ML23249A210

Tpiwg Final Report Oct 27 2022. - Redacted

ML23249A210
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Issue date:	10/31/2022
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U. S. N u c l e a r R e g u l a t o r y C o m m i s s i o n Telework Policy and Implementation Working Group FINAL REPORT

October 2022

1 l P age Table of Contents Executive Summary...................................................................................................................... 3 Introduction.................................................................................................................................... 5 Process and Methodology Used to Develop Recommendations................................................... 6 Information Gathering Activities................................................................................................. 6 Evaluation.................................................................................................................................. 7 Recommendations......................................................................................................................... 8 Phase 1: Telework Pilot - Recommendations and Actions........................................................ 8 Phase 1: Telework Pilot - Hybrid Work Model at a Glance........................................................ 9 Phase 1: Implementation Activities.......................................................................................... 14 Phase 2: Telework Pilot - Recommendations and Actions...................................................... 14 Phase 2: Telework Pilot - Hybrid Work Model at a Glance...................................................... 14 Phase 2: Recommendations................................................................................................... 15 Phase 2: Implementation Activities.......................................................................................... 17 Post-Pilot Assessment and Path Forward................................................................................... 17 Post-Pilot Assessment Activities.............................................................................................. 17 Enclosures................................................................................................................................... 18 Enclosure 1: Team Composition.............................................................................................. 19 Enclosure 2: Glossary of Key Terms....................................................................................... 20 Enclosure 3: Results of the Evaluation of the TPIWG Charter Obj ectives............................... 23 Enclosure 4: Be Risk SMART Remote Work Eligibility for Temporar y Assignments................ 38 Enclosure 5: Be Risk SMART Telework Pilot Analysis............................................................ 41 Enclosure 6: Telework Policy - Hybrid Work Model at a Glance an d Narrative....................... 54 Enclosure 7: Assessing the Effectiveness of the Telework Pilot.............................................. 60 Enclosure 8: Listening Session and Employee Feedback Summary....................................... 65 Enclosure 9: TPIWG Selected List of Key References............................................................ 83

2 l P age Executive Summary

The Telework Policy and Implementation Working Group (TPIWG or working group) was formed by the Executive Director for Operations (EDO) on July 14, 2022, (ML22194A933) to assess the Nuclear Regulatory Commissions (NRC) telework policy and its i mplementation. The working group (Enclosure 1) was specifically tasked to provide recommendations to ensure that the agencys telework policy would have sufficient flexibility to m eet our mission needs, and could be implemented fairly, equitably, consistently, and transparent ly. This report contains the results of our efforts and includes recommendations that were d eveloped to support an expanded and more flexible approach to managing telework. As in dividuals, we share common goals with all employeesto accomplish our safety and security mission and to build and sustain our organizational culture.

Our recommendations were informed by input from a wide variety of sources including:

discussions with the Hybrid Environment Assessment and Review T eam (HEART) members and a review of their report (ML22271A894); feedback from numerous employees who participated in one of four listening sessions and from many su pervisors and managers who participated in a focused listening session; discussions with a gency labor, financial, legal, and culture specialists; meetings with representatives from the Nat ional Treasury Employees Union (NTEU); informal comments and input from staff and supervisors provided directly to working group members; and our own literature reviews. As we began this effort, it became clear that many external organizations are engaged in similar efforts. The y face comparable levels of uncertainty and have diverse views on the optimal blend of remo te and in-person work. These uncertainties, coupled with the information we gathered, shaped our recommendation to conduct a two-phase pilot to assess the potential benefits and unintended consequences of a new approach, before finalizing any permanent changes to our te lework policy.

In making this recommendation, we recognize that the agency is currently operating in a hybrid work environmentan environment that includes a mix of remote a nd in-person work. While the agency expanded the amount of telework available to employe es during re-entry, we did not implement the necessary tools and guidance to ensure consistenc y in how we applied existing telework policy flexibilities and did not sufficiently focus on optimizing the benefits of our in-person work activities. As a result, many employees reported di ssatisfaction with the current work environment, expressing a view that activities performed i n-office often were no different than those routinely performed virtually. Employees also pointe d out that they had limited in-person interactions when they were in the office. To address th ese concerns, we recommend empowering supervisors to be flexible as they manage employee work schedules. We all should be more intentional about how we manage our in-person ti me to achieve the presence with purpose (PwP) goals discussed in the HEART report.

We recommend defining three categories of workers: hybrid worke rs, who are expected to work from an agency worksite a minimum of two days per pay period; hybrid remote workers, who are expected to work in an agency worksite on a regular and rec urring basis, but less than two days per pay period; and full remote workers who do not have a regular or recurring requirement to work from an agency worksite.

We recommend a two-phase pilot. Phase 1 includes activities tha t can be completed in the near-term, while Phase 2 includes activities that require more significant planning and preparation. During Phase 1, we recommend adjusting the number of required in-person days from the currently required fixed four days per pay period to a more flexible schedule with a

3 l P age minimum of two days of in-person work per pay period, combined with additional days, as needed, to support achieving PwP. During Phase 1, every employe e would either be a hybrid or full remote worker. Phase 2 further reduces the minimum numb er of regularly scheduled in-person days to two days per month, supplemented with additional in-person days as needed to support PwP goals, in effect creating the need for a hybrid rem ote worker category. Employees who currently reside more than 50 miles from an official NRC wo rksite would not be eligible for the hybrid remote option because of the cost and other impacts on the agencys operations. For eligible employees who opt to become hybrid remote workers duri ng Phase 2, their alternate work location would become their official duty station. This ch ange in duty station has the potential to affect an employees locality pay. Employees who o pt to work from an agency worksite two or more days per month, or who have duties that ar e not portable, would remain hybrid workers.

We make a number of recommendations related to full remote work, three of which are highlighted here. First, we recommend that employees with exist ing full remote agreements be permitted to continue with their current work arrangements. Sec ond, we recommend that the annual review of full remote arrangements be discontinued, and that feedback related to the employees performance and effectiveness as a full remote worke r be addressed during their annual performance discussion. Third, we recommendif warranted for recruitment or retention purposesthat future vacancy announcements include a statement that a position is eligible for full remote work. This will streamline and add tra nsparency to the current process.

Finally, the development of policy recommendations to establish the proper mix and approaches for managing telework versus in-person work is complicated by t he evolving nature of information and operational experience in this area, the multip le and diverse views that were shared, and the need to consider how other federal requirements might interact with some policy recommendations. As a group, despite our diverse views, we agreed on the primary goals of adding flexibility, empowering supervisors, and focusi ng on activities to achieve PwP, but differed on the details of some recommendations. In our rep ort, we highlight additional perspectives to better inform agency policymakers as they consi der our recommendations.

4 l P age Introduction

The NRCs return to the office strategy changed the workplace m odel from one where most employees work in the office for a majority of the work week to a model where most employees work remotely for a majority of the week. As described in the July 28, 2021 message from the EDO 0F1, the NRCs decision to implement a new hybrid work environment was based on staff input, an assessment of scholarly works, and the judgement of t he NRCs senior leaders.

Specifically, the NRCs leadership determined that the hybrid m odel best supported our ability to achieve our mission by balancing the need to build and sustain the long-term organizational health benefits associated with face-to-face interactions, whil e enhancing the work-life benefits that remote work offers employees and supporting a preference f or expanded remote work opportunities.

While NRC leadership saw the new hybrid work model as expanding remote work opportunities, many employees viewed the new model as a reduction in the flexi bilities afforded to them during the height of the COVID-19 public health emergency. Many of the staff pointed to the agencys success in meeting the mission while operating in a maximum tel ework posture for nearly 18 months as a basis for providing most staff with the option to c ontinue working remotely all or nearly all of the time. Additionally, many staff noted that the y were not having the face-to-face interactions with their colleagues that are desired to support organizational health. Most staff indicated that they see very few people on days they come into the office and do the same work they do remotely. This feedback prompted the EDO to charter the HEART to provide recommendations to agency senior leadership on how to optimize organizational health in a hybrid work environment, now and in the future. The EDO also ch artered our group to holistically assess NRCs telework policy and its implementation. He tasked the group to provide recommendations to ensure the agencys telework policy has sufficient flexibility to meet mission needs and ensure the program can be implemented fairly and equitably, consistently, and with transparency.

Like many organizations, the NRC is working to evaluate and opt imize its approach to the hybrid work model. Establishing the right balance between in-office an d virtual work time, and how to best use the in-person time is a challenge facing many organiza tions. Although many organizations are increasing workplace flexibilities, the long-term impacts on organizational health and mission accomplishment of this approach are unclear. Gartner1F2, an industry consultant group, indicated that the hybrid work model is an ex periment and could be the biggest change to the model of work since Peter Drucker coined the phrase knowledge worker in the late 1950s, which took 30 years to truly understand. Acc ording to Gartner, CEOs and human capital leaders are wrestling with the full implications of the hybrid work model on their organizations. Many leaders are optimistic that increasing flex ibility will help them meet their mission, but also indicate that unbounded flexibility (which oc curred during the pandemic) has had a negative impact on organizations. Over the last two years, leaders have indicated that they are seeing impacts including strained employee/supervisor relationships, staff burnout, and weaker connection of employees to the organization and its cult ure. The ability to sustain a

1 Message from the EDO: Important Updates on Agency Re-Entry Plan, Implementation, and Announcement of Full Re-Entry Date (July 28, 2021) https://intranet.nrc.gov/announcements/standard/covid-19/65458.

2 Kidson, A. (2022, September 20). The Changing Experience of Culture in a Hybrid Work World [Webinar]. Gartner Inc. https://webinar.gartner.com/420348/agenda/session/974761?login=ML.

5 l P age healthy organizational culture with a hybrid work model is a pr imary concern for many leaders and will require organizations to establish new approaches to m aintain their culture.

Although leaders expressed concern about impacts on culture, th ey also determined that a hybrid work model has the potential to increase productivity an d staff morale. In a 2021 Harvard Business Review article, How to do Hybrid Right,2F3 the author focused on how to boost productivity in a hybrid work model. This expert indicated that companies are focused on implementing flexible work desi gned to significantly boost prod uctivity and employee satisfaction. According to this expert, to boost productivity, managers will need to consider four primary factors when developing a hybrid work model: (1) jobs a nd tasks, (2) employee preferences, (3) projects and workflows, and (4) inclusion and fairness.

There appears to be much to be learned about the long-term effe cts of a hybrid work model on organizational health and effectiveness. Therefore, we sought t o offer recommendations that balanced the desire to provide enhanced employee workplace flex ibilities with sufficient and meaningful in-office interactions to achieve our goal of buildi ng and sustaining the agencys mission, organizational health, and values. The bases for the r ecommendations included are transparent and provide a framework for implementing a hybrid work environment that promotes work-life balance, supports a healthy culture, and provides fle xibility for staff and supervisors regarding where and how they work.

