly by defining the statement in a set of frequently asked
questions that were distributed at its quarterly telework coordinators*

meeting on May 6, 2003, and in a new telework guide for managers,
supervisors, and telework coordinators that was released 2 days later. 27
Both the frequently asked questions and the guide indicate that agencies

should offer eligible employees the opportunity to telework by having
supervisors extend the option of teleworking to all employees they
determine are eligible, using established criteria. To ensure that the

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

information contained in the guide reaches all federal telework
coordinators, an OPM official said that a hard copy of this guide would be
mailed to each coordinator. In addition, the guide has been posted at www.
telework. gov.

OPM also further clarified the statement about allowing eligible employees
an opportunity to telework by including a definition in the draft survey
it plans to send to agencies in the fall to obtain data for its January
2004 status report to Congress. Immediately following our meeting with OPM

officials, this draft survey was distributed at OPM*s May 2003 quarterly
telework coordinators meeting. As in last year*s survey, respondents would
be asked for the number of eligible employees given the opportunity to
telework. However, the following additional wording has been proposed

for that question: *How many eligible employees are given the opportunity
to telework, i. e. are actively asked if they wish to telework or are able
to telework because their supervisor informed them they could telework on
some basis?* If this new definition is properly applied by all agencies in
reporting data to OPM, this should address the issue we found. Also
included in the draft survey are two new proposed questions related to
allowing employees the opportunity to telework. These questions ask how
employees were presented with the option to telework and how many turned
it down.

The steps taken by OPM in response to our findings show a ready
willingness to address issues that are hindering telework implementation.
Continued efforts by OPM to publicize these new telework guidelines will

help to ensure that telework coordinators in federal agencies have a clear
understanding of the information they need to fully implement their own
telework programs.

GSA and OPM Provide As discussed earlier, the legislative framework for
telework has provided Services and

both GSA and OPM with lead roles in the implementation of telework in the
federal government, providing each agency with responsibilities for the
Resources to Support

telework initiative. Given these responsibilities, GSA and OPM provide
Governmentwide

federal agencies with a range of services and resources related to this
Tel ework initiative. Table 1 summarizes their efforts in this regard.
Implementation, but Their Efforts Have Not Been Well Coordinated

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

Run a Web site (www. telework. gov), which was designed to provide X
information and guidance Established and led the Interagency Telework
Issues Working Group, X

which canvassed agencies to examine existing policies and produced a
report with a series of recommendations in August 2002

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

Provides guidelines for agencies implementing telework programs X X
Conducts telework- related research and produces reports on telework X X
issues Conducts and participates in seminars X X

Develops telework training materials X X Provides customer support and
consulting X X Provides general promotion, advocacy, and outreach
(promotion of

X X telework policy through publications, speaking engagements, brochures,
conferences, etc.)

Is responsible for federal telework centers, including managing and X
encouraging other agencies to use the centers Offered agencies a free 60-
day trial period of the telework centers from X

March through June 2002 Established and maintains a mailing list server
for telework X coordinators Developed a list of agencies* telework
coordinators X Has an agency outreach initiative to assess program
barriers and

X successes at federal agencies Hosts quarterly telework coordinators*
meetings X

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

As shown in table 1, some of the services and resources are offered
jointly by both agencies, while others are offered individually by both
agencies or uniquely by either GSA or OPM. For example, each of these
agencies independently provides consulting, marketing, and training
services, but only OPM has undertaken an outreach effort to meet face to
face with agencies* telework coordinators and GSA has sole responsibility
for federal

telework centers.

In addition, although a GSA official told us that GSA has been promoting
its E- Connected Intelligent Remote Operations (EIRO) feature as a mobile
solution for government agencies, we found that this feature was not
functioning for a period of at least 5 months in 2003. According to its
Web site, 28 EIRO was supposed to have launched in March 2001 and was
intended to offer services and products from GSA Federal Supply Schedules
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.

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.

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 www. telework. gov.*

Furthermore, a GSA official told us that GSA had asked OPM to place a link
to the Interagency Telework Issues Working Group report on the
governmentwide telework Web site, but OPM had refused to do so, despite
the fact that the working group was jointly formed by both agencies. An
OPM official told us that OPM has been hesitant to post this report
because many of its recommendations were directed at OPM and could not be
readily implemented. In their combined comments on a draft of this report,

however, GSA and OPM said that the two agencies had jointly determined it
would be inappropriate to post the *pre- decisional* Interagency Telework
Issues Working Group report on the federal telework information Web site
until they had had the opportunity to analyze its findings, address issues
contained therein, and fully consider all recommendations. GSA, though,
has already independently posted this report on its own Web site with a
disclaimer, stating: *This final report does not in any way, specific or
implied, represent the official views, positions, or policies of the U. S.
Government, OPM, GSA, nor any of the agencies participating on the

Working Group. This report is currently under review by both OPM and GSA.*
Given that GSA and OPM co- led this group with participation from 15
federal agencies to identify policy actions needed to facilitate agency

use and expansion of telework and then make recommendations, we believe
that the report should be posted on www. telework. gov, with the same or a
similar disclaimer, in the interests of transparency.

After we discussed the issues created by the lack of coordination between
GSA and OPM with both agencies, a GSA official indicated that GSA and OPM
expressed a new commitment to coordination, especially with regard to the
governmentwide telework Web site. Such a commitment reflects a promising
start for better assisting federal agencies in improved implementation of
their telework programs. However, the key to success will be sustained
efforts by both agencies to work together in assisting agencies and
providing consistent and straightforward guidance, services, and resources
on the governmentwide telework initiative. Conflicts that

have arisen from the lack of coordination in the past underscore the need
for GSA and OPM to work together to reach a formal agreement establishing
a delineation of their respective roles regarding the governmentwide
telework initiative in areas where their respective

responsibilities are not clear. In areas where the responsibility is
clearly aligned with the mission of a particular agency, that agency
should be responsible for providing official guidance related to telework.
However, the agencies should consult with each other and attempt to reach

consensus in providing that guidance. Care should be taken to avoid
situations in which agencies are either left without needed guidance or
provided with conflicting guidance because GSA and OPM cannot reach
agreement.

Selected Federal We identified 25 key practices in telework- related
literature and other sources as those that federal agencies should
implement in developing

Agencies Are Not Fully their individual telework programs. 30 For the
purposes of analysis, we

Implementing Key grouped the key practices into the following seven
categories: program Telework Practices

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 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).

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 Categories and practices GSA

OPM Education

VA Program planning

Designate a telework coordinator. Establish a cross- functional project
team, including, for example, IT, union representatives, and other
stakeholders. Establish measurable telework program goals. Develop an
implementation plan for the telework program. Develop a business case for
implementing a telework program. Provide funding to meet the needs of the
telework program. Establish a pilot program. Telework policy

Establish an agencywide telework policy. Establish eligibility criteria to
ensure that teleworkers are selected on an equitable basis using criteria
such as suitability of tasks and employee performance. Establish policies
or requirements to facilitate communication among teleworkers, managers,
and coworkers. Develop a telework agreement for use between teleworkers
and their managers. Develop guidelines on workplace health and safety
issues to ensure that teleworkers have safe and adequate places to work
off- site. Performance management

Ensure that the same performance standards, derived from a modern,
effective, credible, and validated performance system, are used to
evaluate both teleworkers and nonteleworkers. Establish guidelines to
minimize adverse impact on nonteleworkers before employees begin to work
at alternate worksites. Managerial support Obtain support from top
management for a telework program. Address managerial resistance to
telework. Training and publicizing

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

Conduct assessment of teleworker and organization technology needs.
Develop guidelines about whether organization or employee will provide
necessary technology, equipment, and supplies for telework. Provide
technical support for teleworkers. Address access and security issues
related to telework. Establish standards for equipment in the telework
environment. Program evaluation Establish processes, procedures, and/ or a
tracking system to collect data to evaluate the telework program. Identify
problems and/ or issues with the telework program and make appropriate
adjustments. Agency has fully implemented this practice Agency has taken
some steps to implement this practice Agency has not taken any steps to
implement this practice Could not assess Source: GAO analysis of
testimonial evidence and/ or information and documentation collected.

