This is the accessible text file for GAO report number GAO-03-532R 
entitled 'Transmittal of Comptroller General Decision on the 
Transportation Security Administration's Time and Attendance Approval 
System' which was released on March 11, 2003.



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March 11, 2003:



Mr. Robert Gardner:



Assistant Administrator/CFO for Finance and Administration:



Transportation Security Administration:



701 South 12TH Street, Suite 518N:



Arlington, VA 22202:



Subject: Transmittal of Comptroller General Decision on the 

Transportation Security Administration’s Time and Attendance Approval 

System:



Dear Mr. Gardner:



This letter is to highlight for your attention and action internal 

control advice we offered in our December 2002 decision[Footnote 1] to 

four certifying officers of the Department of Transportation (DOT). 

Their July 24, 2002 letter had requested a Comptroller General decision 

related to certifying payroll payments.[Footnote 2] A copy of the 

decision is enclosed. Pursuant to 31 U.S.C. § 3529(a), the four 

certifying officers asked us whether the method of approving an 

employee’s time and attendance (T&A) information in the T&A system, to 

which the Transportation Security Administration (TSA) is 

transitioning, meets the requirements of Title 6 of GAO’s Policy and 

Procedures Manual for Guidance of Federal Agencies (Policy and 

Procedures Manual). To assist you in implementing our internal control 

advice, we are enclosing a copy of our recently issued guidance 

Maintaining Effective Control Over Employee Time and Attendance 

Reporting, GAO-03-352G (Washington, D.C.: January 2003).[Footnote 3]



The certifying officers expressed three concerns with the new T&A 

approval system. In their view, (1) approval is not occurring at the 

appropriate level, (2) data will not be checked against independent 

sources, and (3) the proposed rounding of an employee’s start/stop time 

minutes will not provide a complete and accurate agency record. The 

certifying officers also asked whether GAO would relieve a certifying 

officer pursuant to 31 U.S.C. § 3528(b)(1)(A) if a certifying officer 

certified an improper or illegal payment in reliance on the new T&A 

approval system.



To assist us in addressing the certifying officers’ three concerns, we 

discussed the new T&A system and related controls over T&A information 

with TSA officials. The enclosed Comptroller General decision addresses 

only the three specific concerns raised by the DOT certifying officers. 

We did not audit the system, otherwise, to determine whether the system 

contains flaws that might implicate the certifying officers’ liability 

in other ways.



Based on our discussions with TSA officials, we determined that, in 

accordance with Title 6, first-line supervisors are approving T&A data. 

Because these supervisors will have personal knowledge of the time 

worked by the employees involved, they are not required to check the 

data against independent sources. We also determined that TSA will 

maintain actual original entry records along with a trail of all 

changes to data to support what we consider to be the immaterial 

rounding of employee time in and time out data.



We have, however, identified additional control-related steps that TSA 

management should build into the T&A approval system as it further 

develops and implements it. To better support a future request for 

certifying officer relief should the T&A system, in fact, generate an 

improper payment, TSA officials should implement the T&A approval 

system as described to us and build the following control-related steps 

into it:



Conduct Federal Managers’ Financial Integrity Act reviews with a focus 

on ensuring that the new system is working as designed, the accuracy of 

the T&A data is maintained, and certifying officers are provided with 

assurances to this effect.



Specify in detail in TSA guidance the specific roles and 

responsibilities of first-line supervisors.



Communicate rounding rules for T&A time data to all affected staff.



Ensure the rounding rules for T&A time data are consistently applied.



Ensure that rounded and actual T&A data can be compared and tested once 

the T&A system is fully implemented.



We have discussed the contents of this letter with Jeffrey Bobich, of 

your staff, and he has informed us that TSA will build these steps into 

its T&A process. If you or your staff have any questions, please 

contact me at (202) 512-6906 or Mary Mohiyuddin, Assistant Director, at 

(202) 512-3087.