Process and Methodology Used to Develop Recommendations

Each of the working group members brought a unique perspective to the table. We had a broad range of views, shaped by our diverse life and work experiences, and we came prepared to openly share our opinions as we embarked on this important effo rt. This was evident from the start, as each member shared their personal vision for an idea l hybrid work model. To effectively leverage our differences, while continuing to work in an open and collaborative manner, we aligned on using the core NRC Organizational Values Integrity, Service, Openness, Commitment, Cooperation, Excellence, and Respectas o ur guiding principles to measure the efficacy of our recommendations. As a result, we en joyed an inclusive work experience that allowed us to fully explore and understand each other's views while efficiently aligning on recommendations.

Through our discussions and deliberations, we developed respons es to the five objectives outlined in the Charter3F4 which informed our recommendations ( Enclosure 3). In addition, we sought input and feedback from employees, agency subject matter experts, and other internal stakeholders.

Information Gathering Activities

To begin, we met with the EDO and the Deputies to gain alignmen t and understanding of their expectations on the goals and objectives of the tasking. In add ition, we leveraged outreach

3 Gratton, L. (May-June 2021). How to do Hybrid Right. Harvard Business Review https://hbr.org/2021/05/how-to-do-hybrid-right.

4 Charter for the working group on assessing the NRC telework policy and implementation, dated July 14, 2022.

6 l P age efforts from various groups fr om across the agency who have bee n closely involved with reviewing and assessing the hybrid work environment, specifical ly from the HEART and the Agency Culture Team. We frequently consulted with employee and labor relations and telework experts in the Office of the Chief Human Capital Officer and th e Office of the General Counsel.

In addition, we engaged with travel experts in the Office of th e Chief Financial Officer and facilities experts in the Office of Administration (ADM). Lastl y, we met with members from the NTEU to receive feedback and suggestions.

Additionally, as part of our data collection we reviewed the HE ART report and documents obtained throughout their assessment which included information from various agency working groups, external benchmarking entities, and literature reviews. We reviewed EDO Town Hall questions and answers from meetings that were held between Febr uary 2021 through July 2022, where there were approximately 110 comments related to te lework. We also reviewed telework and attrition/retention data, responses from exit surv ey interviews, feedback from summer employees, and data provided by the Office of the Chief Information Officer (OCIO) and ADM related to building occupancy and network access. Finally, we reviewed telework policies from other federal agencies including the Department of Energy.

To further support engagement and employee outreach, we conduct ed four agencywide listening sessions to provide employees the opportunity to shar e their insights and perspectives on the current telework policy, considerations for enhancements, and how/when to best leverage in-person and virtual interactions. A total of 1,057 e mployees attended the listening sessions and 63 employees provided comments orally. Equally imp ortant, we conducted an additional listening session dedicated to supervisors. While th is session was intended for first-line supervisors to provide their perspectives, senior managers also were invited to participate and share their feedback. A total of 312 participated in the su pervisor listening session and 22 supervisors provided comments orally. A summary of the listenin g session feedback is provided in Enclosure 8.

Furthermore, we obtained feedback from more than 26 employees v ia email or during open door sessions. We reviewed and considered this feedback to info rm our recommendations. A summary of the employee feedback is provided in Enclosure 8.

Finally, we issued a voluntary agencywide survey to capture add itional information on pay, job function, distance from assigned NRC offices, commute time, and locality pay. The survey was active from October 3 - 14, 2022, and received 1507 responses ( ~54% of the agency). This survey data further informed recommendations for the future hyb rid work model. A summary of the survey data analysis is provided in Enclosure 6.

Evaluation

We considered and analyzed the information provided from the ab ove sources to support the development and assessment of the recommendations contained in this report. Specifically, each recommendation was reviewed to ensure that it: 1) would su pport continued effective accomplishment of our safety and security mission and would bui ld and sustain our organizational health; 2) was consistent with NRC Organizationa l Values; 3) considered risk (i.e., benefits versus challenges as described in the BeRiskSMA RT evaluation in Enclosure 5);

4) was consistent with, or permitted by, current requirements ( e.g., the Collective Bargaining Agreement or applicable Federal requirements); 5) considered re source impacts; and 6) improved or responded to identified concerns that were associat ed with the current policy.

7 l P age Our recommendations are described below. For some, we provide a dditional information to highlight key challenges or benefits to better inform decisions related to acceptance or non-acceptance of any recommendation.

Recommendations

To optimize the agencys organizational health in a hybrid envi ronment and inform future hybrid work model changes, we recommend that immediate, near-term, and longer-term telework changes be piloted.

Figure 1: TPIWG Approach

The telework pilot we propose consists of two phases of recomme ndations and actions as outlined in Figure 1 with the overarching goal of successfully achieving agencywide implementation of the PwP telework philosophy. Each phase of th e telework pilot provides an opportunity for the agency to learn from a period of progressiv ely reduced fixed in-person requirements for the majority of employees. The proposed approa ch provides for near-term implementation of Phase 1 to enable the agency to make an initi al shift to a flexible, and more meaningful in-person presence and, if considered successful, to prepare for the transition to Phase 2. Phase 2 further reduces the amount of fixed in-person presence to twice per month and we recommend piloting this hybrid work model for a full yea r. At the completion of Phase 2, we recommend the NRC complete a post-pilot assessment to determ ine a path forward for the agencys telework policy, appropriately informed by the pilot r esults.

Phase 1: Telework Pilot - Recommendations and Actions

Over the course of our effort, we identified recommendations fo r immediate and near-term action that do not have or are not foreseen to have significant policy implications. Some of these recommendations were provided to the EDO or a specific of fice in advance of the final report because the working group determined that the recommenda tion was associated with ongoing efforts to address some specific telework issues. Recom mendations outlined in Phase 1 are those that have been accepted by the EDO; are in progress and led by an agency office

8 l P age for implementation; or are new near-term recommendations. Addit ionally, Phase 1 includes necessary actions that should be considered for implementation of Phase 2 of the telework pilot.

Phase 1: Telework Pilot - Hybrid Work Model at a Glance

Figure 2 illustrates the proposed agency hybrid work model for Phase 1 of the telework pilot.

Additional details are provided in the recommendations below.

Figure 2: Phase 1 - Telework Pilot

Recommendation 1: Adopt and implement PwP. This includes the need for all emplo yees to adjust work schedules as needed to support the PwP guiding prin ciples of in-person interactions to connect, collaborate, create, and celebrate.

• Offices should implement in-person core days once a month. The se core days should include some PwP activities. We provide a calendar example in Enclosure 3, page 36 to illustrate this concept. These core days also provide opportuni ties to bring in full remote workers and resident inspectors to participate in office-wide m eetings and team building activities on occasion.

A risk associated with the PwP monthly core day approach that w e considered is the impact on individual employee telework schedules. The benefit of a cor e day is that it provides an opportunity for PwP activities across the office. This was view ed as important enough to offset any potential impact on individual preferred telework sc hedules. In any case, supervisors would retain the ability to grant exceptions.

9 l P age Recommendation 2: Modify the current agency hybrid work model to reduce the numbe r of required fixed schedule in-person days from four to two days pe r pay period if the nature of the work supports it. The authority to approve telework schedules w ill reside with the Branch Chief.

Under this new hybrid work model, supervisors will have the dis cretion to exceed this two-day minimum, consistent with their responsibility to support necess ary in-person PwP activities.

• The authority to approve telework schedules will reside with t he Branch Chief. Under this new hybrid work model, supervisors will have the discretio n to exceed this two-day minimum, consistent with their responsibility to support necess ary in-person PwP activities.

• This telework schedule includes employees who will have a fixe d schedule of at least two days per pay period in-pers on. Employees under this plan wo uld retain their existing office worksite as their official duty station for purposes of locality pay.

A risk that we considered associated with further reducing the amount of in-person presence for the telework baseline was the impact on the agencys abilit y to recruit and retain staff for positions that are unable to support this amount for telework d ue to the nature of their work (e.g., Headquarters operations officers, resident inspectors, e tc.). To address this risk, we will continue to emphasize the importance of monitoring the imp act of our telework pilot to our ability recruit and retain these critical positions. These positions have sometimes been difficult to fill, and the agency has employed various incentiv e strategies to address this challenge. Continued monitoring will allow leaders to assess an y new or modified incentives that should be put into place.

Recommendation 3: Modify the processes related to full remote work by implementin g the following items.

• Approval should be based on the need to support recruitment an d retention to maintain critical skills, and should be the exception, not the norm.

• Where office directors/regional administrators determine it is necessary to address recruitment or retention challenges, provide an option to post vacancy announcements with location identified as To Be Determined (TBD)/Anywhere.

• Change approval authority for full remote work from the Chief Human Capital Officer (CHCO) to the office director or regional administrator.

• Emphasize that the approval guidance is forward looking and wi ll not affect existing full remote arrangements.

• Eliminate the annual renewal process and incorporate instead i nto annual performance conversations a discussion of what has worked during full remot e telework and may need to be addressed.

This recommendation addresses two concerns expressed by staff d uring the listening sessions related to the uncertainty and stress associated with the annual review of full remote telework arrangements and eliminates the multi-step proc ess that requires full remote employees to report to the agency worksite after selecti on for, and acceptance of, a new position before being eligible to apply to become a full re mote worker. By specifying up-front that a position may be eligible for full remote work, candidates can make an informed decision about whether to apply for the position.

10 l P age We acknowledge this recommendation does not directly address co ncerns expressed by current full remote workers about limited promotion opportuniti es, but it will increase fairness and transparency.

We recognize that some employees who feel no recurring minimum amount of in-person presence is necessary would prefer for the new hybrid work mode l to make full remote work available to any employee who requests it. The working group ho lds the view that such wide scale full remote work could over time negatively impact o ur organizational health and erode our ability to meet the agencys mission. Instead, we off er an approach that, increases employee flexibility, r educes the minimum in-person t ime and with proper implementation of PwP, makes in-person interactions more meanin gful.

This recommendation expands upon t he clarification provided by the EDO4F5 regarding annual full remote telework renewals. Specifically, the EDO cla rified the expectation that annual full-time telework agreements will continue to be renewe d unless there are significant changes to the work of the position or there is a significant c hange to the justification for the original agreement, as outlined in agency policy and the Collective Bargaining Agreement 5F6.

Detailed discussion of the working groups analysis of full rem ote work is included in Enclosure 3.

Recommendation 4: Delegate approval authority and streamline the full remote wo rk approval process for temporary assignments (i.e., rotations and details) to better enable the agency to fill emergent limited-duration agency needs, see Enclosure 4.

• Update guidance to reflect delegated approval of full remote w ork to Division Director level with office director/Regional Administrator included for awareness prior to posting the temporary assignment.

• Post all temporary assignments with preferred location (e.g., Headquarters, Region 3) with a clear statement that full remote work may be available, if the work is portable.

• Supervisor to design a plan that provides the appropriate mix of in-person and remote work to achieve organizational needs. This plan will be include d in the posting.

• Minimize or eliminate telework paperwork for selected employee s.

Some aspects of this recommendation were included in the EDO message to staff on organizational health, dated September 19, 2022.. Specifically, the EDO supports the posting of rotations/details/temporary assignments as eligible for remote work from a persons permanent duty station if the work is portable (for a duration up to 6 months)

5 EDO Message to Staff on Organizational Health September 19, 2022 https://intranet.nrc.gov/announcements/standard/general-interest/edo-message-to-staff-on-organizational-health.