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. 31 Using standards derived from a modern,
effective, credible, and validated performance system, telework- related
literature suggests that agencies need to take

steps to ensure that the same performance standards are used to evaluate
both teleworkers and nonteleworkers. In addition, agencies need to
establish guidelines to minimize adverse impacts that telework can have on
nonteleworkers before employees begin to work at alternate worksites.
Figure 2 shows that two of the four agencies we reviewed have taken some
steps to implement the practice of setting the same performance standards

for teleworkers and nonteleworkers and three of the four agencies had
fully implemented the practice of establishing guidelines to minimize
adverse impacts of telework on nonteleworkers.

Managerial Support Telework- related literature has shown that it is
critical to obtain support from top management and to address managerial
resistance in establishing

an effective telework program. As our earlier work has shown, and others
recognize, changes in an organization*s culture, such as the acceptance of
flexibilities like telework by managers throughout the organization, are
highly dependent on top management*s support for and commitment to

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

those changes. 32 In addition, our 1997 report on agencies* policies and
views on telework in the federal government identified managerial
resistance as the largest barrier to implementing telework. 33 This
resistance can be attributed to several factors, including general
resistance to change, since telework requires managers to shift from
managing by observation to managing by results. However, as shown in
figure 2, both of these practices still need attention by most of the
agencies we reviewed.

Training and Publicizing Because telework involves new ways of working, as
well as supervising, telework- related literature suggests that both
employees and supervisors

should receive training to ensure a common understanding of the program.
The Interagency Telework Issues Working Group report highlighted the need
for telework training in its report. In addition, the report states that
telework training should consist of two key components. One of these
components should address policy issues and include general information,
such as policy updates and an orientation to telework, while the other
component should focus on telework program activities, including such
topics as information technology (IT) applications, performance
management, and time management. Telework- related literature also
suggests that it is important to inform the workforce about the telework

program. Despite their importance, figure 2 illustrates that both of these
practices still need attention by some or all of the agencies we reviewed.

Technology OPM*s January 2003 report to Congress on the status of telework
in the federal government identified data security and IT issues as the
two most

frequently cited barriers to telework, as reported by federal agencies. In
32 See, for example, the following GAO products: Human Capital: Effective
Use of Flexibilities Can Assist Agencies in Managing Their Workforces,
GAO- 03- 2 (Washington, D. C.: Dec. 6, 2002); A Model of Strategic Human
Capital Management* Exposure Draft,

GAO- 02- 373SP (Washington, D. C.: Mar. 15, 2002); Managing for Results:
Next Steps To Improve the Federal Government*s Management and Performance,
GAO- O2- 439T (Washington, D. C.: Feb. 15, 2002); and Human Capital:
Practices That Empowered and Involved Employees, GAO- 01- 1070
(Washington, D. C.: Sept. 14, 2001). Also see Booz Allen Hamilton,
Analysis of Home- Based Telework Technology Barriers: Final Report on
Technology Barriers to Home- Based Telework (Washington, D. C.: Apr. 5,
2002) and U. S. Environmental Protection Agency, Telecommuting/ Telework
Programs: Implementing Commuter Benefits under the Commuter Choice
Leadership Initiative (Washington, D. C.: Sept. 2001).

33 GAO/ GGD- 97- 116.

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 In addition to the key practices we identified as being
integral to Identified

developing successful federal telework programs, we asked agency program
officials and union representatives at GSA, Education, OPM, and
Governmentwide

VA for their views on what governmentwide actions could be taken to
Actions That Could Be

increase telework participation in federal agencies. We also spoke with
Taken to Encourage officials representing federal employees
governmentwide, such as the National Treasury Employees Union and the
National Federation of

Federal Agencies to Federal Employees, to obtain their views on potential
governmentwide

Increase Telework actions. In addition, OPM*s November 2002 telework
survey asked

agencies about what OPM*s governmentwide telework initiative could do to
Participation

assist agencies in fully implementing telework policies. Some agency and
union officials identified governmentwide actions that are closely related
to the key practices we identified, such as the need for funding of
telework programs, the need for training, and the importance of obtaining
top- level support for telework. In addition, several officials

identified the need for GSA and OPM to provide more guidance or
information about telework and the need for clarification regarding the
implementation of the telework provisions in Pub. L. No. 106- 346. In
particular, agency officials identified a need for additional guidance
related to their data reporting and collection methods for OPM. Two agency
officials stated that OPM has changed the data that it requests from
agencies from year to year, which has made it difficult for them to
establish systems to collect the necessary data.

Conclusions Telework has received significant attention in Congress and
the executive branch and is an increasingly popular flexibility among
federal employees.

Not only is telework an important flexibility from the perspective of
employees, but it has also become a critical management tool for coping
with potential disruptions to the workplace, including terrorism. However,
the federal government*s telework initiative needs further development to

become an effective human capital flexibility. Congress* most significant
demonstration of support for telework was the enactment of Section 359 of
Pub. L. No. 106- 346. In guidance related to that law, OPM told agencies
that eligible employees who wanted to telework must be allowed that
opportunity, but did not provide a definition for what constituted such an
opportunity. Although the lack of a definition for that statement resulted
in the reporting of incomparable telework data to Congress, OPM promptly
released publications defining the previously

ambiguous statement following a discussion in which we highlighted this
issue for OPM officials.

On the other hand, the relationship between two other provisions* one that
requires specified agencies to set aside $50,000 each year for the use of
GSA telework centers and one that prohibits some of the same agencies and
several others from spending funds on GSA telecommunication centers*
remains in need of clarification. Although GSA telework centers are not
known by the term *GSA telecommunication centers,* GSA officials believe
that this term does in fact refer to GSA telework centers. Despite this
belief, it has not been made clear to all applicable agencies that the
provision prohibiting certain agencies from spending appropriated funds on
GSA telecommunication centers applies to GSA telework centers. This was
supported by the fact that two of the relevant agencies used

appropriated funds for GSA telework centers in fiscal year 2002, even
though the provision prohibiting them from spending appropriated funds on
GSA telecommunication centers was in effect. Although GSA and OPM are lead
agencies for the governmentwide telework initiative, they have not fully
coordinated their efforts in leading the governmentwide telework
initiative and have had difficulty in resolving their conflicting views on
telework- related matters. This lack of coordination created confusion for
federal agencies in implementing their individual telework programs. Both
GSA and OPM officials recently indicated a willingness to work together to
resolve this issue, but sustained attention and actions that result in
actual solutions will still be needed.

In addition, the key telework practices we identified are integral to the
success of the telework initiative in the federal government and need to
be considered individually by each federal agency within the context of
its

own mission, programs, and telework programs. However, as our work at four
agencies has shown, agencies face numerous difficulties in implementing
their individual agency programs. Regular attention by agencies to the key
practices is important to foster program growth and remove barriers to
telework participation.

Recommendations for We recommend that the Administrator, GSA, work with
Congress to

Agency Action 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. 34 In implementing that recommendation, OPM should
include information about telework, because it is such a flexibility. To
provide agencies with the capabilities to effectively implement telework,

both GSA and OPM should continue to monitor agencies* telework programs
and align their efforts with areas that are still in need of attention.

Agency Comments We provided a draft of this report in June 2003 to the
Secretaries of Education and VA, the Administrator, GSA, and the Director,
OPM. The

Director of Human Resources Services from Education provided comments via
e- mail (see app. III for a summary of these comments). In

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

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 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

Appendi Appendi xes x 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. 35 GSA and OPM were selected because of
their lead roles in the governmentwide telework initiative. In addition,
OPM was reported to have the highest telework utilization rate among the
CFO Act agencies. Education was included because its reported utilization
rate was the second highest among the CFO Act agencies. VA was selected
based on its distinction as the second largest CFO Act agency combined
with its having the lowest reported telework utilization rate

among the CFO Act agencies. 36 This agency selection process was not
designed to produce findings that could be considered representative of
telework implementation in the federal government as a whole, but rather
to provide illustrative examples of the extent to which selected
individual agencies with varied sizes, reported utilization rates, and
missions had implemented the key practices identified in our literature
review.