Sincerely yours,



McCoy Williams:



Director:



Financial Management and Assurance:



Decision:



Matter of: Transportation Security Administration’s Proposed Time and 

Attendance System:



File: B-291001:



Date: December 23, 2002:



DIGEST:



Transportation Security Administration (TSA) certifying officers 

expressed three concerns with TSA’s new Time and Attendance (T&A) 

approval system. In their view, (1) approval is not occurring at the 

appropriate level, (2) data will not be checked against independent 

sources, and (3) the proposed rounding of an employee’s start/stop time 

minutes will not provide a complete and accurate agency record. Based 

on our discussions with TSA officials, we determined that, in 

accordance with Title 6 of GAO’s Policy and Procedures Manual for 

Guidance of Federal Agencies, first-line supervisors are approving T&A 

data. These supervisors have personal knowledge of the time worked of 

the employees involved; therefore, they are not required to check the 

data against independent sources. In addition, TSA will maintain actual 

original entry records along with a trail of all changes to data to 

support what we consider to be the immaterial rounding of employee time 

in and time out data. TSA management, however, should build additional 

control-related steps into the T&A approval system as it further 

develops and implements the system.



DECISION:



Pursuant to 31 U.S.C. § 3529(a), four certifying officers at the 

Department of Transportation (DOT) asked us whether the method of 

approving an employee’s time and attendance (T&A) information in the 

T&A system to which the Transportation Security Administration (TSA) is 

transitioning meets the requirements of Title 6(1) of

GAO’s Policy and Procedures Manual for Guidance of Federal Agencies 

(Policy and Procedures Manual). The certifying officers also asked 

whether GAO would relieve a certifying officer pursuant to 31 U.S.C. § 

3528(b)(1)(A) if a certifying officer certified an improper or illegal 

payment in reliance on the new T&A approval system.



A certifying officer’s liability is strict; however, a certifying 

officer may request a decision from the Comptroller General in advance 

of payment when he or she is uncertain regarding his or her authority 

to make or authorize particular payments. 31 U.S.C. § 3529. In this 

regard, the certifying officers expressed three concerns with the new 

T&A approval system. In their view, (1) approval is not occurring at 

the appropriate level, (2) data will not be checked against independent 

sources, and

(3) the proposed rounding of an employee’s start/stop time minutes will 

not provide a complete and accurate agency record. Based on our 

discussions with TSA officials, we determined that, in accordance with 

Title 6, first-line supervisors are approving T&A data. Because these 

supervisors will have personal knowledge of the time worked of the 

employees involved, they are not required to check the data against 

independent sources. We also determined that TSA will maintain actual 

original entry records along with a trail of all changes to data to 

support what we consider to be the immaterial rounding of employee time 

in and time out data.



We have identified additional control-related steps that TSA management 

should build into the T&A approval system as it further develops and 

implements the system. To better support a future request for 

certifying officer relief should the system, in fact, generate an 

improper payment, TSA officials should implement the system as 

described to us, and build into the system the control-related steps 

that we discuss herein.



Background:



Standard for Relief:



Certifying officers are responsible for the legality of proposed 

payments and for repaying any payment that was “illegal, improper, or 

incorrect because of an inaccurate or misleading certification.” 31 

U.S.C. § 3528(a). A certifying officer’s legal liability is strict and 

arises automatically at the time of an illegal or improper payment. 54 

Comp. Gen. 112, 114 (1974). A certifying officer may request a decision 

from the Comptroller General in advance of payment when he or she is 

uncertain regarding his or her authority to make, or authorize the 

making of, particular payments. 31 U.S.C. § 3529. A certifying officer 

may rely on this advance decision when certifying future payments. This 

Office also has authority pursuant to

31 U.S.C. § 3528(b)(1) to relieve a certifying officer from liability 

when we find that the certification was based on official records and 

the official did not know, and by reasonable diligence and inquiry 

could not have discovered, the correct information. B-254385, March 22, 

1994.



The nature of the technology used in a payment processing system does 

not alter the basic concepts of accountability for certifying officers. 

69 Comp. Gen. 85 (1989). Where certifying officials rely on the 

integrity of an automated payment system, such as the TSA system at 

issue here, the reasonableness of a certifying officer’s reliance on an 

automated system to continually produce reliable and accurate 

information is a factor that we consider when addressing relief of the 

certifying officer from liability for illegal or improper payments. 69 

Comp. Gen. 85 (1989); B-247563, April 5, 1996. In this regard, we look 

to see if the system satisfies our Title 6 requirements, and whether 

the agency has provided its certifying officers with documentation 

establishing that the system is operating effectively and can be relied 

upon to provide accurate information. B-247563, April 5, 1996; GAO/

FGMSD-76-82, Nov. 7, 1977. Pursuant to section 3.3 of Title 6 of GAO’s 

Policy and Procedures Manual, agencies should provide their certifying 

officers with documentation establishing that management has in place 

internal controls that provide reasonable assurance that (1) T&A 

transactions are properly authorized and approved and (2) T&A data are 

completely and accurately recorded and retained.