6 Collective Bargaining Agreement.

https://adamsxt.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML21321A264.

11 l P age Recommendation 5: Streamline and automate agency telework process and associated forms.

Streamline the telework request process and automate the proces s in a way that allows the agency to capture, maintain, and analyze telework data to suppo rt future decision-making.

This recommendation builds on the winning staff submission from the 2021 agencywide IdeaScale challenge campaign to identify ways to Better Use of Technology, Data, Analytics, and Automation. The winning submission was to autom ate the telework request process. This recommendation is in process for implementation a nd is being led by the Office of the Chief Human Capital Officer (OCHCO) and OCIO]

Recommendation 6: Revise and clarify guidance on appropriate use of Project-Based Telework.

• Issue a reminder about the purpose of project-based telework: to provide a short-term (i.e., hours or days) telework arrangement, when an employees work assignments, or a portion of them, can be performed remotely for a short period o f time and where project-based telework is necessary to meet mission requirements.

• Emphasize that the use of project-based telework should be occ asional (e.g., special project, inclement weather, recovery from a medical procedure), and that we expect limited need for project-based telew ork for many employees beca use of the expansion of telework flexibilities.

• Revise guidance related to approval authority and consecutive workday thresholds to reflect the updated hybrid work model that will be available to many employees.

• Emphasize that project-based telework shall not be used to cir cumvent the agencys telework policy.

Recommendation 7: Replace the term full-time telework (FTTW) with the term ful l remote telework.

This modification aligns more closely with Office of Personnel Managements (OPM) usage.

OPM guidance uses the term remote to indicate an arrangement in which an employee, under a written remote work agreement, is scheduled to perform their work at an alternative worksite and is not expected to perform work at an agency works ite on a regular and recurring basis. 7 6F

Recommendation 8: Provide clarification of existing telework flexibilities.

Provide communication to NRC superv isors on existing telework f lexibilities to optimize the hybrid work environment. These flexibilities include supervisor s' ability to adjust an employees fixed telework day w ithout a formal change to suppor t purposeful engagement; crediting in-person activities as in-office days when they may take place at an alternate work location (ex. Licensee facility); clarifying that employees do not need to make up an in-office

7 Office of Personnel Management, 2021 Guide to Telework and Remote Work in the Federal Government (Nov.

2021) at 11, available at https://www.telework.gov/guidance-legislation/telework-guidance/telework-guide/guide-to-telework-in-the-federal-government.pdf (OPM 2021 Telework guide).

12 l P age day if the fixed day is on a holiday, employee is on leave or f or some other extenuating circumstance. [Lead: OCHCO]

Recommendation 9: Update and consolidate all telework guidance to enable successf ul implementation of the agencys telework program.

Recommendation 10: Establish the infrastructure to capture agency telework data to enhance transparency and support analysis and information needs to support the pilot and enable the agency to make ongoing decisions related to telework.

Recommendation 11: Update telework guidance to explicitly capture expectations a nd norms for optimizing hybrid and virtual meetings.

Specifically, include but not limited to:

• Cameras should generally be used when participating virtually (e.g., cameras should be on when speaking or when in small group meetings).

• Employees should physically attend and be present at meetings when they are in-office, and a designated space is reserved.

The above recommendation addresses a risk associated with expan ded use of remote work.

To make the most of the hybrid environment, we will need to con tinuously adapt our behaviors to leverage the capabilit ies of new and evolving tech nologies. This recommendation is intended to promote the use of tools consider ed necessary to enhance interpersonal communications and improve the quality of both in -person and virtual interactions.

Recommendation 12: Establish an agencywide position on the minimum number of hou rs in the office for the in-person day to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This recommendation provides clarit y by setting clear expectati ons. We recognize that it may increase the amount of time per day that some employees wou ld normally be expected to perform in-person work at an agency worksite. This change is necessary to support effective accomplishment of the PwP activities identified in th is report.

13 l P age Phase 1: Implementation Activities

• Establish a Telework Pilot Implementation Team with an SES cha mpion to implement the pilot recommendations.

• Develop an Implementation and Change Management Plan

• Establish metrics to evaluate the success and sustainability o f the hybrid work model and implantation and to assess the impact on organizational health (Enclosure 7).

• Establish a Human Capital Council Sub-Committee to monitor pil ot implementation and periodically review data throughout the pilot.

• Provide supervisors with hybrid management guidance and traini ng that focuses on effectively using in-office days in support of PwP.

• Stand up an agencywide Branch Chief community of practice to c ollaborate and share experiences, best practices, and examples of PwP to foste r success, and to share feedback with the HCC Sub-Committee.

• Provide additional guidance to supervisors and staff on the pr ocess for approving full remote work requests.

• Develop process changes and associated guidance for posting po sitions to ensure employees understand remote work eligibility for the position.

• Implement a streamlined and automated telework approval proces s, including all associated forms.

• Review elements and standards and performance plan verbiage fo r all employees to ensure expectations align with and support a hybrid work enviro nment.

Phase 2: Telework Pilot - Recommendations and Actions

Phase 2 recommendations include actions that require more signi ficant planning and preparation. Therefore, the working group recommends that this phase last for at least a year.

This will provide time to assess the potential benefits, impact s, and challenges associated with the pilot. We also include implementation activities for Phase 2.

The new approach emphasizes flexibility in the scheduling of in -office workdays, further expands the decision-making authorities of first-line superviso rs as described below and prioritizes PwP. This new approach reflects a significant adjus tment from our current agency hybrid work model and is designed to enhance connection, collab oration, creation, and celebration to help us better achieve our shared goal of buildi ng and sustaining strong organizational health and a more engaged workforce.

Phase 2: Telework Pilot - Hybrid Work Model at a Glance

Figure 3 illustrates the proposed agency hybrid work model for Phase 2 of the telework pilot.

Additional details are provided in the recommendations below.

14 l P age Figure 3: Phase 2 - Telework Pilot

Phase 2: Recommendations

Recommendation 13: Establish a new telework option, hybrid remote worker, that req uires a minimum of 2 days per month in-person and PwP.

• Supervisors will have the discretion to add days consistent wi th their responsibility to support necessary in-person PwP activities. This telework optio n is limited to employees that reside within 50 miles of their assigned agency worksite.

• Employees who elect this telework option will be considered hy brid remote workers. The hybrid remote worker differs from full remote workers because h ybrid remote workers will be in-person on a regular and recurring basis, that is a m inimum of twice per month.

A hybrid remote workers duty station will change to their alte rnate worksite because they will be scheduled to report to the agency worksite less th an two days per pay period. Note: some eligible employees may elect to voluntarily maintain a fixed telework schedule of greater than 2 days per pay period to retain a high er locality pay instead of converting to hybrid remote status.

• This option is available to employees who reside within 50 mil es of their assigned agency worksite. Federal Travel Regulations require agencies to reimburse employees for travel exceeding 50 miles, including time spent traveling t o the office when the employees duty station is not the NRC facility.

This recommendation may raise fairness concerns for employees t hat live greater than 50 miles from their assigned agency worksite. A relatively small p ercentage of employees live

15 l P age outside the 50-mile limit for m andated reimbursement. Excluding employees on full-time telework agreements, we estimate that approximately 150 out of the 2800 staff in the agency fall into this category. (Further details about the assu mptions underlying this estimate can be found in Enclosure 6.) By federal law, the agency would be required to consider hybrid remote employees living beyond 50-mile of the a gency worksite to be on official duty travel when commuting into the office. We estimat ed this would cost the agency

$1.2 to $2 million annually, see Enclosure 6. We also considered the agency cost savings that might be realized by reducing the NRCs office space if we included these employees in the hybrid remote worker plan. Any space savings associated wit h transitioning approximately 150 staff from 2 days per pay period to 2 days pe r month spread across six different NRC office locations would be relatively small; and a ny net savings would not be realized for years. An additional consideration is that the ana lysis only accounted for current employees and did not adjust for potential cost increases in th e future if more workers elect to live beyond the 50-mile range. As a result, we do not recomm end making employees residing beyond the 50-mile range eligible for the hybrid remot e plan. These workers will remain hybrid workers.

We recognize that the hybrid remote plan is progressive and rep resents a significant reduction to in-person presence, which comes with the risk of u nintended effects on organizational health and on our ability to successfully train and develop new employees and future agency leaders. We were particularly concerned with the potential impact on our ability effectively onboard, train, and integrate into the NRC culture a large percentage of new employees; over the next several years the NRC may evolve t o a condition where nearly 50 percent of agency staff will have less than five year s of NRC experience. There is a potential concern that the amount of in-person engagement con tained in this recommendation may not be sufficient to properly train and inte grate these new employees into the NRC workforce. However, if embraced by all employees, PwP should mitigate this risk if employees identify the need for and conduct in-person i nteractions to properly onboard and develop new staff. Therefore, we were largely willi ng to recommend accepting this risk for a limited-duration pilot in exchange for the oppo rtunity to collect data that will allow the agency to closely monitor impacts on organizational h ealth and to assess the effectiveness of the agencys ability to make the new hybrid wo rk environment and PwP successful. Preliminary thoughts on data collection needs to mo nitor pilot implementation are provided in Enclosure 7.

Upon implementation, there will be increased cost to the agency for employees who are located less than 50 miles from an agency worksite. Based on su rvey data collected, for the vast majority of respondents within 50 miles, locality pay will not change. However, we identified a risk of further increased agency costs as a result of employees who potentially relocate to a higher locality pay area or onboarding new employ ees in a higher locality pay area. It is important to monitor and manage associated costs an d determine if future changes to the hybrid work model are warranted.

As discussed in Phase 1, a key risk that we considered was the potential impact of ineligibility for the hybrid remote plan on our ability to recr uit and retain staff for positions that are less portable. Phase 2 has the potential to compound this r isk further.

16 l P age Recommendation 14: Modify Management Directive 14.1 Official Temporary Duty Travel to provide that the NRC will not reimburse local travel for employ ees commuting 50 or less miles from their alternate worksite to their assigned agency worksite. The modification does not affect reimbursement for local travel for other purposes.

Phase 2: Implementation Activities

• Execute an Implementation and Change Management Plan

• Create a SharePoint site and dashboard to monitor and communica te telework pilot information

• Establish an Agency PSAT Risk focused on the success and sustai nability of the telework pilot implementation and to assess the impact on organ izational health.

• Report telework pilot metrics during Quarterly Performance Revi ew meetings.

• Implement a one-year pilot

• Measure the pilot results throughout the implementation year (i ncluding maintaining awareness of external factors that could shape the pilot)

Post-Pilot Assessment and Path Forward

While monitoring will occur throughout the implementation of th e pilot, we recommend that a post-pilot assessment be conducted to determine the path forwar d for implementation of NRCs telework policy.

Recommendation 15: Conduct a thorough assessment of the pilot to inform any new policy changes or potentially determine a need to modify or extend the pilot to better inform the content and implementation of a new policy.