We interviewed officials and union representatives from the four selected
agencies to obtain their views on additional governmentwide actions that
could be taken to encourage federal agencies to increase telecommuting
participation. In addition, we contacted other unions representing federal

employees, including the National Treasury Employees Union, the American
Federation of Government Employees, and the National Federation of Federal
Employees, to solicit their views on such additional actions. (Officials
for the American Federation of Government Employees did not respond to our
request.) Our work was conducted from May 2002 through May 2003 in
accordance with generally accepted government auditing standards.

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

36 In its comments, VA noted that a *significant number of VA employees
are engaged in direct patient care and benefit service delivery to
veterans, which precludes large- scale participation in telework,* which
it considers to be a significant factor accounting for its limited
telework participation rate.

Descriptions of Efforts by the Selected

Appendi x II

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

Telework resources provided by both GSA and OPM in their roles as lead
Coordinator

agencies for the federal telework initiative state that, in implementing
their telework programs, federal agencies need to designate agency
telework coordinators and contacts. 37 All four of the agencies in our
study have a designated telework coordinator. At Education, the
coordinator works on the agency*s telework program full time. At the other
three agencies, the telework coordinator has other responsibilities in
addition to telework.

Establishing a CrossOur 2002 report on the effective use of flexibilities
identified stakeholder

Functional Project Team, input as a key practice for effectively using
human capital flexibilities, such

as telework. 38 According to this report, agency leaders, managers,
Including, for Example, IT,

employees, and employee unions need to work together to develop policies
Union Representatives, and

and procedures, because such involvement helps in reaching agreement on
Other Stakeholders the need for change, the direction and scope that
change will take, and how progress will be assessed. Stakeholder input
should also be used to ensure that the policies surrounding the use of
flexibilities are clear and the

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

procedures to implement them are uncomplicated. Telework- related
literature suggests that stakeholder involvement should be obtained by
establishing a committee with members from human resources,

information management, risk management, facilities management, and senior
management, as well as employee and union representatives. All four of the
agencies we reviewed established cross- functional project teams in
implementing their telework programs.

Establishing Measurable According to the International Telework
Association and Council*s (ITAC)

Telework Program Goals

e- Work Guide, research conducted by the American Management Association
in 2000 indicated that *68 percent of *highly successful* telework
programs felt it was *critical* to develop clear and reasonable program
objectives for their program* and another 27 percent considered it to be
helpful. 39 None of the four agencies we examined have taken any steps to
implement this practice.

In comments on a draft of this report, both OPM and VA said they had
established measurable telework program goals. However, neither agency was
able to provide documentation of such goals. Therefore, our assessments of
these agencies on this practice remain unchanged.

Developing an Guidelines issued by OPM in its capacity as a leader of the
governmentwide Implementation Plan for the

telework initiative suggest that agencies should establish a strategic
plan Telework Program

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. 40 Two of the agencies reviewed, Education and OPM,
have fully implemented this practice in their internal telework programs,
while VA has not taken any steps to implement this practice. However, in
comments

on a draft of this report, VA said that it had developed an implementation
plan for the telework program. When we requested documentation of such a
plan, VA responded that, in fact, it did not establish an implementation
39 International Telework Association and Council, e- Work Guide: How to
Make Telework Work for Your Organization (Washington, D. C.: 2000), 3. 40
International Telework Association and Council, e- Work Guide, 22.

plan for its current telework policy. Therefore, our assessment of VA on
this practice remains unchanged. During our review, GSA*s telework
coordinator told us that there was not a written implementation plan for
the telework program when it was first started. However, in comments on a
draft of this report, GSA indicated that it had an implementation plan
that was utilized 10 years ago when the program was first developed, but
this plan was not kept in the files, because it was no longer in use.
Therefore, we were unable to assess GSA*s implementation of this practice,
and have modified the report accordingly.

Developing a Business Case ITAC*s e- Work Guide states that *successful
telework programs reside in

for Implementing a organizations that understand why they support
telework, address the

Telework Program relevant issues, minimize business risk and make the
investment when it

supports their objectives.* 41 To achieve such success, the guide
recommends that organizations develop business cases for implementing
telework programs. The April 2002 report issued by Booz Allen Hamilton on
home- based telework technology barriers also recommends that agencies
develop business cases for implementing telework in their organizations,
because such an approach has proven effective in engaging management on
the benefits of telework to an organization. 42 Through

business case analysis, organizations have been able to identify cost
reductions in the post- telework office environment that offset additional
costs incurred in implementing telework and the most attractive approach
to telework implementation. Of the four agencies we reviewed, Education
was the only agency to have taken some steps to implement this practice. A
program official at this agency said that she has developed a PowerPoint
presentation of a business case for implementing a telework program at
Education. However, she has never actually given this presentation to
anyone at Education.

Providing Funding to Meet Telework- related literature suggests that
agencies should incorporate

the Needs of the Telework requirements for home- based telework into their
IT capital planning and Program

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

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

providing funding to meet the needs of the telework program is a practice
that the four agencies have only partially implemented.

Under the provisions of 40 U. S. C. 587( d)( 2), the only legislated
funding for telework programs that applies to the executive agencies that
we reviewed, specified agencies are to make at least $50,000 of the funds
appropriated for salaries and expenses available each fiscal year for
their employees* use of GSA telework centers. 43 However, the agencies
covered under this legislation are not required to spend the money made
available. While this provision pertains to all four of the agencies in
our study, neither VA nor OPM actually spent at least $50, 000 for
telework center use in fiscal year 2002. In contrast, both Education and
GSA spent more than this minimum

set aside. 44 Although VA*s telework policy states that the agency*s
telework assignments may be established at community- based telework
centers when determined to be consistent with the agency*s mission, a
program official said that VA generally does not choose to support use of
the centers. In fiscal year 2002, VA spent only $6, 800 for two users at
one telework center. OPM*s expenditures for telework center use in that
year were about $36,400. At Education, the telework program requests at
least a 10 percent increase in funds to be made available each year over
those requested the preceding year. For example, for fiscal year 2002,
$82,000 was requested and approved, while for fiscal year 2003, $125,000
was

requested and approved. An Education program official said that the 2003
request was much greater than the 2002 request because, in 2002, the
agency actually spent over $87,000 for use of the centers and the demand

was far greater than she had anticipated or could fund. The expenditures
for telework center use at GSA in 2002 were about $97, 000.

In addition to the funds made available for employees to work at telework
centers, each of the four agencies pays the salaries of telework
coordinators. In its comments on our draft report, GSA said that it did
not have a central telework fund. Instead, it said that individual
organizations

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

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.
45 Of the four agencies we reviewed, only Education had a pilot related to
the implementation of its agencywide telework program. Although GSA and
OPM did not have individual pilot programs for their internal telework
programs, both agencies were involved in the year- long governmentwide
telework pilot program that was implemented in 1990.

In comments on a draft of this report, VA said that it had two pilot
programs. However, when we requested documentation of a pilot relating to
implementation of its current program, VA responded that, in fact, it did
not conduct a pilot program for its current telework policy. Therefore, we
did not change our assessment of VA on this practice.

Telework Policy Establishing an Agencywide

OPM*s January 2003 report to Congress stated that of the 77 reporting
Telework Policy

agencies, 63 reported having approved and implemented their telework
policies, 9 were in the process of policy development, 3 were in the
implementation stages, and 2 reported no policies or policy development
activity. All 4 of the agencies in our study have implemented telework
policies and, according to agency officials at all of these agencies, they
have given some consideration to updating their policies to reflect
changes within the agency and more recent trends in telework. At VA, a
program official provided us with a draft for an updated policy, which was
developed to modernize the agency*s policy and expand the eligible

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

population at VA. According to this official, the draft policy was going
through the approval process at that time. Program officials at all 4 of
the agencies told us that revisions to their policies would involve
obtaining union input on those revisions. Telework program officials at
GSA and OPM said that reaching such agreement with the unions can take a
year or more.