Proposed Transportation Security Administration T&A Svstem:



The Aviation and Transportation Security Act, Pub. L. No. 107-71, 115 

Stat. 597 (2001), created the Transportation Security Administration 

under the Department of Transportation(2) A large part of the TSA 

workforce will be passenger and baggage screening personnel assigned to 

the nation’s airports. TSA has selected a private contractor to create 

and provide a new system for collecting T&A data.” The contractor is 

introducing the system at Baltimore-Washington International Airport 

and subsequently will implement it at all commercial service airports 

throughout the nation.



In their July 2002 request, the certifying officers provided us with 

the following information. DOT’s current system of record for time and 

attendance for DOT

personnel is called the Integrated Personnel and Payroll System (IPPS). 

DOT, through its Consolidated Uniform Payroll System (CUPS), calculates 

salary payments biweekly using T&A data from IPPS. CUPS will be used as 

well, drawing on IPPS data, to calculate biweekly salary payments for 

TSA screening personnel. It is the proposed T&A data approval system, 

and the reliability of the TSA T&A data that will be entered into IPPS 

from that system, that concerns the four certifying officers.



The TSA T&A collection system will use individual identification cards, 

issued to each screener, which he/she will swipe through a time 

recording device and record his/her start and stop times. The 

certifying officers explained that the collected data will be “rounded 

up or down based upon a 7-minute grace period from the scheduled start/

stop times, and provided to the supervisor to record any leave taken by 

the employee.” At the end of the pay period, “a supervisor will 

validate (sometimes referred to as a pre-approval) that the T&A data in 

this new system is ready to be interfaced into IPPS.” At this point, 

the supervisor is able to see a column summary of base hours worked and 

leave hours taken by the employee. The supervisor approves the data for 

transmission to the IPPS, where it passes through IPPS’ edits and is 

provided to the IPPS approving official. The certifying officials 

stated that “[i]t is anticipated that the approving official in IPPS 

will be a high level supervisor (not necessarily the supervisor who has 

knowledge of time worked and absences of the employees) at each airport 

or facility. This IPPS approver will then approve all T&As for a 

particular airport or facility, which could include several hundred or 

possibly 1,000 T&As.”:



The certifying officers expressed three concerns about this proposed 

T&A collection system:



(1) The IPPS approving official will approve a large number of T&As for 

employees he/she does not directly supervise.



(2) The data will not be checked against other independent sources. The 

supervisor who “pre-approves” the data will not be able to check the 

data against the records maintained in the IPPS, and it is not clear 

that the IPPS approving official will be able to reference the records 

maintained in IPPS back to the T&A data in the new system.



(3) The rounding of an employees start/stop time minutes will not 

provide a complete and accurate agency record.



Analysis:



This decision addresses only the three specific concerns raised by the 

TSA certifying officers. We did not audit the system, otherwise, to 

determine whether the system contains flaws that might implicate the 

certifying officers’ liability in other ways. To assist us in 

addressing the certifying officers’ three concerns, we discussed the 

new T&A system and related controls over T&A information with TSA 

officials. Our conclusions about the operation of the new T&A approval 

system are based on a conceptual understanding of the system design, 

and we did not assess whether the current or proposed T&A system meets 

all of the requirements of Title 6. Based on our understanding of the 

proposed system, our responses to the certifying officers’ specific 

concerns are as follows. Because both the first and second concerns 

relate to the approval of the data in the new system, we address these 

two concerns together.



The IPPS Official Does Not Approve TSA Employee T&As:



The TSA certifying officers expressed concern that the IPPS official 

will approve a large number of T&As for employees he or she does not 

directly supervise. It is not our understanding, however, that the IPPS 

official will be “approving” T&As for employees he or she does not 

supervise. We understand, instead, that it will be the employees’ 

first--line supervisors who will approve T&As for their employees and 

submit the data for input into IPPS.