Post-Pilot Assessment Activities

• Develop a new telework policy or extend/modify the pilot to gai n additional information to inform the final policy

• Identify policy implications and make modifications to affected policy documents and guidance

• Modify the agencys signposts and markers to include an assessm ent of the agency telework program (ex. environmental factors, monitoring/trends)

• Establish a plan for continuous assessment of policy and implem entation

• Implement new policy changes based on results of the pilot

• Consider the impact to office space experienced over the pilot in developing a long-term plan and final policy

17 l P age Enclosures : TPIWG Team Composition : Glossary of Key Terms : Results of the TPIWG Charter Objectives Evaluation : Be Risk SMART Remote Work Eligibility for Temporar y Assignments : Be Risk SMART Telework Pilot Analysis : Telework Pilot - Hybrid Work Model at a Glance and Narrative : Assessing Effectiveness of the Telework Pilot : Listening Session and Employee Feedback Summary : TPIWG Selected List of Key References

18 l P age Enclosure 1: Team Composition

As outlined in memorandum, Charter for the working group on assessing the NRC telework policy and implementation, dated July 14, 2022, the EDO selected the following senior managers to serve on the TPIWG.

• Mike King, Co-Chair TPIWG, Deputy Director for Reactor Safety Programs a nd Mission Support, Office of Nuclear Reactor Regulation

• David Pelton, Co-Chair TPIWG, Deputy Regional Administrator, Region II

• Bernice Ammon, Deputy General Counsel for Licensing, Hearings, and Enforceme nt, Office of the General Counsel

• Stephanie Coffin, Deputy Director, Office of Nuclear Regulatory Research

• Eric Dilworth, Deputy Chief Human Capital Officer

• Scott Flanders, Deputy Chief Information, Officer Office of the Chief Informa tion Officer

• Raymond K. Lorson, Deputy Regional Administrator, Region I

In addition, the following individuals provided technical staff support:

• Carey Bickett, Technical Assistant, Region I

• Christine Steger, Executive Technical Assistant, Office of the Executive Director for Operations (detail; home office OCHCO)

TPIWG members during in-person work session. TPIWG members during virtual work session.

19 l P age : Glossary of Key Terms

The key terms described below are referenced throughout the TPI WG report. To provide consistency, we use terms and definitions provided in the OPM T elework Guidance, the Nuclear Regulatory Commissions HEART Report, NRCs Strategic Plan Fisc al Years 2022-2026, and the Collective Bargaining Agreement (CBA).

• OPM 2021 Guide to Telework and Remote Work in the Federal Gover nment: (page 11)

• HEART Report: Appendix B ML22271A896

• NRC Strategic Plan Fiscal Years 2022-2026 (NUREG-1614, Volume 8, page 13)

• Collective Bargaining Agreement Article 7 - Telework

Agency Worksite Agency worksite refers to an official federal agency location w here work activities are based, generally considered a centralized location of an employees as signed organization. The term regular worksite is also used to describe agency worksite. [OPM]

Alternative Worksite Alternative worksite is generally considered an employees appr oved telework site, or, for a remote worker, the approved remote site (e.g., an employees re sidence). [OPM]

Distributed Workforce An organizational unit with some members working primarily at v arying locations from each other. [HEART]

Duty Station The duty station is the location of the employees official wor ksite as documented on an employees Standard Form 50. [OPM]

Fixed A recurring telework arrangement with a fixed schedule that des ignates the day(s) and hours each pay period in which work w ill be performed at the employee s home or approved offsite location [alternative worksite], including other NRC facilities not associated with an employees position of record. A request for approval of a fixed telework schedule shall be submitted to the first-line supervisor. [CBA]

Full Remote Worker A type of teleworker who is not expected to perform work at an agency worksite on a regular or recurring basis. [TPIWG]

Hybrid Worker A type of teleworker who is required to have a minimum of in-pe rson presence two days per pay period with additional in-person days as necessary to support presence with purpose activities.

This hybrid workers official w orksite is the agency worksite. [TPIWG]

Hybrid Remote Worker A type of teleworker who is required to have a minimum of in-pe rson presence two days per month with additional in-person days as necessary to support pr esence with purpose activities.

The remote hybrid workers official worksite is an alternate wo rksite that is less than or equal to 50 miles from their agency worksite. [TPIWG]

20 l P age Hybrid Work Environment An organization that maintains a workplace scenario where the w orkplace is not fixed or homogenous. Typically, in a hybrid work environment a subset of the organization works physically from the office paired with another subset that work s away from the office on any given day. [HEART]

In-Office or Onsite Work location that is not the employees alternate worksite. Ex amples would include, but are not limited to, an NRC office, licensee site, inspection field location, and/or in-person training location. [TPIWG]

In-Person More broadly used in terms of being physically present together such as face-to-face interactions that may occur in-office by meeting with someone r ather than engaging via Teams, talking on the phone, or e-mailing. [TPIWG]

Locality Locality relates to the region where the employee works. This f actor adjusts the base rate of pay for the cost of living in a geographic area. While each pos ition is assigned to a specific grade, and each employee is assigned to a step within that grad e, the pay rate will vary by location. [OPM] Locality Pay Area Definitions

Official Worksite Official worksite is the agency worksite for most employees, in cluding a teleworker [hybrid worker]. For a [full] remote worker, the official worksite is t he alternative worksite to which the agency and the employee agreed (e.g., the employees residence). The official worksite is generally the location of an employees duty station as documen ted on an employees Standard Form 50. [OPM]

Organizational Health At the NRC, organizational health refers to the NRCs ability t o adapt and cope with change, while continuing to meet its important public health and safety mission.

A healthy organization would result in an infrastructure that f acilitates continuous learning and innovation, knowledge management, diversity and inclusion, tech nology adoption, and strategic planning, which inspires the NRC's workforce.

A healthy organization includes a culture that creates a sense of belonging, promotes and sustains a strong safety culture, fosters creativity and innova tion, connects vision with action, and continuously adapts and strives to be a healthy organizatio n. [HEART and NRCs Strategic Plan]

Presence with Purpose Approach In a Presence with Purpose approach, the organization emphasi zes being intentional about connection and flexible regarding location of where work is per formed. Employees go to in-person locations, as needed, to accomplish work that cannot be performed remotely (e.g.,

facility inspection). Further, in-person interactions should be considered for connection, collaboration, creation, and celebration. [HEART]

Project-Based Telework

21 l P age A short-term telework, when an employees work assignments, or a portion thereof, can be performed remotely for a short period of time. The duration of an approved project-based telework arrangement can be measured in terms of hours or a few days. [CBA]

Special Circumstances A non-permanent telework arrangement [typically full remote] fo r a relatively short period of time due to personal incapacitation or a personal hardship. [CBA]

Telework The term 'telework' or 'teleworking' refers to a work flexibili ty arrangement under which an employee performs the duties and responsibilities of such emplo yee's position, and other authorized activities, from an approved worksite other than the location from which the employee would otherwise work. [HEART and OPM]

22 l P age : Results of the Evaluation of the TPIWG Charter Objectives

The TPIWG considered and evaluated the following five objective s outlined in the Charter to inform our recommendations.

• Objective 1: Develop key messages around hybrid work including the benefit s to the organization of remote work and the benefits to the organizatio n of in-person engagement.

• Objective 2: Evaluate the implementation of hybrid (combination of virtual and in-office) work schedules, including how to provide flexibility in schedul ing in-office work to support effective collaboration, mentoring, difficult conversations, et c.

• Objective 3: Evaluate the implementation of full-time telework within the commuting area, including consideration of the level of approval and ways to ensure transparency and consistent implementation for similar work throughout the a gency. Evaluate the use of the term rare in existing policy and practice.

• Objective 4: Evaluate consideration of the agency interests and level of a pproval related to authorizing full-time telework outside the commuting area.

• Objective 5: Evaluate impacts of telework (with particular focus on onboardi ng, knowledge management, and organizational health) and identify s pecific examples for people to come into the office.

Objective 1: Develop key messages around hybrid work including the benefits to the organization of remot e work and the benefits to the organization of in-person engagement.

Response

Our re-entry experience has demonstrated that the types of acti vities conducted remotely verses in-person must be thoughtfully considered in order to ha ve PwP. Some types of work are enhanced by being conducted remotely, while others may bene fit more if conducted in-person. Intentional collaboration and PwP will need to be a key part of our day-to-day thinking and planning to sustain a healthy culture, complete the work ac tivities that must be, or can most effectively be accomplished in-person, while increasing telewor k opportunities to enhance employee work-life balance. In-per son activities provide us wit h the opportunity to connect, collaborate, create, and celebrate, which are key components of maintaining organizational health.

Successful implementation of hybrid work enables any organizati on to reap the benefits of both in-person and remote work, improving organizational agility and effectiveness. There are some clear benefits to both (as outlined below) however, determining the appropriate balance between in-person and remote work is not an exact science and w ill likely evolve as we gain additional experience.

Based on reviews of related literature, benchmarking, listening session feedback, individual staff member feedback, and other data, the following are some example s of key benefits of remote and in-person work and the TPIWG report highlights some additio nal examples:

23 l P age Benefits of Remote:

• Increased flexibility to support work-life balance

• Less commute time

• Increased productivity during working hours

• Increased access to meetings through virtual platforms

• Increased opportunity to realize long-term cost savings (Space, etc.)

• Increased resilience to bad weather, etc.

• Increased resilience to individual personal chall enges

• Extends trust up and down and across the or ganization

Benefits of In-Person:

• Improved interpersonal c onnections

• Increased focus and fewer digital distractions

• Improves ability to work through conflicts

• Enables more effective team building

• Provides more opportunity for organic & serendipitous interact ions

• Makes it easier for free-flowing discussions

• Helps to avoid the Always On syndrome

Like others seeking to optimize the hybrid work experience, we do not have all the answers. We fully acknowledge that some degree of risk and uncertainty exis ts with how best to implement a more flexible hybrid work model. We believe that conducting a p ilot, with embedded monitoring capability to measure successes and challenges, will allow us t o move forward with a more flexible hybrid work model while providing a platform for addre ssing concerns and identifying best practices. As identified by HEART, these is no one-size-f its-all solution for the appropriate mix of in-person and virtual work activities. We wi ll need to work together, learn together, and grow together with a shared goal of realizing the benefits of both in-person and remote work.

Objective 2: Evaluate the implementation of hybrid (combination of virtual and in-office) work schedules, including how to provide flexibility in scheduling in-office work to support effective collaboration, mentoring, difficult conversations, etc.

Response

The working group began this effort by reviewing the underlying factors that led to the agencys decision to develop a hybrid work model, or a model that involv es a mix of work locations, both in-person and virtual, with a majority of the staff expected to work virtually for some part of the

24 l P age work week. These factors were described in a message from the E DO 7F8 dated July 28, 2021, and included: staff input, an assessment of scholarly works, an d the judgement of NRC senior leaders. The EDOs message stated that the longer-term benefits of having some face-to-face interactions enhanced our ability to achieve our mission and al so stated a desire to maintain those benefits following re-entry. The EDO message also highlig hted the success of the agency at accomplishing the mission during the pandemic and attributed the success, in part, to the leveraging of strong partnerships and relationships that had be en developed prior to the pandemic through in-person interactions.