Establishing Eligibility Several telework- related sources have emphasized
the need for eligibility

Criteria to Ensure That criteria to ensure that teleworkers are selected
on an equitable basis. Most Teleworkers Are Selected

of these sources advise that these criteria should be based on the
suitability on an Equitable Basis Using

of both the tasks and the employee for telework. According to the
Interagency Telework Issues Working Group report, criteria for Criteria
Such as Suitability

determining the suitability of the employee should be based on objective
of Tasks and Employee

criteria that are equitable, reasonable, and clearly stated and not on
general Performance

personal characteristics that are assessed using subjective measures, such
as being organized, conscientious, highly disciplined, and a self-
starter. The report went on to say that using such criteria can lead to
subjective supervisory assessments, which can inaccurately or
inappropriately impede telework participation. To address this concern,
the report recommended that OPM establish a policy that all federal
employees are potentially eligible to participate in telework, unless
excluded by their agency based on objective criteria that are supportive
of the intent of the telework requirements in Public Law 106- 346. The
group also recommended that OPM require each individual agency to identify
and define, in its telework policy, positions excluded from telework
arrangements, based strictly on tasks performed in the excluded positions.

Education has included eligibility criteria in its policy that are similar
to those that the Interagency Telework Issues Working Group cautioned
against using. Education*s policy states that an employee who is suitable
to telework should exhibit self- starter characteristics, good
organizational skills, and the ability to function independently.
Education and OPM also require that teleworkers are performing at or above
a specified rating level such as *fully successful.* In addition, OPM*s
telework policy states that employees approved for telework should be able
to manage workloads with minimum supervision and that generally, telework
is not appropriate for new employees such as those who need to be in the
office to learn the organization and those who require on- the- job
training. GSA*s policy does not include eligibility criteria, but states
that criteria for selecting occupations and employees for telework are not
hard and fast rules. However, the policy also refers to a separate GSA
Office of Human

Resources document for selection factors particularly relevant to
telework. A GSA program official said that she had been trying to locate
that document for a while, but to date has not been able to do so. VA*s
current policy includes eligibility criteria based solely on position
classifications. However, a VA program official acknowledged that there is
variation in the application of eligibility requirements among parts of
that agency, given the subjective nature of the approval process. She
added that the proposed revisions to VA*s current policy would require
supervisors to give reasons for denial on the application form, which she
hoped would provide needed information to help assess equitable treatment.
Because none of the four agencies have yet taken steps to ascertain
whether teleworkers are being selected on an equitable basis, these
agencies cannot ensure that their eligibility criteria are being applied
equitably.

Establishing Policies or Although telework- related sources suggest that
establishing policies or

Requirements to Facilitate requirements to facilitate communication among
teleworkers, managers,

Communication Among and coworkers is helpful in addressing managerial
concerns about

Teleworkers, Managers, and telework, teleworker isolation, and morale
issues that may arise with Coworkers

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

Telework- related literature recommends that agencies develop a telework
Agreement for Use between

agreement to be signed by both teleworkers and their supervisors.
Teleworkers and Their

According to ITAC*s e- Work Guide, such an agreement should establish job
Managers

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

Telework- related literature describes several means for employers to
Workplace Health and

ensure that teleworkers have safe and adequate alternate workplaces.
Safety Issues to Ensure That

These include specifically addressing health and safety issues related to
Teleworkers Have Safe and

telework in policies, including health and safety issues in telework
training, having teleworkers fill out a safety checklist, and performing
on- site Adequate Places to Work

inspections with adequate notice to the teleworker. Three of the four Off-
Site

agencies we reviewed, Education, GSA, and OPM, have developed safety
checklists, which are to be completed along with the telework agreement,
to ensure that teleworkers have certified the safety of their alternate
workplaces. However, Education is the only agency that requires all

teleworkers to complete and sign such a checklist before they begin
teleworking. GSA includes a safety checklist with the telework agreement,
but episodic teleworkers are not required to complete an agreement or,
therefore, a checklist. OPM*s telework policy recommends that the telework
agreement include a safety checklist, but such a checklist is not
required. According to a program official from VA, the agency*s current
policy does not contain health and safety guidelines, but the revised
draft policy, which is currently going through the agency*s approval
process, includes a safety checklist.

Performance Management

Ensuring That the Same Although none of the agencies have fully
implemented the practice of Performance Standards,

ensuring that the same performance standards are used to evaluate both
Derived from a Modern,

teleworkers and nonteleworkers, Education and OPM have taken some
Effective, and Credible

steps to implement this practice. Education*s telework policy states that
employees participating in the telework program shall be treated equally
Performance System, Are

with other employees in decisions that affect conditions of employment for
Used to Evaluate Both

awards, promotions, and/ or any other condition of employment. A
Teleworkers and

program official at OPM said that work performed by teleworkers is
Nonteleworkers

supposed to be evaluated using the same performance standards used for
nonteleworkers and that managers are supposed to communicate this.
Although such a statement was not included in OPM*s telework policy, the

policy does state that the employees* current performance standards will
be used to govern all telecommuting assignments as well as those in the
telecommuters* current traditional federal offices. A GSA program official

told us that the agency incorporated this concept into its telework policy
and reiterated it in counseling sessions with managers and staff. We did
not find any support of this in GSA*s policy, although it did indicate
that

*[ t] ime spent and quality of products will be measured by correlation
with previous and similar efforts.* VA*s current telework policy does not
contain any statements related to using the same performance standards for
both teleworkers and nonteleworkers. In comments on a draft of this
report, VA stated that the department consistently advises supervisors and
managers

that performance standards for teleworkers and nonteleworkers should be
the same. However, VA could not provide us with any information to support
this comment. In fact, VA responded that it provides such advice *on an
as- requested basis,* which does not constitute *consistently advising.*
Therefore, our assessment of VA on this practice remains unchanged.

Establishing Guidelines to Telework- related literature suggests that
performance and morale issues Minimize Adverse Impact on

can arise if guidelines are not established to address and minimize
adverse Nonteleworkers Before

impacts of telework on nonteleworkers. The literature describes several
Employees Begin to Work at

issues that can contribute to such issues among nonteleworkers, including
eligibility criteria that are perceived as unfair and cause nonteleworkers
to Alternate Worksites

feel left out or discriminated against, teleworkers that allow their in-
office

responsibilities to fall on the shoulders of nonteleworkers, and reduced
communication between the teleworker and nonteleworker. To mitigate these
situations, care should be taken to establish fair and equitable
eligibility criteria and means of distributing work.

Three of the four agencies, Education, OPM, and VA, have fully implemented
this practice by including specific guidelines in their policies.
Education*s telework policy states that telework should not affect the
performance of other employees and that it shall not put a burden on staff
remaining in the office. It also says that an equitable distribution of
work must be maintained and methods should be instituted to ensure that

employees working in the office do not have to handle the teleworker*s
work. OPM*s policy says that supervisors should consider the effect of
telework on all employees in the work unit, especially if it means there
are fewer employees in the office to handle customer requests. At VA,
supervisors are charged with ensuring that participating and
nonparticipating employees are treated equitably. According to a program
official at GSA, the agency*s policy sets out guidelines for effective use
of telework, including that a unit should use whatever systems it deems
necessary to ensure that there is a balance of work between those
teleworking and those in the office. However, we did not see any support
of this in GSA*s policy.

