Transportation Security Administration's Proposed Time and, B-291001, December 23, 2002

B-291001 Dec 23, 2002 Jump To VIEW DECISION RELATED PAGES GAO CONTACTS Highlights (1) approval is not occurring at the appropriate level. (2) data will not be checked against independent sources. (3) the proposed rounding of an employee's start/stop time minutes will not provide a complete and accurate agency record. First-line supervisors are approving T&A data. These supervisors have personal knowledge of the time worked of the employees involved. They are not required to check the data against independent sources. 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. 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). View Decision Transportation Security Administration's Proposed Time and, B-291001, December 23, 2002 DIGEST DECISION Pursuant to 31 U.S.C. Sec. 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. Sec. 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. Sec. 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. Sec. 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. Sec. 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. Sec. 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).