Based on how well the organization functioned in a nearly full remote work model during the height of the pandemic, NRC leadership saw value in expanding t he use of telework following re-entry and developed a model wher e a majority of the employees would have the opportunity to telework six days a pay period, which was greater than the n umber of days that many of the staff teleworked prior to the pandemic. While not explicitly st ated, it seemed the goal of implementing a hybrid work model was to provide a framework that balanced the need for sufficient in-person interactions to sustain a healthy culture, and complete the work activities that must be, or can most effectively be accomplished in-person, while increasing telework opportunities to enhance work-life balance. With these goals in mind, effective implementation of a hybrid work schedule would seek to have employees in-offic e for activities that benefit most from in-person interactions and would provide flexibility to al low employees to work virtually when in-person interactions are not anticipated or needed to wo rk effectively. We evaluated two work schedule models:

• The agencys current schedule where a majority of the staff ar e expected to work in-office a minimum of four days per pay period, and

• A flexible schedule that emphasizes an approach where in-offic e days are developed and adjusted as needed to support PwP activities and engagement.

Current Agency Work Schedule

The agencys current hybrid work schedule model requires a majo rity of staff to come into the office four days per pay period (nominally two days per week) unless an exception is approved.

An employee may request a work schedule that requires less than two days of in-office presence per week and that request is required to be approved b y the office director/Regional Administrator. In addition, an employee may request to work vir tually full-time (i.e., remote worker) and those requests must be approved by the office direc tor/Regional Administrator and also by the Director of the OCHCO. While some work units may co ordinate schedules of employees, the current policy does not require that in-office d ays be coordinated with other colleagues. The current model has been in place for about 8 mon ths, which does not account for the approximate 3-month period (mid-December to mid-March) where the agency returned to maximum full-time telework following an increase COVID infectio ns from the Omicron variant.

Based on observation, data provided by HEART, and input from li stening sessions, implementation of the current hybrid work schedules has not ful ly achieved the goal of having a sufficient number of meaningful in-person interactions to condu ct culture sustaining activities.

8 Important Updates on Agency Re-Entry Plan, Implementation, and Announcement of Full Re-Entry Date, https://intranet.nrc.gov/announcements/standard/covid-19/65458.

25 l P age Many employees have reported that they rarely see colleagues wh en they come into the office and frequently perform many of the same activities in-office as they do when working virtually.

For example, employees may participate in Teams meetings and in teract with other colleagues who are working virtually while the employee is working from th e office on one of their scheduled in-office days. The feedback from the staff and super visor listening sessions suggests that there does not appear to be sufficient guidance a nd/or a common understanding of the flexibilities available within the current work schedule, which has led to inconsistent implementation, not fully utilizing available flexibilities, an d not fully achieving the benefits of having employees in-office.

Many of the challenges above can be attributed to a few key fac tors. First, the current hybrid work model requires the same number of fixed in-office days for most of the employees, without consideration of the type of work performed. The HEART report stated that the appropriateness of different types of hybrid work schedules var ies greatly by organizational function, team, role, and individual. There is no ideal one-siz e-fits-all answer.8F9 In our case, establishing a four day per pay period in-office work schedule for most staff created a requirement for employees to come into the office on a fixed schedule without sufficient consideration of the activities to be performed while in-office. As noted above this led to many employees performing similar ac tivities while in-office that th ey were performing at home (e.g.,

participating in Teams meetings, heads down report writing, etc.) Second, the flexibility afforded to the employees to select their in-office days has not led to having sufficient numbers of employees in-office together to take advantage of meaningful in -person interactions. Third, guidance to employees and supervisors prior to re-entry was not sufficient to ensure a common understanding of the flexibilities and adjustments to the fixed work schedules that could be implemented to better support employee requests and/or to enhan ce the experiences and interactions of employees during their in-office workdays.

Flexible Schedule

One alternative to the agencys current hybrid work model is a flexible schedule model. A flexible schedule would encourage staff and supervisors to iden tify and adjust work schedules to support meaningful in-person presence activities. If properly i mplemented, a flexible work schedule provides an increased opportunity for staff to have mo re meaningful in-office interactions, particularly when coupled with a PwP philosophy a s recommended by HEART.

However, as HEART noted in their report, a flexible work schedu le model, even when implemented with a PwP philosophy, has the potential to have ne gative consequences such as inferior orientation and onboarding for new employees, less eff ective collaboration, diminished relationship building, and insufficient knowledge transfer/mana gement (See HEART Report Appendix L). Additionally, inconsistent application could also have a neg ative impact on organizational health and may lead to difficulty in filling imp ortant agency positions such as resident inspectors who dont have as much opportunity for tele work. The HEART report mentions some approaches through the use of technology that may help mitigate some of the challenges related to training of new employees, collaboration, diminished relationship building, and knowledge transfer.

TPIWG Recommended Hybrid Work Schedule

9 See page 9 of NRC Hybrid Environment Assessment and Review Team Report (ML22271A894).

26 l P age We agree with HEARTs recommendation to implement a PwP philoso phy when implementing hybrid work schedules, and we agree that teams and branches are best position to determine when, how, and where in-person interactions will best support t hat work unit. However, we believe that some guideposts are needed to help mitigate some o f the potentially negative consequences identified by HEART. While we agree with the mitig ation recommendations proposed by HEART, we also believe that establishing some param eters around in-person interactions for all NRC organizations is necessary to better f acilitate a more consistent approach across the agency to reduce the risk of the agency exp eriencing many of the negative impacts noted above. A core component of the NRC leaderships view on organizational health is to establish an environment to provide sufficient numbers of in-person interactions to conduct culture sustaining activities. For a level of consistency, and as a further mitigating action to address the challenges identified by the HEART, and to avoid th e challenge of not providing sufficient guidance during the initial re-entry, we determined that the flexible work schedule approach would work best when combined with expectations regard ing a minimal number of in-person days. We also think it is important to establish a clear expectation that the agency fully embraces PwP guiding principles and supervisors should not simp ly require employees to come into the office based solely on their own work preferences. To appropriately implement the PwP philosophy, we expect employees will likely need come into the office more frequently than the minimum (i.e., two days per month), but rarely more than the cu rrent requirement (i.e., 4 days per pay period or 8 days per month). Additionally, some in-offi ce days should be coordinated at an office level to further build office culture. As noted in th e recommendations section, changes will be necessary to fully implement the recommended hybrid wor k model. However, many of the changes related to emphasizing PwP and taking advantage of current flexibilities can be adopted before all the changes are implemented.

As noted in the HEART report, implementation of the current hyb rid work schedules could be improved without policy changes by supervisors using a PwP phil osophy to create more intentional in-person interactions when employees are in the of fice. Supervisors could use the guiding principles for in-person interactions (i.e., 4-Cs) to i dentify moments that matter and then work with the staff to adjust schedules to ensure those in-pers on interactions are meaningful.

This should reduce the number of instances where the employees come into the office and carry out the same work they do remotely. However, because of t he current four day per pay period fixed work schedule many employees will likely still hav e this experience. Any change to PwP philosophy should be complemented by additional employee tr aining on the 4-Cs to facilitate effective in-office collaboration, mentoring, and co nstructive resolution of conflicts when engaged in difficult conversations. It should be noted that in recent months the agency has sponsored supervisor training on leading in a hybrid environmen t. We recommend the PwP philosophy and associated training be developed promptly and im plemented immediately. This will improve implementation o f the current work schedule model while changes are being made.

27 l P age Objective 3: Evaluate the implementation of full-time telework within the commuting area, including considerati on of the level of approval and ways to ensure transparency and consistent implementation for similar work throughout the agency. Evaluate the use of the term rare in existing policy and practice.

Objective 4: Evaluate consideration of the agency interests and level of approval related to authorizing full-time telework outside the commuting area.

These two Objectives are considered together. For purposes of b oth phases of the pilot, the term full remote applies to what the agency has previously ca lled full-time teleworkers. We use full remote in the place of full-time throughout the di scussion of these two objectives.

This change aligns with OPMs definition of remote: an arrange ment in which an employee, under a written remote work agreement, is scheduled to perform their work at an alternative worksite and is not expected to perform work at an agency works ite on a regular and recurring basis.9F10 We added the term full to provide clarity and distinguish thi s category of teleworker from the hybrid remote category. Workers in this category may o r may not be within the commuting area of NRC facilities and the considerations we addr ess will apply without regard to the geographical location of a proposed full remote arrangement. Geographical location will, however, affect the choices some employees makethis also is tr ue for some potential remote hybrid workersand these will be discussed.

Full Remote Telework

Concerns. In addition to concerns over how re-entry was communicated, t he issue generating perhaps the highest energy since re-entry has been full remote telework, in all its permutations (e.g., local, geographically distant, special circumstances). S taff, first-line supervisors, and executives all have raised questions about implementation of th e existing policies and have provided views on how the policies should be modified. In our l istening sessions, we heard vocal criticisms of the agencys posture on full remote telewor k. Individuals pointed to a wide range of concerns, including the difficulty of receiving approv al for full remote telework and the level at which approval is required; the complexity of the proc ess for requesting full remote telework; the frequency with which renewal must be requested an d the associated stress related to annual review of full remote telework arrangements; the numb er/percentages of employees who should be on full remote telework within a work unit; eligi bility for continued full remote telework as a barrier to promotion; supervisory burdens related to managing both full remote telework and hybrid work modes; onboarding challenges; coaching ; hiring and retention challenges; and lack of consistency and equity within teams and across the agency. We heard a perception that the way full remote telework requests are pro cessed and evaluated has

10 Office of Personnel Management, 2021 Guide to Telework and Remote Work in the Federal Government (Nov.

2021) at 11, available at https://www.telework.gov/guidance-legislation/telework-guidance/telework-guide/guide-to-telework-in-the-federal-government.pdf.

28 l P age changedincluding when compared to pre-pandemic practiceswith the result that new and renewal requests are evaluated with an elevated level of rigor and at a higher level within OCHCO than they were before the pandemic arrived.

Counterpoint. In contrast to the vocal criticisms of the agencys hybrid po sture that we heard during our listening sessions, other input, including outreach from individual employees and survey input, paints a more nuanced picture of views on full re mote telework. Opinions on the importance of in-person, in-office/onsite interactions are mixe d, as are opinions on how much in-office presence is needed to maintain organizational health. Op inions also are divided on the types of interactions that are best performed in-office/onsite, though there appears to be general agreement that in-office/onsite presence should be purposeful. The working group does not have precise data on employee preferences. However, a small sam ple survey of bargaining unit employees conducted by the union showed that a majority of those surveyed preferred to be in the office at least two days per week, with a third prefe rring to be in the office three or more days per week. While not conclusive based on the small sam ple size, the result does suggest that employee preferences are not uniform, and that a n ot insignificant number of employees would prefer to be in the office with a high degree o f regularity.