Managerial Support Obtaining Support from Top

Although program officials from all four agencies recognized support from
Management for a Telework

top management as being critical to the success of a program such as
Program

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 Our 1997 report identified managerial resistance as
the largest barrier to

Resistance to Telework implementing telework, attributing it to several
factors, including general

resistance to change, since telework requires managers to shift from
managing by observation to managing by results. 46 Officials from three of
the four agencies that we spoke with* Education, GSA, and VA* also cited
this as a challenge that they face and identified it as a barrier to
telework in their responses to OPM*s November 2002 telework survey.
Current and

former program officials at OPM stated that managers at that agency do not
exhibit signs of managerial resistance to telework and thus this practice
has been fully implemented. A former program official directly linked the
presence of top management support for telework at OPM to the prevention
of managerial resistance, because managers were told that they have to
allow telework and that they must give a business case for rejecting

an employee*s request to telework. Program officials at two of the
agencies presented some ideas for addressing managerial resistance. A VA
program official would like to bring in outside consultants to hold an
information forum or educational

briefings for supervisors and managers, which would tie telework to the
shift from the industrial age to the information age and walk managers
through the process of approving a telework arrangement. VA*s draft
Telework Proposal form, included in its revised draft telework policy,
will help to address managerial resistance, if it is implemented in its
current form, by requiring that supervisors provide a written reason if a
telework application is not approved. In its response to OPM*s 2002
telework survey, VA also said that it is using initiatives to gain top
management support to overcome barriers that include managerial
resistance. According to a

program official, GSA has considered handling the approval process for
telework agreements by committee instead of by individual supervisors as

46 GAO/ GGD- 97- 116, 14.

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

Training and Publicizing

Training All Involved, Three of the four agencies that we reviewed provide
some telework

Including, at a Minimum, training. At Education, training for teleworkers
is mandatory before they

Managers and Teleworkers 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

www. golearn. gov* an OPM- provided on- line learning center. The
availability of such training may help to address any disparity in the
provision of telework training among agencies.

Informing the Workforce Telework- related literature suggests that it is
important to inform the

about the Telework workforce about opportunities to telework. Two of the
agencies, GSA and

Program 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

Since teleworkers often require the use of IT equipment to access files,
of Teleworker and

internal networks, and e- mail, the Environmental Protection Agency (EPA)
Organization Technology

suggests that agencies assess both their own and their employees*
technology needs for telework with a mind toward providing employees Needs

with access to equipment similar to what they have in the office. 47 In
addition, ITAC*s e- Work Guide reports that research conducted by the
American Management Association found that 73 percent of *highly

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

successful* telework programs regarded it as *critical* to do an analysis
and review of the organization*s technology base and its compatibility
with teleworker requirements. According to Booz Allen Hamilton*s report on
technology barriers to home- based telework, the technologies acquired in
response to such assessments, including document management systems,

collaboration tools, and performance measurement systems, can result in
benefits for both teleworkers and those in the office environment as well.
Two of the four agencies we reviewed, Education and OPM, have fully
implemented this practice and GSA has partially implemented the practice.
According to an IT official at Education, the department did an
engineering analysis to determine both current and future infrastructure
needs for telework. In addition, a program official from Education told us
that each applicant for telework must complete a technology assessment
worksheet. OPM conducted a technology assessment as part of its program
planning. As part of this effort, OPM*s IT staff chose the technologies to
be used for remote access and decided that government- issued equipment
was preferred to personal equipment for security purposes. OPM*s IT
department also distributes virus software to employees who use their
personal computers for telework. GSA has not conducted an agencywide
assessment of teleworker and organization technology needs. According to a
GSA program official, this is done on a case- by- case basis at the
organization level because each organization is responsible for its own
budget and for providing its workers with the appropriate tools for doing
the job. According to another GSA official, GSA*s Office of Governmentwide
Policy is conducting a pilot with laptops and docking

stations to minimize the agency*s costs of maintaining two workstations
for teleworkers. According to an IT official, VA has not conducted an
assessment of technology needs with respect to teleworkers. As it
currently stands, the process at VA is handled individually between the

supervisor and employees. Developing Guidelines

Guidelines issued by GSA for the governmentwide telework initiative about
Whether the

indicate that, while agencies are permitted, but not required, to provide
Organization or Employee

teleworkers with equipment for use at alternate worksites, each agency
Will Provide Necessary

must establish its own policies on the provision and installation of
Technology, Equipment, and

equipment for telework. All of the agencies we reviewed have established
policies in this regard, stating that the agency will make decisions about
Supplies for Telework

providing equipment for telework on a case- by- case basis in light of
funding and other considerations, such as the work to be performed at the
alternate site, the type of equipment and software that is needed, and the
availability

of equipment. For those agencies that allow employees to use personal
equipment for telework, one program official acknowledged that such a
policy can result in a *digital divide* between those employees who have
the option of using or acquiring personal equipment for telework when the
agency is not able to provide them with equipment and those who do not
have such equipment available to them.

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

for Teleworkers establishing technical support for both government- owned
and personal equipment used to perform official duties for remote users,
especially for

teleworkers, is a relatively new issue for agencies. Some concerns
associated with this issue focus on the availability and consistency of
such support for teleworkers. To address these concerns, the report
recommends that GSA establish a policy requiring that telework
arrangements are covered in each agency*s IT technical support policies
and that agencies refer to relevant sources of information on technical
support in their telework policies.

All four of the agencies reviewed have fully implemented this practice.
According to an IT official at Education, the same technical assistance is
available to all Education employees, whether they are in the office or
teleworking. There is no special technical support for teleworkers. A
program official from Education also said that customer service center
staff can provide technical support for nongovernment- owned equipment,
but this support is limited to whatever help can be provided over the
telephone. An IT official at GSA said that the agency has two levels of
technical support for users. The first level of technical support for all
users, regardless of where they are working, is from their own unit*s
support staff. The second level of support for remote access users,
including teleworkers, is the Remote Access Team in the Chief Information

Officer*s office. This level of support is called upon when the first
level cannot resolve the problem. According to an IT official at OPM, the
agency has a telework group that manages the servers, the virtual private
network,

and communication software. There is a separate phone number for people to
call with computer problems associated with personal or agencyprovided
computers encountered while teleworking. At VA, teleworkers have remote
access to the same technical support as office- based workers.

Addressing Access and The Interagency Telework Issues Working Group report
states that remote

Security Issues Related to access is a key component of telework programs,
because *low- tech*

Telework 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 Booz Allen Hamilton*s report on technology
barriers to home- based

Equipment in the Telework telework recommends that federal organizations
specifically define

Environment 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,

Even though the four agencies we studied have processes and procedures
Procedures, and/ or a

to collect data on their telework programs, none of them currently does a
Tracking System to Collect

survey specifically related to telework or has a tracking system that Data
to Evaluate the

provides accurate participation rates and other information about
teleworkers and the program. Such lack of information not only impedes
Telework Program

the agencies in identifying problems or issues related to their telework
programs, it also prevents these agencies from providing OPM, and
subsequently Congress, with complete and accurate data.

Education*s process to collect data provides some useful information, but
it is not complete. To compile information on telework at Education, a
database was developed, which uses information from telework agreements
and the department*s payroll system. Using this database, Education can
produce reports on a number of topics, including the number of
teleworkers, whether they telework on a regularly scheduled or ad hoc
basis, what regions or offices they work for, who their supervisors

are, and their grade levels. However, an Education program official
acknowledged that although this system is designed to track telework
agreements, some agreements are not accounted for, such as informal
agreements that are unbeknownst to her or agreements that have not gone

through the whole process. Furthermore, because it tracks agreements and
not actual usage, the system cannot measure telework utilization. VA
currently does not have a database for telework and uses decentralized

data collection methods, but a program official indicated that the agency
plans to implement telework tracking via the time and attendance system.
Although this official said that she hopes this new tracking system will
address data inconsistency issues within the agency, she could not provide
a time frame for its implementation.

OPM tracks its teleworkers by counting telework agreements and recently
developed a database to keep track of these agreements, although a program
official acknowledged that informal e- mailed telework agreements that are
sometimes used at OPM might not all be included in the database because
she did not receive them. As stated above, systems that rely on agreements
to track telework participation do not actually provide information about
utilization rates. At OPM this weakness is compounded by the fact that the
agency does not ensure that telework agreements are used in all cases. GSA
does not have an agencywide tracking system. Coordinators for individual
units at GSA calculate telework data from telework agreements once a year
in order to provide the information GSA submits for OPM*s annual
governmentwide telework survey. However, no documentation is required for
intermittent telework arrangements at GSA, and, as a result, a program
official acknowledged that the number of these types of arrangements
reported to OPM for its 2002 telework survey was a rough estimate. She
also said that the survey instruments and reporting mechanisms used by
OPM*s governmentwide telework initiative for its annual report on telework
in the federal

government were a challenge in this area because of changes in the data
requested from year to year, which made it difficult to determine the kind
of system an agency needed to develop to best track the requested data.