The IPPS official will verify that the data in IPPS is the same as that 

entered by the first-line supervisors and that the data cleared the 

system’s internal controls, including automated data edit checks. This 

is an important distinction. The IPPS official is not an approving 

official; therefore, lie is not required to have first-band knowledge 

of the employees’ time worked. GAO Policy and Procedures Manual, Title 

6§ 3.6E. Instead, the IPPS official may rely upon the proper 

functioning of internal controls that provide reasonable assurance the 

T&A system, as well as other systems supporting payroll processing, are 

operating properly and payments are valid. 69 Comp. Gen. 85 (1989).



One of the key controls the IPPS approving official will rely upon is 

proper supervisory review. Section 3.6E of Title 6 of the GAO Policy 

and Procedures Manual, entitled “Approval of T&A Reports and Related 

Records,” states, “All T&A reports and related supporting documents 

...must be reviewed and approved by an authorized official. Review and 

approval should be made by the official, normally the immediate 

supervisor, most knowledgeable of the time worked and absence of the 

employees involved.”



According to TSA finance office staff, the new T&A approval system will 

require generally that checkpoint supervisors or screening managers 

approve a screener’s T&A information before it is recorded in IPPS’ TSA 

finance officers told us that these first-line supervisors (i.e., the 

supervisors, according to the TSA certifying

officers, who “pre-approve” the data) best meet the criterion in Title 

6 section 3.6, which requires that the official most knowledgeable 

about an employee’s time worked and absences be authorized to review 

and approve employee time and attendance information. These first-line 

approvers will be required to work in close proximity to the workforce 

so that they will be able to attest that the employee time records are 

complete and accurate. This will entail validating that the employee 

actually worked the hours recorded and had proper approval for any 

leave taken.



Much of the data in the new system will be available in near real time 

once the employee “swipes” his or her identification badge; therefore, 

the supervisor will have near real-time information about who is at 

work, arrival and departure times, and organizational or project codes 

being charged. By approving the T&A information, the official agrees, 

ratifies, or concurs that to the best of his or her knowledge the T&A 

information being approved is true, correct, and accurate and in 

accordance with laws, regulations and legal decisions. For that reason, 

unlike the certifying officers, we are not concerned that the first-

line supervisor will not be able to check the data against the records 

maintained in IPPS, and that the IPPS official will not be able 

reference the records maintained in IPPS back to the T&A data in the 

new system. Pursuant to Title 6, if the first-line supervisor’s 

approval is based on personal knowledge, additional independent checks 

are not required. GAO Policy and Procedures Manual, Title 6 § 3.6E.



Because the first-line supervisor is a critical control and must 

approve specific T&A infornation under Title 6, TSA should ensure that 

its guidance documents the specific roles and responsibilities of the 

first-line supervisor and the steps first-line supervisors should take 

to ensure T&A information is proper in as much detail as practical.



TSA officials should coordinate with DOT officials as necessary to 

ensure that any risks to the achievement of Title 6 objectives 

resulting from the integration of the new T&A system and supporting 

controls into the existing control environment are understood and 

addressed. If this occurs, and the current payroll processing controls 

are working properly, the IPPS official should have a reasonable basis 

on which to verify the T&A data.



Pounded Start and Stop Tunes Can Provide a Complete and Accurate 

Record:



With regard to the third concern, we have no objection to TSA’s use of 

immaterial rounding of employee actual time in and out data by TSA for 

purposes of recording T&A information. We consider the proposed 7-

minute grace period from the scheduled starting/stopping times to be 

immaterial, and TSA proposes to retain actual time in and out data:



The certifying officers’ concern stems from a Title 6 requirement that 

a complete and accurate record of the hours or fractions of an hour 

that an employee works be retained, which they fear would not be 

possible with the rounding of start and stop

times on an employee’s T&A. According to TSA finance office staff, 

however, TSA will maintain actual original entry records, along with a 

trail of all changes to data. We have no objection to the use of 

rounding if actual recorded time in and time out data are retained by 

TSA in a form that can be subjected to testing, and if TSA, indeed, 

tests the controls over this data. TSA also should take reasonable 

steps to ensure that its time rounding rules are consistently applied 

and communicated to affected staff.