NTEU Bargaining Unit Employee Survey Response to Telework Preference

0%

5%

3%

13% Always or Almost Always in the office

4% Telework 1 or 2 Days a Week 28% Telework 3 Days a Week

T e l e w o r k 4 D a y s a W e e k Local Remote (PwP)

National Remote 47% International Remote

Specific Considerations and Recommendations. A significant number of complaints heard during listening sessions and through other vehicles relate to the agencys implementation of its current full remote telework policies. Near-term recommendation s to address some of these concerns are presented in the body of the report; some of these recommendations have already been accepted, and others are in progress. Concerns related to the level of approval for full remote telework requests, including the approval process; trans parency and consistency of

29 l P age decision-making; use of the word rare and the criteria that s hould apply to full remote telework approvals; agency interests; and local versus geographically di stanced full remote telework considerations are examined here.

• Level of Approval (Approval Process)

Current Process. The agencys current process for requesting and receiving appro val for full remote telework is a multi-step process that starts with comple ting and submitting paperwork that wends its way through the supervisory chain. Office direct ors or regional administrators make the first call on whether a given request should be approv ed, but the final decision is made by the CHCO, who can overturn the office directors or reg ional administrators decision. Full remote telework request paperwork is complicated and burdensome. Renewals are required to be formally requested and re-approved on an ann ual basis. Employees on geographically distanced full remote telework agreements who se ek lateral or promotion opportunities are required to return to headquarters (or the re levant regional office) if they accept an offer and must reapply for full remote telework with no guarantee that their request will be approved.

Recommendations. Based upon input received, we recommend revising the entire process. First, the telework forms should be updated and simpli fied. Action on this front is underwaythe offices of the CHCO and Chief Information Officer have embarked on a project to examine workflows and requirements and to update, streamline, and automate the forms. To ensure and confirm complete understanding, the revised form wil l include a check box statement that transparently explains the implications for loca lity pay depending on the duty station proposed by the employee for full remote work.

Second, the level of approval required for full remote telework should be pushed down to the level where the right balance between the nature of the work an d the costs and benefits of the proposed full remote plan are best understood. We heard strong arguments that the branch chief is in the best position to understand the nature of the w ork, and therefore whether a particular full remote telework plan makes sense for the organi zation. There is validity to that pointbut the branch chief is not necessarily going to have the complete picture. Similarly, a centralized agency decisionmaker may be too far removed from th e day-to-day work to entirely understand the unique needs of the organization. Office directo rs and regional administrators are well-positioned to understand all factors. They have a good handle on the day-to-day work, the extent to which the work can be performed fully remote with out affecting organizational health, and the budgetary implications of various levels of ful l remote workers. As a result, we recommend that the decision-making authority to approve full re mote telework agreements be delegated to the office directors and regional administrators. As an additional consistency check, we recommend tasking a new subcommittee of the Human Cap ital Council with monitoring full remote work and suggesting course corrections w hen needed throughout phases 1 and 2 of the pilot.

To be crystal clear: Our recommendations are forward looking, a nd there are no plans to revisit existing full remote arrangements. Further, to reduce the stres s that accompanies the current requirement for annual renewal of full remote telework agreemen ts, we recommend replacing this requirement with a discussion and review during the annual appraisal process, with no renewal paperwork required. Generally, this should take place d uring the appraisal conversation between the employee and the first-line supervisor and should include a discussion of strategies that were successful during the apprai sal period as well as ideas to improve the effectiveness of the full remote arrangement going forward. Only in exceptional

30 l P age circumstances, where the nature of the work has changed to redu ce its portability, where full remote work can no longer be sustained and mission is affected, or where performance issues have not been able to be addressed despite concerted efforts to manage them virtually, should the arrangement be altered. In these circumstances, the first-l ine supervisor should have elevated the conversation to the office director or regional ad ministrator and should have engaged an employee relations specialist before engaging with t he employee on the topic, since approval authority will reside at that higher level.

Additionally, full remote workers should not be subjected to un necessary paperwork and approvals and should not face uncertainty when they look for pr omotion opportunities. As before, vacancy announcements should plainly specify locationb ut we recommend an option to post vacancy announcements with location TBD/Anywhere in s ituations where the work clearly can be performed fully rem otely, and where retention and recruitment needs, and the nature of the skillset required to fill the position justify fi lling it through a full remote posting. Similarly, job postings for positions that cannot be p erformed fully remotely should so state with absolute clarity. Further, offers to employees on ex isting full remote telework agreements should confirm that the offer includes continuation of the full remote arrangement, with no requirement to first return to headquarters (or the reg ion) to reapply for a full remote arrangement. Action to develop and implement optional TBD/Anyw here location language is in progress, with the OCHCO taking the lead.

• Transparency and Consistency

Current Status. Perceptions regarding transparency and consistency are mixed. Employees do not understand the basis for full remote telework decisions and perceive inequities in how approval and denial decisions are made. The approval process is a black box; many expect the routine answer to be denial. There are perceived inequities/con sistency concerns between employees with long-standing full remote telework agreements an d employees seeking similar agreements now. There also are perceived inequities/consistency concerns for those desiring local full remote telework arrangements as opposed to geographi cally distanced full remote arrangements.

Recommendations. Guidance for full remote telework decision-making should be t ransparent, well-understood, and consistent across the agency. Information about the process for applying for a full remote arrangement should be easy to find, posted on a prominent, centralized intranet site together with information about work schedule requirements, available schedule flexibilities, and project-based work options for each phase of the pilot, as well as PwP expectations. This intranet site should also serve as the portal to the revamped, automated telework forms. In addition, it should include clear guidance on the criteria to b e used when making an approval decision, so that employees, supervisors, regional administrato rs, and office directors have a shared understanding of the process. It also should include gui dance for supervisors and personnel staffing specialists regarding the decision on when t o post vacancies announcements with location TBD/Anywhere and when location restrictions are appropriate based on the nature of the work. This guidance also should address situation s where consultation with another office director or regional administrator is required. For example, if a vacancy is posted with location TBD/Anywhere, and the anywhere could end up b eing onsite at a regional office because of the nature of the job (e.g., information security re quirements), the regional administrator should be consulted in advance, preferably at the vacancy announcement stage, to confirm the availability of office space.

31 l P age As discussed, placing the authority for making approval decisio ns at the regional administrator or office director level, will serve to provide consistency and a balanced decision based on the type of work and broader office staffing, resource, knowledge m anagement, and culture concerns. Also as discussed, the new subcommittee of the Human Capital Council charged with monitoring full remote work will provide an additional lay er of consistency.

• Use of the Word Rare (Full Remote Telework Approval Criteria )

Current Usage. The use of the word rare in connection with full remote appro val decisions, together with the guidance provided to leadership was a flashpo int for employees. Another flashpoint was the succession planning language included in the full remote telework approval forms. This language is interpreted by many as requiring superv isors to plan for replacing the fully remote employee with a person who would be located at hea dquarters or in a regional officewith the implied eventual termination of the full remote workers agreement and a forced choice to return or to leave the agency. Employees view use of the word rare as code for a policy of routinely denying full remote telework requests.

Recommendations. The proposed hybrid model, which includes a significant reducti on in the number of mandatory days in-person onsite, coupled with additio nal, meaningful PwP in-person onsite activities, may largely obviate desire for requests for full remote telework schedules, except for employees who live a si gnificant distance away from NRC facilities. In view of this potential result, we anticipate that requests for approval of f ull remote telework schedules whether local or somewhere else in the countrymay be infrequen t and low in number. To the extent such requests are nonetheless made, routine, wholesale a pprovals of full remote telework schedules would be inconsistent with the PwP approach and would complicate our ability to meet organizational effectiveness goals. Criteria fo r approval decisions do need to be established, however. These criteria need to be transparent and easily understood by employees and managers alike.

OPMs telework guidance, on the Recruitment & Retention page, states that Agencies are encouraged to use telework as a tool to help attract, recruit, and retain the best possible workforce.10F 11 Further, telework can be used as an effective succession plann ing tool, encouraging potential retirees to continue workingto facilita te a smooth and continuous transition of institutional knowledge and technical competencie s.11F 12 While this guidance applies to telework generallyincluding schedules where employees telew ork only part of the timeit also is instructive in the context of approvals for full remote telework requests. To balance organizational needs to build the best possible workforce with the critical skills needed to perform the mission, we recommend using full remote telework as a tool for recruitment and retention, including retention for knowledge management purpose s.

Some factors to consider when deciding to use full remote telew ork as either a recruiting or a retention tool:

• Using the retention or the recruiting tool to maintain critica l skills is in the agencys best interests

11 Accessible at: https://www.telework.gov/guidance-legislation/telework-guidance/recruitment-retention/.

12 Id.

32 l P age

• The skill set is unique, and the agency has experienced great hardship in finding or developing high performing employees with the requisite knowled ge, skills, and abilities

• The current hiring environment and market analysis demonstrate that competitors routinely offer full remote work for this type of position

• The work is nearly 100% portable and can be successfully compl eted with only occasional in-person presence

• The cost of travel has been explicitly captured in the office budget, and there is a net benefit to the agency

Additional factors to consider when deciding to use full remote telework as a retention tool:

• The employee is a demonstrated flight risk or is in a position that is highly recruited externally

• The employee is a key contributor to mission effectiveness, wi th multiple years of superior performance

• The employee has demonstrated the ability to operate effective ly in a virtual environment, with little supervision

• The employee has repeatedly shown the ability to skillfully us e tools and techniques for collaboration, knowledge management, and training of other empl oyees

• Cost and time to backfill for the employee are significant

• The employee has a temporary or permanent need for full remote work due to life events outside the employees control

Additional factors to consider when deciding to use full remote telework as a recruiting tool:

• All acceptable candidates (internal and external) with the ski ll set want full remote work

• Employees already in full remote status are known to have skil l sets matching the requirements of the position

• Need to fill the position is acute

Some employees and supervisors believe there are whole categori es of work that are, by definition, fully portable; these categories are in job series where the agency has historically had recruitment challenges that have only been exacerbated by the c urrent telework policy. We do not recommend the establishment of position-based categories at this time. But experience during the pilot may shed light on whether the agency should co nsider denoting certain positions as automatically eligible for full remote telework in the future. Other federal agencies have embarked on this course of action, and we can leverage the ir experience if the agency decides in future to pursue position-based categories.

• Agency Interests

The agency has a basic need to maintain organization effectiven ess going forward. The hybrid work model we recommend fundamentally requires some routine in-person PwP to sustain a healthy organizational culture. The model we propose includes a combination of hybrid, remote hybrid, and full remote work, with hybrid and remote hybrid as the predominant modes and full remote the exception. Too many exceptions to the hybrid plan wo uld complicate our ability to meet organizational effectiveness goals and should only be cons idered where there is an overriding agency need, specifically, the need to retain or rec ruit highly qualified employees with critical skills. Additional agency interests include budgetary considerations, including costs of bringing geographically distanced full remote workers back to t heir headquarters or regional facility for PwP engagement with some reasonable periodicity; f airness and equity concerns for

33 l P age employees who are not approved for full remote work; and potent ially diminished promotion opportunities for full remote workers.