Identifying Problems and/ or ITAC*s e- Work Guide recommends that
organizations choose an evaluation

Issues with the Telework design that 1) allows the clearest judgment of
the program*s effectiveness

Program and Making and 2) uses the evaluation results to develop an action
plan to guide any

Appropriate Adjustments 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.

Appendi x 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.

Comments from the Department of Veterans

Appendi x IV

Affairs Note: GAO comments supplementing those in the report text appear
at the end of this appendix. See comment 1. See comment 2. See comment 1.

See comment 3a. See comment 3b. See comment 3c.

See comment 3d. See comment 3e. See comment 3f. See comment 3g.

GAO Responses to 1. VA agreed with our conclusion that there is a need for
further guidance Comments from VA

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: a. In its comments, VA noted that it had conducted two pilot
programs. When we requested additional information from VA to support its

comment, VA provided us with information about two pilot programs that did
not relate to their current telework program. VA also stated that it did
not conduct a pilot program for its current telework policy. Because VA
could not provide information about a pilot program for

its current telework policy, we did not change our assessment that VA has
not taken any steps to implement this practice.

b. VA said it had established measurable telework program goals and an the
course of our work that VA did not have any measurable telework goals or
an implementation plan. Therefore, we have not changed our assessment that
VA has not taken any steps to implement these practices.

c. VA commented, as our draft report had noted, that its revised telework
policy has a *Self- Certification Safety Checklist.* However, as we also
noted in our draft report, this policy is still in draft form

and was not in use during our review. Because VA*s current telework policy
does not contain a safety checklist and the draft checklist is not in use,
we have not changed our assessment that VA has not taken any steps to
ensure that teleworkers have safe and adequate places to work off- site.

d. VA indicated that it had developed a Telework Proposal form that was
designed to facilitate communication among supervisors, employees, and
managers. However, that form is part of VA*s revised telework policy,
which, as noted in our draft report, has not yet been approved for use at
VA and, therefore, was not considered in our

evaluation. Moreover, this form, once approved, will not serve to
establish policies or requirements to facilitate communication between
managers and teleworkers, such as detailing the methods of communication
that should be used or the frequency with which communication should occur
while teleworking. More importantly, VA*s existing telework policy does
not establish such policies or requirements to facilitate communication.
Given these

considerations, our assessment that VA has not taken any steps to
implement this practice remains unchanged.

e. VA stated that the Telework Proposal form, which, as we noted, is still
a draft, allows it to track and evaluate the effectiveness of its program
as well as VA*s success in achieving targeted participation goals. This
form simply allows VA to count how many employees have applied for
telework and how many have been approved for such an arrangement. Such
information will be important and valuable. However, the form would not
fully enable VA to evaluate the effectiveness of its program or its
success in achieving participation goals in terms of the number of
employees actually teleworking and, equally important, the extent to which
telework is

being used. As we had noted in our draft report, a VA program official had
indicated to us that the agency plans to implement telework tracking via
the time and attendance system, which she hopes will address data
inconsistency issues within the agency. Such a tracking mechanism, if
implemented, could be helpful in tracking telework participation. Based on
these considerations, our

assessment that VA has taken some steps to implement this practice remains
unchanged.

f. VA also stated that the department consistently advises supervisors and
managers that performance standards for teleworkers and nonteleworkers
should be the same and said that this was consistent with the criteria
under our category of *Performance Management.* However, VA could not
provide us with any information to support

this comment. In fact, VA responded that it provides such advice *on an
as- requested basis,* which does not constitute *consistently advising.*
Furthermore, VA*s current telework policy does not contain any statements
related to using the same performance standards for both teleworkers and
nonteleworkers. Given these considerations, we have not changed our
assessment that VA has not taken any steps to ensure that the same
performance standards are used to evaluate both teleworkers and
nonteleworkers.

g. In addition, VA noted that its ability to conduct a technology
assessment for telework is compromised by the lack of clear guidance
regarding which positions are suitable to telework. This further
illustrates our finding, as stated in our draft report, that agencies may
need additional guidance, guidelines, and/ or individualized technical
support to fully implement the practices we have identified. However, VA*s
comment does not affect our assessment that VA has not taken any steps to
implement this practice.

Comments from the General Services Administration and the Office of
Personnel

Appendi x V

Management Note: GAO comments supplementing those in the report text
appear at the end of this appendix. See comment 3a. See comment 3a.

See comment 3b. See comment 3c. See comment 3b. See comment 3d. See
comment 3e.

See comment 4k.

See comment 1. See comment 2. See comment 1.

See comment 4. See comment 4a. See comment 4b. See comment 4c.

See comment 4d. See comment 4e.

See comment 4f. See comment 4g. See comment 4h.

See comment 4i. See comment 4j.

See comment 4k. See comment 4l.

See comment 5. See comment 5a. See comment 5b. See comment 5c. See comment
5d.

GAO Responses to 1. In their combined comments, GSA and OPM agreed that
telework is an

Comments from GSA important tool for federal agencies and stated that they
would

encourage and champion telework as a key human capital flexibility and OPM
and do everything possible to facilitate its acceptance and use. The
agencies also agreed to implement our recommendation that they use their
lead roles in the federal telework initiative to assist agencies in
implementing the key telework practices we identified. In this regard,

GSA and OPM stated that they will provide agencies with a checklist of the
practices we identified and recommend that agencies do a selfassessment 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 Webbased training site during
fiscal year 2003.

2. In addition, GSA agreed with our recommendation that it work with
Congress to determine what was meant by the phrase *GSA telecommunication
center* in Section 314, Division F, title III of Pub. L. No. 108- 7 and
whether this provision is in conflict with the provision contained in 40
U. S. C. 587( d)( 2). GSA stated that it will coordinate internally and
with the appropriate congressional committees to resolve the conflicting
language in the statutes and then provide clarification to its customer
agencies.

3. GSA and OPM disagreed with several of our findings relating to their
lead roles in the governmentwide telework initiative. Below are summaries
of GSA*s and OPM*s comments and our responses:

a. These agencies stated that, given the efforts they have made in
promoting telework, they were *taken aback* by language in the draft that
noted confusion at the *implementation level* throughout the federal
government regarding the policy guidance that they had put forth to date.
However, as detailed in our draft report, our finding was actually that
conflicting messages from GSA and OPM on certain telework- related matters
had created confusion. Apart from this finding, we recognize GSA*s and
OPM*s efforts to promote telework and had included in our draft report
many of the examples of those efforts that GSA and OPM cited in their
response, such as jointly running the telework Web site to provide
information and guidance, OPM*s rapid issuance of guidance in response to
our finding related

to the lack of a definition for providing employees with the opportunity
to telework, and GSA*s management and promotion of the telework centers.
Also, our draft report discussed OPM*s outreach effort to meet face to
face with agencies* telework coordinators and, as GSA*s and OPM*s comments
noted, this effort was also described in our May 2003 report entitled
Human Capital: OPM Can Better Assist Agencies in Using Personnel
Flexibilities. 48 However, while such promotional efforts can be
constructive, they

do not address the confusion we identified as a result of GSA*s and OPM*s
conflicting messages.

b. GSA and OPM strongly disagreed with our finding that they have not
fully coordinated their governmentwide telework efforts in the past. In
one instance, they said that the draft report stated there were unresolved
disagreements between GSA and OPM on telework policy

issues concerning dependent care and emergency closing of government
offices, and that they believed there were no such disagreements. However,
GSA and OPM also stated that, while they believed that their responses to
the dependent care and emergency closing issues were not in conflict, they
clarified them to avoid any confusion. We believe this is a noteworthy
development because, as stated in our draft report, agencies had expressed
concern about conflicting messages they had received from GSA and OPM on
several topics, including dependent care and emergency closings. More
generally, we also indicated in our draft report that, because