Other Control-Related Steps:



As previously stated, the reasonableness of a certifying officer’s 

reliance on an automated system to produce reliable and accurate 

information is a factor that we consider when addressing relief of the 

certifying officer from liability. 69 Comp. Gen. 85 (1989); B-247563, 

April 5, 1996. In this regard, one of the things we look for is whether 

the agency has provided its certifying officers with documentation 

establishing that the system on which they rely is operating 

effectively and can be relied upon to provide accurate and reliable 

information. B-247563, April 5, 1996; GAO/FGMSD-76-82, Nov. 7, 1977. 

Therefore, it is important that implementation of the proposed system 

be monitored closely to ensure that it is operating effectively. Since 

the 1982 enactment of the Federal Managers’ Financial Integrity Act 

(FMFIA), all executive branch agencies have been required to annually 

review their systems of internal control and to report material 

weaknesses. Especially during the initial period and the first full 

year of the proposed system’ s implementation, TSA should include in 

this review testing of the new system to ensure it is working as 

designed and that the accuracy of the T&A data is maintained.



Conclusion:



In accordance with Title 6, first-line supervisors will approve TSA 

screeners’ T&A data. Because these supervisors will have personal 

knowledge of the time worked of the employees involved, they are not 

required to check the data against independent sources. In addition, we 

do not object to what we consider to be an immaterial rounding of 

employee time in and time out data that is supported by the original 

entry records and a trail of all changes to data. We have, however, 

identified additional control-related steps that TSA management should 

build into the T&A approval system as it further develops and 

implements the T&A system. To better support a future request for 

certifying officer relief should the T&A system, in fact, generate an 

improper payment, TSA officials should implement the T&A approval 

system as described to us and build the following control-related steps 

into the T&A approval system: (1) conduct Federal Managers’ Financial 

Integrity Act reviews with a focus on ensuring that the new system is 

working as designed, the accuracy of the T&A data is maintained, and 

certifying officers are provided with assurances to this effect, (2) 

specify in detail in TSA guidance the specific roles and 

responsibilities of first-line supervisors, (3) communicate rounding 

rules for T&A time data to all affected staff, (4) ensure the rounding 

rules for T&A time data are consistently

applied, and (5) ensure that rounded and actual T&A time data can be 

compared and tested once the T&A system is fully implemented.



If you have any questions, please contact Susan A. Poling, Managing 

Associate General Counsel, or Hannah P. Laufe, General Attorney, at 

202-512-5644.



Anthony H. Gamboa

General Counsel:



FOOTNOTES for DECISION:



[1] Title 6 of GAO’s Policy and Procedures Manual addresses Pay, Leave, 

and Allowances; chapter 3 specifically addresses Time and Attendance. 

Although plans to issue updated Time and Attendance guidance in early 
2003, GAO 

plans no revision of the requirements applied in this decision.



[2] Pursuant to the Homeland Security Act of 2002, Pub. L. No. 107-

296, 116 Stat. 2135, TSA will be transferred to the Department of 

Homeland Security and retained as a distinct entity. We do not address 

in this decision what effect this move may have, if any, on the new TSA 

T&A system.



[3] Staff in the office of the TSA Chief Financial Officer told us that 
the 

proposed T&A system initially will cover baggage and passenger 

screeners but will eventually cover other employees as well.



[4] TSA staff told us that each individual airport Federal Security 

Director (the senior TSA official at the airport) will have authority 

to designate an approval structure to fit the airport, and delegate 

approval responsibilities accordingly.



[End of section]



(195003):



FOOTNOTES



[1] See Comptroller General Decision B-291001 (Dec. 23, 2002).



[2] Pursuant to 31 U.S.C. § 3529, disbursing or certifying officers or 

the head of an agency may request a decision from the Comptroller 

General in advance of payment when uncertain regarding authority to 

make or authorize particular payments.



[3] This guidance replaces the 1996 revision to Title 6, “Pay, Leave, 

and Allowances” of GAO’s Policy and Procedures Manual. The requirements 

applied in the enclosed decision, which are from chapter 3, “Time and 

Attendance,” were not changed by this guidance.