• Commuting Area (Local versus Geographically Distanced Full Rem ote Telework)

Current Model. Generally, the pre-pandemic and re-entry practic e has been to view full remote telework as something that occurs in a geographical distant loc ation. Local full remote telework has been discouraged except in the most exceptional circumstanc esoften only in the context of a reasonable accommodation scenario or a situation where tem porary special circumstances support full remote work for a brief period.

Recommendations. Setting aside the independent process for seek ing a reasonable accommodationwhich is not under consideration herethe process for requesting full remote telework should be the same whether the request is for local or geographically distanced full remote teleworksee the approval process and approval criteria discussions above.

Importantly, however, the implicat ions of a decision to request full remote telework should be clearly explained to employees and supervisors. In particular, a fact sheet explaining locality pay rules and employee responsibility for relocation expenses s hould be prepared, as should a fact sheet regarding the agencys responsibility for travel exp enses. As discussed above, the telework forms should include a statement explaining the implic ations of an employees choice to request full remote telework on locality pay, with a check b ox to acknowledge understanding. Expectations for in-office presence for both loc al and geographically distanced full remote teleworkers should be established and should includ e in-person PwP activities on a frequency that aligns with the nature of the work and the offic e director or regional administrators assessment of the appropriate number of times p er quarter or year that full remote workers should be onsite.

Objective 5: Evaluate impacts of telework (with particular focus on onboarding, knowledge management, and organizational health) and identify specific examples for peop le to come into the office.

Given the agencys demographics, we have an acute need to ensur e our onboarding and knowledge management remain effective and our organizational he alth is sustained in a hybrid work environment. There is a widely held belief that onboarding, and knowledge management are most effective and organizational health is best sustained through regular, frequent, in-person interactions. As with all things telework-related, this belief has been challenged by our lived experience. The most effective approach to a specific sit uation depends on many factors.

It depends on the individuals involved (e.g., tactile learner v ersus auditory learner), how well they know each other (e.g., new relationship versus well-establ ished relationship), and the quality of the relationship (e.g., antagonistic versus easy). I t depends also on the complexity of the material and information of interest (e.g., tacit knowledge versus explicit knowledge). Social scientists agree physical connection is important for human bei ngs to thrive [NASA]. In the workplace, however, the amount of physical connection necessary for an individual or a team to thrive will vary widely, d epending on the individuals, team d ynamics, and the nature of the mission-related work. The HEART reports recommendation of PwP and the 4Cs of connect,

34 l P age collaborate, create, and celebrate provide all employees with t he framework to determine the most effective approach.

The overarching sentiment from the listening sessions indicated that onboarding and knowledge management, has been and will continue to be successful, and th at organizational health will continue to be sustained even in a fully remote environment. Th e testimonials of several new hires who shared their positive onboarding and training experie nces during the pandemic, while under maximum telework were of particular relevance. In contras t to this experience, an exit survey of our summer hires indicated a desire for more in-perso n interactions. We also received feedback through informal emails, chats and drop ins that indic ated some amount of in-person connection was desired, particularly for these three areas. Our recommendations recognize how much our employees can do well in a virtual environment and the benefits that accrue from teleworkingthus we recommend expanding telework flexibilities. Our recommendations similarly recognize how critical in-person interactions are in support of many agency activities, particularly in the areas of onboarding, knowledge management, and organizational health.

Thus, we recommend implementing PwP including a monthly core d ay for all headquarters and Technical Training Center offices.

Lets turn to the benefits of and examples for in-person intera ctions:

• Physical proximity can enhance a sense of belonging (e.g., whe n welcoming a new hire into the agency)

• Physical proximity can provide an increased sense of safety (e.g., when participating in a contentious public meeting)

• Physical proximity can improve future performance (e.g., when preparing for presentations to the Advisory Committee for Reactor Safeguards, the Atomic Safety and Licensing Board, or the Commission)

• Physical proximity can enhance understanding and engagement (e.g., when brainstorming a solution to a thorny issue or explaining a comp lex technical topic)

Many important activities require in-person presence. The HEART report refers to such activities as location dependent. We note that the activity r arely takes place in an employees workspace and may not occur in an NRC facility. We believe thes e activities are self-evident and well-understood by employees. Examples of such activities a re provided below.

• Administrating badging, issuing laptops, and distributing mail

• Conducting inspections at an NRC licensee, applicant, or poten tial applicants facility

• Conducting environmental public scoping meetings at the locati on of interest

• Observing experiments or visiting experimental facilities

• Presenting at domestic or international conferences

• Presenting to the ACRS, ASLB, ACMUI, and the Commission

• Conducting classified or safeguards activities and some Freedo m of Information Act (FOIA) activities

• Responding to an event at an NRC facility or an NRC licensees facility

• Maintaining safe and secure NRC facilities

• Administrating operator licensing exams

• Administrating or participating in drug testing

• Escorting visitors at an NRC facility

• Troubleshooting (e.g., building issues, IT issues)

35 l P age There are also important activities that benefit from in-person presence, that align to a 4C outcome (i.e., connect, collaborate, create, and celebrate). Wh at may be challenging about these types of activities is that the in-person benefits may be less obvious or immediate and less valued by one or more of the affected participants. A Harv ard Business Review article described a work environment similar to our work environment an d offered a useful view about how to move forward [Harvard]. Examples of gatherings that often benefit from in-person presence are provided below.

• Onboarding new employees (e.g., supervisor and team introducti ons, building walk-arounds, getting supplies, certain training, and development ac tivities, establishing relationships) [Connect]

• Conducting Alternate Dispute Resolution meetings [Connect, Col laborate]

• Participating in recruiting events [Connect]

• Participating in certain training events (particularly multi-d ay intensive training) [Create]

• Recognizing employee contributions (e.g., giving or receiving awards and length of service, participating in retirement events) [Celebrate]

• Participating in public meetings and conferences [Connect, Col laborate]

• Resolving a conflict and/or devising a solution [Collaborate]

• Receiving distinguished guests [Connect]

• Giving and receiving feedback, coaching, or mentoring [Collabo rate]

• Brainstorming, particularly when body language and immediate r esponse or when white boarding improves understanding and engagement [Create, Collab orate]

• Participating in team building (e.g., kick-off meetings, proje ct planning, brainstorming sessions, celebrating milestone completions) [Create, Connect, Collaborate, Celebrate]

• Networking [Connect, Collaborate]

• Attending affinity group gatherings [Connect, Collaborate, Cel ebrate]

• Preparing for high-priority, high-visibility meetings, qualifi cation boards, interviews

[Create, Collaborate]

• Recognizing major organizational change events (e.g., new buil ding or major renovation, organizational structure change) [Connect, Celebrate]

A schematic of what an in-office day in the life might look l ike for an employee follows:

36 l P age 37 l P age

Travel Reimbursement for PwP

Distance Our proposal defines three categories of telework employees.

Column 1: Hybrid Worker

Hybrid Worker: A type of teleworker who is required to have a m inimum of in-person presence 2x per pay period with additional in-person days as ne cessary to support PwP activities. The hybrid worker s official worksite is the agency worksite.

Column 1 describes employees that by the nature of their work, are required to be in-person at least two days per pay period. In some cases, this could involv e significantly more than two days per pay period depending on the requirements of the job po sition (e.g., resident inspectors, headquarters operations officers, facilities personnel, etc.). This column would also include employees that may be eligible for Column 2 but choose to commu te to one of the six NRC office locations (i.e., Headquarters, Regions I - IV, Technical Training Center) which they are assigned to at least two days per pay period by choice and/or t o maintain their assigned NRC office locality pay. Under this option, supervisors maintain th e discretion to exceed the minimum in-person days as necessary to support PwP activities. Column 1 is most like the current hybrid schedule but requires only two days per pay peri od in-person instead of four. As is currently, the duty station and locality pay for these emplo yees would be associated with their assigned NRC office. Time spent traveling to and from their ass igned NRC office location would be considered normal commuting time and would not be reimbursab le. Activities which are covered under official travel and/or local travel currently (e. g., inspection, training, etc.) would be unchanged under the proposed hybrid work model for employees in Column 1. Work schedule approval authority for this column would be the responsibility of the respective branch chief.

Column 2: Hybrid Remote Worker

Hybrid Remote Worker: A type of teleworker who is required to h ave a minimum of in-person presence 2x per month with additional in-person days as necessa ry to support PwP activities.

The remote hybrid workers official worksite is an alternate wo rksite that is less than or equal to 50 miles from their agency worksite.

Column 2 describes a fixed schedule of less than two days per p ay period, with a minimum of two days per month in-person with additional in-person days as necessary to support PwP activities. Employees that fall into this category generally ha ve work that is fully portable.

Because in-office presence is less than two days per pay period, employees in this category will not meet OPM requirements for maintaining their assigned NRC office as their official duty station, and therefore, locality pay and duty station would be based on the employees alternative worksite (e.g., home). Given the change in official duty station, we considered three separate subcategories in Column 2 to quantify potential impact s to the agency, especially those associated with changes in locality pay, commuting time, and travel expenses.

• Employees that live less than or equal to 50 miles from their assigned NRC office. We determined 50 miles was appropriate based on Federal Travel Reg ulation requirements to reimburse any travel (including time spent commuting) greate r than 50 miles.

• Employees that live greater than 50 miles but less than or equ al to 120 miles from their assigned NRC office. We considered 120 miles as an upper bound for this category because it represented a reasonable commuting distance. Employe es in this category would be eligible for official temporary duty travel for any tr ips from their alternative worksite to their assigned NRC office for PwP activities. Addit ionally, employees that

55 l P age travel outside of their regular work schedule would be eligible for comp time for travel, and travel during their regular work schedule would be compensa ted as regular hours.

• Employees that live greater than 120 miles from their assigned NRC office. Employees in this category would be eligible for official temporary duty travel for any trips from their alternative worksite to their assigned NRC office for PwP activ ities. Additionally, employees that travel outside of their regular work schedule wo uld be eligible for comp time for travel, and travel during their regular work schedule would be compensated as regular hours.

To further refine the potential agency impact of allowing emplo yees to work less than two days per pay period at their assigned NRC office, we issued an agenc ywide survey to gather data on pay, job function, distance from assigned NRC office, commute t ime, and locality pay. The survey was active from October 3 - 14, 2022 and received 1507 r esponses. This survey data provided a snapshot of how current employees would fit into the proposed hyrbid work model.

The survey data also allowed us to estimate agency costs associ ated with employees traveling to and from an agency worksite for PwP activities. These costs included travel time, changes in locality, transportation, travel voucher fees, meals and incide ntals, and lodging. Assumptions made during the analysis included:

• Localities and hourly rates were based on 2022 values. Per die m costs were based on 2023 values. If per diem rates fluctuate throughout the year, t he highest value was used.

• All employees were at a step 10 in their grade. In cases where multiple grades were listed in the survey (e.g., GG 1-8), the highest grade was used.

• An employee would be in the NRC office for at least six hours for a PwP day.