GSA and OPM have not developed a Memorandum of Understanding or other
formal agreement regarding their responsibilities for the governmentwide
telework initiative, they should work together to reach a formal agreement
establishing a delineation of these responsibilities. In their comments,
the agencies said that they have recognized the need to better outline
separate and shared responsibilities and that a Memorandum of
Understanding was among the options they were considering to clearly
designate each agency*s responsibilities. We have added language to
reflect GSA*s

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

c. In addition, GSA*s and OPM*s comments said that it was unnecessary for
OPM to re- coordinate with GSA on the final version of the telework guide
for managers, supervisors, and telework coordinators because GSA*s
comments had already been incorporated into the guide. Although we found
that OPM had made substantive changes

to the guide subsequent to GSA*s review, we now believe that, given the
concerns expressed by agencies, and underscored by Education*s and VA*s
comments on our draft report, it was sufficiently important to issue the
guide in a timely fashion, without a final review by GSA. Relevant changes
have been made to our report.

d. According to GSA*s and OPM*s comments, GSA*s senior program executive
for telework disputed our finding that GSA had expressed concerns about
OPM*s changes to the joint OPM/ GSA telework Web site (www. telework.
gov). However, this statement varies from information provided to us both
by GSA and OPM officials during the

course of our review and by the senior OPM official for the governmentwide
telework initiative at our exit conference with OPM. For example, during
our exit conference, the senior OPM official for the governmentwide
telework initiative acknowledged changing the telework Web site without
GSA being informed or OPM getting input from GSA. She said that GSA was
not very happy with the new look, adding that GSA felt the changes were
imposed on it by OPM without any consultation. Nonetheless, we have
adjusted the report to reflect the view of the GSA senior program
executive.

e. In their comments, GSA and OPM also said that the two agencies had
jointly determined it would be inappropriate to post the *predecisional*
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 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 25 th practice should not apply to it. As we clarified in this
report, some of the practices, such as developing an implementation plan
and establishing a pilot program, are historical

in nature and cannot be implemented at this time by agencies with existing
telework programs. However, as we also clarified in the report, agencies
with existing programs that did not initially implement some of the more
developmental practices can still be successful with sustained attention
to the other practices we identified.

In its comments, OPM stated that *[ E] ach comment listed was conveyed to
GAO during the interview process.* On the contrary, OPM*s comments, for
the most part, contain new information and/ or information that does not
correspond with what was conveyed to us during our meetings with OPM
officials. Summaries of OPM*s

comments, and our responses, are discussed below: a. OPM disputed our
finding that the agency had not established

measurable telework program goals, saying that it had done so by meeting,
even exceeding, the requirements of Section 359 of Pub. L. No. 106- 346.
OPM said that, *[ i] n effect, the legislation has provided the program
goals for Federal agencies through 2004.* However, in its May 2003
telework guide for managers, supervisors, and telework

coordinators, 49 OPM discusses the importance of establishing program
goals and objectives for telework because they will be

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

helpful in conducting program evaluations of a telework program. OPM*s
guide notes that *[ k] ey issues for evaluation for most agencies include
the effect of telework on productivity, operating costs, employee morale,
recruitment, and retention* and that the evaluation plan *should be based
on quantifiable program goals and objectives to allow for ease of
measurement.* Section 359 of Pub. L. No. 106- 346 refers broadly to the
federal workforce and OPM has not provided any documentation illustrating
how it has converted the law*s requirements into program goals to measure
the effect of telework on productivity, operating costs, employee morale,
recruitment, retention, or any other such desirable outcome. Moreover,
OPM*s telework coordinator told us during the course of our review that
goals have not been set for OPM*s internal program. Given these
considerations, our assessment of OPM for this practice

remains unchanged. b. OPM disagreed with our finding that it had not
established a business

case for implementing a telework program, stating that the business case
for telework has been developed through various means, including
statements made in its governmentwide guidance, information provided in
training sessions for its managers, and by referring its managers to the
OPM/ GSA telework Web site. As described in a source from which we drew
our key practices, a

comprehensive business case for a telework program entails identifying
full costs and benefits to the extent practicable, prior to implementation
of the program, that are specific to the organization, including IT
components, facilities, recruiting, retention, contingency support, and
security and risk assessments. 50 The business case that OPM refers to in
its comments does not fully meet these criteria. Furthermore, this comment
does not correspond with what was

conveyed to us during our meetings with OPM officials. Instead, OPM*s
telework coordinator at the time its current program was developed in 2001
told us that a business case for telework had not been developed prior to
implementing the telework program. Given these considerations, our
assessment of OPM for this practice remains unchanged.

c. OPM disputed our finding that it has only taken some steps to provide
funding to meet the needs of the telework program. The 50 Booz Allen
Hamilton, V- 2.

agency said that it has provided *full funding* for its telework program
and that it has identified resources that have allowed it to accommodate
*every employee (who is otherwise eligible and wants

to telecommute) with appropriate computer equipment, technology support,
and remote connections.* OPM did not provide documentation of this
funding. As our draft report indicated, OPM has taken important steps to
implement this practice, by paying the salary for a telework coordinator
and setting aside $50,000 in fiscal year 2002 for telework center use, as
required by law. However, an IT official at OPM said that there were times
that the agency has experienced shortages of the older computers it loans
to teleworkers. He said that the people who absolutely need to

telework get computers immediately, if they require one, but that people
who would like to telework, but do not have a *need* to do so, have had to
wait to begin teleworking until computers become available. According to
this IT official, managers usually make the decision about whether
telework is a *need,* although employees will sometimes decide for
themselves that it is not necessary for them to telework. Given these
considerations, we did not change our assessment that OPM had taken some
steps to implement this

practice. d. OPM questioned the validity of our having assessed its
telework

program against the practice of establishing a pilot program because *the
founding legislation* did not include a requirement for establishing pilot
programs and because OPM is confident that a pilot would not have added
significant value to its program. As noted in our draft, we used a variety
of sources, including GSA*s and OPM*s telework guidance, to identify key
practices. Successful telework experiences and related telework literature
suggest that pilot programs can be valuable at the outset of telework
initiatives by providing a means to test the concept and its integration
within a particular organization*s environment. However, as we recognize
in

this report, agencies with existing telework programs that did not
implement this practice when the program was initially developed can still
have successful telework programs with sustained attention to the other
practices. Because OPM did not establish a pilot program at the outset of
its telework program, our assessment of OPM for this practice remains
unchanged.

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

an equitable basis using criteria such as suitability of tasks and
employee performance, stating that it had fully implemented this practice
by providing objective eligibility criteria in its telework policy. Our
draft report noted the progress OPM had made in this area and that
guidance was in place on eligibility criteria. However, OPM*s telework
coordinator also told us that the eligibility criteria

varied by OPM unit and may not be consistently applied. Therefore, while
the OPM guidance is an important step, its consistent application is not
being ensured. Thus, we continue to believe that OPM has taken some steps
to implement this practice.

f. OPM disagreed with our finding that it had taken some steps to
establish policies or requirements to facilitate communication among
teleworkers, managers, and coworkers, stating that its policy and
associated forms serve to facilitate communication. Based on further
analysis of the policy and its associated forms, we have changed the
report to reflect that OPM has fully implemented this practice.

g. OPM disagreed with our finding that it has taken some steps to develop
guidelines on workplace health and safety issues to ensure that
teleworkers have safe and adequate places to work off- site, because one
of the appendixes included with OPM*s telework policy is a safety
checklist for the alternate worksite. As we noted in our draft report,
OPM*s telework policy states that the telework agreement should include a
safety checklist. Importantly, however, the suggested checklist, included
as an appendix to OPM*s policy, states that the employee *may use* it to
*assist them in a survey of

the overall safety and adequacy of their alternate worksite.* It goes on
to say *the following are only recommendations and do not encompass every
situation that may be encountered.* Moreover, the checklist does not have
a signature line or any way for it to be certified by the employee.
Because this checklist is only

recommended, not required, and does not need to be certified by the
employee, it is not sufficient to ensure that teleworkers have a safe and
adequate place to work off- site. Therefore, we continue to believe that
OPM has taken some steps to implement this practice.

