Overview
The Massachusetts Environmental Police (MEP) did not always obtain required approval for the overtime reported on officers’ timesheets. Of the 74 overtime transactions selected, for 5 (7%), MEP could not provide adequate documentation to substantiate that the officers in question obtained approval to work the overtime reported on their timesheets. Not ensuring that officers adhere to all overtime approval requirements creates a higher-than-acceptable risk of incurring unnecessary overtime costs.
Authoritative Guidance
During calendar year 2017, MEP developed various forms for various types of overtime, which its officers use to substantiate that they have approval to work overtime.11 Examples of these types of overtime and their associated approvals (both before and after overtime is worked) include the following:
- Department of Conservation and Recreation (DCR) overtime has an approved DCR Directed Patrol Narrative sheet that is required to be signed by the working officer and submitted to his/her supervisors for signature approval. This form requires officers to explain the work they performed, the time and date of the patrol, and the number of hours worked.
- Divisional overtime requires a notation in the Information Management Corporation Computer-Aided Dispatch (IMC CAD) system that the shift extension has been approved by someone at or above the rank of captain.
- Off-highway vehicle and recreational boat safety overtime requires an operational plan that must be created by an MEP lieutenant and approved by an MEP employee at or above the rank of captain before being worked.
By developing these forms and procedures, MEP management demonstrated that it believes that documenting formal written approvals for overtime to support what officers claim on their timesheets is a best practice and an important internal control to ensure that all overtime worked is necessary and proper.
Reasons for Issue
MEP lacked effective monitoring controls to ensure that its officers properly documented that they obtained proper approval for the overtime hours they reported on their timesheets.
Recommendations
- MEP should develop policies and procedures to ensure that all overtime is approved and approvals are documented.
- MEP should establish monitoring controls to ensure that these procedures are followed.
Auditee’s Response
MEP has effective controls for ensuring that overtime is approved. In order for an Environmental Police Officer ("EPO") to receive payment for overtime, the EPO must enter overtime hours into the HR/CMS system. A supervisor must then approve those overtime hours, and that approval is recorded in HR/CMS. These HR/CMS entries serve as documentation from both the employee and the supervisor that the overtime was approved overtime. By requiring weekly review and approval by a supervisor who is responsible for reviewing and approving the time of a small number of EPOs (between 3 and 7), MEP ensures that approval of overtime is reviewed and documented at or near the time of the event.
The five instances identified in the audit team's finding are not instances for which EPOs failed to work claimed overtime or even instances for which EPOs failed to secure approval before working overtime. Rather, in these instances the MEP is unable to produce additional documents corroborating the HR/CMS entries years after the fact. In an effort to provide a belt and suspenders approach to documenting overtime approvals, MEP is strengthening its policies and procedures as follows:
- For overtime in connection with call-outs and shift extensions, a reminder has been sent to dispatchers to manually enter all approvals of such overtime into the IMC system. MEP officers will also be instructed to enter narrative notes into the HR/CMS payroll system describing the nature of work performed and correlating it with a specific IMC call # as a cross-reference;
- For overtime in connection with boating safety and off-highway vehicle missions, a reminder will be sent in April 2020 to lieutenants that operational plans for these missions must be approved by a manager of the rank of captain or higher, and MEP will designate central locations to save paper or electronic copies of operational plans and after-action plans;
- For overtime performed for the Department of Conservation and Recreation (DCR), a reminder will be sent in April 2020 to MEP officers that narratives must be signed by the officer's time approver and sent to DCR Fiscal, consistent with [MEP’s overtime policy] ADM-015.
Auditor’s Reply
The Office of the State Auditor (OSA) acknowledges that the process MEP uses to approve and record both the regular time and the overtime worked by its officers in the Human Resources Compensation Management System (HR/CMS) serves as a control to substantiate that officers have worked the overtime they report. However, as noted above, MEP management believed it was necessary to establish more effective controls over this process by developing forms for various types of overtime, which it requires its officers use to substantiate that they have approval to work overtime. These additional controls better ensure that all overtime worked by officers is necessary and proper. In our audit, we found that for 5 of the 74 overtime transactions tested, MEP could not provide adequate documentation (the required form, properly completed and authorized) to substantiate that the officers in question obtained approval to work the overtime reported on their timesheets. When management implements requirements for a process, it is also obligated to establish monitoring controls over the process to ensure that the requirements are consistently followed. However, MEP lacked effective monitoring controls to ensure that its officers properly documented that they obtained proper approval for the overtime hours they reported on their timesheets.
Based on its response, MEP is taking measures to improve the documentation of overtime approvals. We also urge MEP to implement our recommendation regarding establishing effective monitoring controls over this process.
| Date published: | April 21, 2020 |
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