h. OPM disagreed with our finding that it has not taken any steps to
ensure that the same performance standards, derived from a modern,
effective, credible, and validated performance system, are used to
evaluate both teleworkers and nonteleworkers, saying that the

performance standards that employees are evaluated against annually are
based on the duties and responsibilities of the employee*s position and
not on whether the employee is a teleworker or nonteleworker. OPM further
stated that the performance standards are the same, regardless of where
the work is performed. As we stated in the draft report, although OPM*s
policy does state that the employees* current performance standards will
be used to govern all telecommuting assignments, as well as those in the
telecommuters* current traditional federal offices. However, it does not
include a statement requiring that the same performance standards be used
for teleworkers and nonteleworkers. Without such a statement, at a
minimum, OPM cannot fully ensure that the same performance standards are
used to evaluate both teleworkers and nonteleworkers. Nonetheless, we have
revised the report to acknowledge that OPM has taken some steps to
implement this

practice. While these steps are important, there are steps that OPM can
take to more fully ensure that the criteria have been consistently
applied, such as periodically checking the performance appraisals for
consistency. i. OPM disagreed with our finding that it had not taken any
steps to train all involved in its telework program, including, at a
minimum, managers and teleworkers, saying that it has provided extensive

training to both managers and employees. However, this comment does not
correspond with what was conveyed to us during our meetings with OPM
officials. According to both the current and past OPM telework
coordinators, OPM had provided mandatory training to managers and optional
training to employees when the telework program began, more than 2 years
ago. In addition, they told us that OPM has not provided any training
since then. Even the initial training would not have been sufficient to
train *all involved* in the telework program, because employees were not
required to attend. In response to OPM*s comments, we have revised our
report to reflect OPM*s initial training efforts by indicating that OPM
has taken some steps to implement this practice. We are also pleased that
OPM indicated in its comments that, now that its agency restructuring has

been completed, it plans to provide continued outreach and training on
telework. However, OPM cannot be considered to have fully implemented the
practice of training all involved in its telework program until this
training is actively provided to and required of all relevant parties.

j. OPM disputed our finding that it had not taken any steps to establish
standards for equipment in the telework environment, saying that OPM has a
standard platform for connectivity and has established a protocol for
requesting necessary equipment and connectivity. During our review, an IT
official from OPM told us that the equipment

standards had not yet been fully applied to agency- owned equipment, but
he expected this to be done between July and October 2003. Based on OPM*s
more recent comments, we have revised our report to reflect that OPM has
taken some steps to implement this practice. However, the IT official also
told us that OPM does not have a

standard for employee- provided equipment. Until OPM establishes and
applies its standards to employee- provided equipment, it will not have
fully implemented this practice.

k. OPM disputed our finding that it had taken some steps to establish
processes, procedures, and/ or a tracking system to collect data to
evaluate the telework program, stating that it collects and tracks a
variety of data that is used to evaluate and report on its telework
program. According to OPM, because its policy states *[ c] ompleted

work agreements must be forwarded to the organizational telecommuting
contact for record keeping purposes,* the agency has fully implemented
this practice. In our draft report, we recognize OPM*s policy that
employees sign a work agreement with their supervisor. However, OPM*s
telework coordinator told us that work agreements, whether in hard copy or
e- mail form, are not always completed and forwarded to her. Additionally,
while OPM endeavors

to track participation rates through these work agreements, the agreements
only provide information on how many employees have been approved to
telework, not how many are actually participating.

Without a tracking and evaluation system that accurately measures program
participation, OPM cannot be considered to have taken more than some steps
to implement this practice. One such system was suggested by OPM itself in
the section of GSA*s and OPM*s comments on our draft report that is
related to those agencies* governmentwide leadership roles. These comments
said, *OPM has concluded from research that the best telework data is
collected through time and attendance tracking systems. OPM will be
issuing guidance to agencies later this year on the use of this data
source for its next survey.* Such guidance will be an important step
toward helping all agencies to more accurately track and report such data
and so that they can use the data for evaluation and program improvement
purposes.

l. OPM disputed our finding that it had not taken any steps to identify
problems and/ or issues with the telework program and make appropriate
adjustments, indicating that the various surveys and data it collects are
used, not only to report on the number of employees teleworking in the
agency, but also to help inform enhancements to its program. However,
OPM*s telework coordinator indicated that she does not actively seek to
identify issues using any evaluation tools. Instead, as OPM pointed out in
its comments, she relies on

employees to bring issues to her attention. While employees can be an
important source of information, such data sources are complements to, and
not substitutes for, formal feedback mechanisms and well- designed
evaluations, as described in OPM*s recently released telework guide to
managers, supervisors, and telework coordinators. 51 Nonetheless, given
these considerations,

we have revised our assessment of OPM for this practice to reflect that it
has taken some steps to implement this practice.

5. GSA did not disagree with our findings pertaining to its internal
telework program. However, the agency did note several areas where it
would like us to revise statements relative to its implementation of the
key practices we identified. Below is a summary of GSA*s comments and our
responses:

a. GSA said that, since its program has been in place for more than 10
years, it does not have or need a current implementation plan.
Furthermore, GSA indicated that it had an implementation plan that was
utilized 10 years ago, when the program was first developed. However, GSA
stated that this plan was not kept in the files, because it is no longer
in use. We agree that GSA should not develop an implementation plan for a
program that is already in place. Our analysis was focused on whether an
agency had developed an implementation plan to shape the design and
implementation of its program to ensure future success. In this regard,
GSA*s telework coordinator had told us that there was not a written
implementation plan for the telework program when it was first started.

Nevertheless, we have revised our report to indicate that we were unable
to assess GSA on this practice.

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

b. GSA indicated that it does not have a central telework fund and that
individual organizations within GSA provide their own funding. We had
considered this information in our analysis of the level of GSA*s

implementation of this practice. However, we have added GSA*s statement to
our report to provide additional context. Also, as already noted in our
draft report, GSA said that it had set aside the required central funding
for telecenter utilization.

c. GSA noted that it has an operational telework program and,
consequently, there is no further need for piloting. We agree with GSA
that there is no further need for piloting. Our analysis in this regard
assessed whether or not an agency had established a pilot at the beginning
of its individual telework program. GSA did not establish a pilot program
prior to implementation of its telework program. Therefore, our assessment
of GSA for this practice remains

unchanged. d. In addition, GSA provided comments related to several other
areas,

including: 1) its position on establishing telework eligibility criteria,
2) its emphasis on fairness toward teleworkers and others, and 3) its
existing lines of communication regarding telework, including its network
of telework coordinators in regions and organizations throughout the
agency, its provision of e- mail and on- line information on telework, and
its *strong emphasis on communication.* While these comments were helpful
in setting the context for GSA*s internal telework program, they were not
relevant to our analysis and, therefore, are not reflected in the body of
our report.

(450126)

a

GAO United States General Accounting Office

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
crossfunctional 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.
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.

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. HUMAN CAPITAL

Further Guidance, Assistance, and Coordination Can Improve Federal
Telework Efforts

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. Highlights of GAO- 03- 679, a report to the

Chairman, Committee on Government Reform, U. S. House of Representatives

July 2003

Page i GAO- 03- 679 Improving Federal Telework Efforts

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Appendix I

Appendix I Scope and Methodology

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Appendix II

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Appendix III

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Appendix IV

Appendix IV Comments from the Department of Veterans Affairs

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Appendix IV Comments from the Department of Veterans Affairs

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Appendix IV Comments from the Department of Veterans Affairs

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Appendix IV Comments from the Department of Veterans Affairs

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Appendix V

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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