• For employees that were greater than 50 miles from the office, a hotel stay would be needed for anyone with more than five hours of roundtrip travel or that requires a flight to get to and from the office.

• PwP days were not conducted back-to-back.

• Average roundtrip airfare was $350

• A privately-owned vehicle was used for travel less than 250 mi les one way.

• When considering whether an em ployee would potentially choose to voluntarily commute to the office at least two days per pay period to maint ain their locality pay, we considered change in annual salary, commuting distance and time, and travel reimbursement. This generally amounted to at least a $10,000 ch ange in salary and/or at least 500-mile roundtrip commuting distance.

These assumptions are conservative and representative of a boun ding value. We acknowledge there could be additional savings depending on specific employe e circumstances.

Based on analysis of the survey data and consideration of exist ing NRC policies, we determined that allowing a fixed schedule of less than two days per pay pe riod, with a minimum of two days per month in-person and PwP activities, would be acceptable for employees that live within 50 miles of their agency worksite, contingent upon policy changes related to local travel. We recommend that the NRC does not reimburse travel expenses to th e assigned NRC office for Column 2 employees that live less than or equal to 50 miles fro m their agency worksite. This would require a policy modification to Management Directive (MD) 14.1, Official Temporary Duty Travel.

56 l P age Requirements associated with local travel are agency-specific, as Federal Travel Regulations do not cover this topic. The NRC currently defines local travel, in part, as travel to points that are not in excess of 35 miles from the official station as dete rmined by standard highway mileage guides. We recommend that the agencys policies associ ated with local travel be modified only as it relates to the proposed hybrid work model. Prior to implementing any recommendation to adjust the fixed work schedules for employees to work in-person from one of the six NRC office locations less than two days per pay period, the agency should implement a change to MD 14.1 Section II, Local Travel at the Official S tation, to clarify that the agency will not cover an employees commuting time and/or any expense associated with travel to/from the alternate work location specified their telework agreement to their assigned official NRC office location. Under current requirements, the employees reg ular place of duty is defined as their official duty station. If the work schedule does not requ ire the employee to spend a minimum of two days per pay period at an NRC official office lo cation, then the alternate work location becomes their official duty station for the purposes o f determining locality pay and eligibility for travel reimbursement.

While MD 14.1,Section II.A.2 states that the government does n ot pay commuting costs, it does allow an employee to be reimbursed for local travel to/from eit her the travelers home or official business site in the performance of official duties. MD 14.1 Se ction II.A.2 is clear about not paying the costs to commute from their home to an official NRC work location but is silent in terms of how to treat reimbursement for time and travel when th e employees home becomes their official duty station. Note that the above recommendation only applies to reimbursement for local travel. Travel expenses (i.e., compensation for time spent in a travel status and the cost travel) for an employee whose alternate work location is g reater than 50 miles from an NRC office must be compensated for by the agency in accordance with applicable Federal Travel Regulations.

The change proposed in this section is viewed as necessary to r esolve any potential ambiguity and provide an explicit position that the agency will not pay t he local travel expenses associated with travel to/from an alternate work location to an employees assigned official NRC office.

Further, the local travel limit for this specific instance woul d extend to less than or equal to 50 miles, versus 35 miles, between the alternate work location and the assigned NRC office facility.

We recommend that the current definition of local travel (less than or equal to 35 miles) be maintained for all other purposes, such as inspection, conferen ce attendance, training, etc.

For employees that are greater than 50 miles from their assigne d NRC office, we determined the adverse impact to the agency of allowing those individuals to maintain a hybrid schedule of less than two days per pay period outweighed the benefits of in creased flexibilities to the employees. The key contributors to this determination are discu ssed below:

• As previously mentioned, employees that are not at their assig ned NRC office at least two days per pay period would be required by OPM to change thei r duty station to their alternative worksite (e.g., home). For employees that are great er than 50 miles from their assigned NRC office, per Federal Travel Regulations, the agency would be required to reimburse those employees for travel to the office for PwP days (i.e., this is official temporary duty travel). Employees in this category can not voluntarily cover the costs because this would put the agency in violation of Federal Travel Regulations.

• Time spent commuting to the office for PwP days would be compe nsable as either special compensatory time for travel or regular hours, dependin g on when the travel occurred. This time would effectively be lost productive time a nd could be significant depending on the location of the alternative worksite. In addit ion to potentially needing

57 l P age to hire additional employees to account for the lost time, this could affect the ability of employees to respond in a timely manner to activities such as r andom drug testing, licensee events, emergent resident site support, etc.

• Based on survey results, travel costs were generally not offset by a change in locality pay. In some cases, employees live in a higher locality than th eir assigned NRC office.

In cases where there is a significant decrease in locality pay, using the assumptions discussed above, we concluded that most employees would likely travel to their assigned NRC office at least two days per pay period to maintai n the higher locality pay.

Considering changes in locality pay, travel expenses, and emplo yee time, we estimate that the expense to the agency to bring employees that live gre ater than 50 miles away into the office two to three days per month is approximately $1.2 - 2 million dollars per year. This number could change in the future depending on the o ther factors discussed here.

• The data shows that additional costs to the agency to implemen t this proposal are significant today for a relatively small population of employee s affected (~150 of 2800) and it is in the best interest of the agency to account for unr ealized/unfunded future costs and liabilities. This could include the potential for emp loyees over time to migrate to areas further than 50 miles from the office or to areas of h igher locality pay, which would result in increased costs to the agency. We recognize tha t future savings in office space may offset some of these costs. However, we estimate that the magnitude of these savings would be relatively small, especially since space consolidation was already in progress prior to the pandemic. Most notably, saving s in office space would take significant time to realize depending on costs and time as sociated with giving up the space (e.g., relocation of critical infrastructure that would r equire significant funds to move), lease requirements, projected hiring, and the need to re structure/reassign space amongst the program offices. Thoug h fewer employees will likely be in the office at any given time, enough space will still be needed for PwP activitie s, especially at the office level. More analysis is needed in this area to further quantify these uncertainties.

• We considered allowing reimbursement of travel expenses for Co lumn 2 employees that were greater than 50 miles and less than or equal to 120 miles from their assigned NRC office. However, based on analysis of the survey results, we de termined that it was not feasible at this point to develop a clear boundary and associat ed criteria for reimbursement that would be both fair to all employees and in t he best interests of the agency. This is an area that could possibly be revisited follow ing analysis of office space savings and the results of the proposed pilot.

Based on these factors, we recommend that employees in Column 2 that live greater than 50 miles from their assigned NRC office be assigned to Column 1 (i.e., minimum of two in-person days per pay period).

Approval authority for Column 2 work schedules would be the res ponsibility of the respective branch chief unless the work schedule would result in cost impl ications for the agency (e.g.,

change in locality pay), in which case we recommend that this d ecision be the responsibility of the respective office director/regional administrator, as they can evaluate overall budget implications, equity considerations, and other factors.

Column 3: Full Remote Worker

Full Remote Worker: A type of teleworker who is not expected to perform work at an agency worksite on a regular or recurring basis.

58 l P age Column 3 covers employees that would be considered full remote workers. These employees would not have a fixed schedule and would only travel to their assigned NRC office as needed.

Because in-person presence is l ess than two days per pay period, employees in this category will not meet OPM requirements for maintaining their assigned NRC office as their duty station, and therefore, locality pay and duty station would be based on the employees alternative worksite (e.g., home). This category is most similar to the cur rent full-time telework program.

Based on the agencys desire to maintain a hybrid telework sche dule, we recommend that this category be maintained as an exception and primarily used as a recruitment and retention tool to maintain critical skills. Approval authority for full remote work would be the associated office director/regional administrator. (Full remote work is discussed in more detail in Enclosure 3).

The survey/financial data table contents internal agency inform ation and is not public available.

59 l P age : Assessing the Effectiveness of the Telework Pilot

Consistent with Management Direc tive 6.9, Performance Management, the working group recognizes the importance of gathering and assessing data to en sure our hybrid work model is achieving the desired outcomes - that is, we are realizing the opportunities and mitigating the risks. This enclosure provides suggestions to assess the effect iveness of the telework pilot.

The first column, Data and Basis describes the specific data and the basis for collecting the data. The second column, Reporting Frequency, describes the f requency for the data collection. The third column, Monitoring Vehicle and Responsib le Entity describes where the data will be captured and the group responsible for analysis an d action. The fourth column, Example Metrics describes metrics tied with the opportunities and the risks associated with the hybrid work model.

Related to specific data collection and analysis efforts captur ed in the following table, the working group also recommends the following:

• Establish a Human Capital Council (HCC) Telework Subcommittee to monitor and assess telework data and metrics.

• Establish Programmatic Senior Assessment Team. risk to capture risk and mitigation plan and report out during Quarterly Performance Review meeting s.

• Create SharePoint site and Telework Dashboard to monitor and c ommunicate telework information. Automate data collection if possible.

• Create a Community of Practice amongst first-line supervisors (Branch Chiefs and Team Leaders) to vent, brainstorm, share best practices, identify re commendations to address common challenges, etc. to support and optimize our hybrid work model.

• Create Telework Pulse Surveys to get real-time feedback from e mployees.

• Procure contractor support as necessary.

• Establish recurring communication to employees on status of te lework pilot (e.g., EDO Updates and Town Halls, Agency Network Announcements, Telework Dashboard).

• Engage internal controls experts to assess pilot program and p rovide insights and recommendations.

TPIWG considered the need for monitoring the impact of the new hybrid work model on external stakeholder interactions during the pilot and decided that a de liberate monitoring mechanism is not required. The proposed changes to telework have minimal eff ect on most of the NRCs interactions with external stakeholders. The NRC should use exi sting mechanisms (external working group interactions, public meeting feedback, etc.) to g ain insight as needed.

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Listening Session and Employee Feedback Summary

Listening Sessions with the Telework Policy and Implementation Working Group Summary - September 2022

The TPIWG conducted four agencywide listening sessions to provi de employees the opportunity to share their insights and perspectives on the current telewor k policy, considerations for enhancements, and how/when to best leverage in-person and virtu al interactions. The first two sessions were conducted in a hybrid format, offering employees to attend in-person or virtually on Microsoft Teams, while the final two sessions were held virt ually.

Following the initial agencywide sessions, the TPIWG determined it was necessary to conduct an additional virtual listening session dedicated to supervisor s. While the session was intended for first-line supervisors to provide their perspectives, senio r managers were also invited to participate and share their feedback.

The intent of the sessions was for TPIWG members to listen to e mployee perspectives, without responding to questions or comments being shared. All sessions were conducted using a similar format and were not recorded. Sessions were facilitated by NRC trained facilitators who opened the session and established ground rules. Facilitators t hen turned over the discussion to TPIWG who provided opening remarks sharing an overview of th e TPIWG purpose and charter objectives, key messages on the tasking, and questions to prompt discussion. The facilitators then began the listening session and opened the fl oor for employees to share their feedback. Session notes were taken by NRC staff volunteers and chat discussions in Teams were captured.

The following standard set of questions were shared by TPIWG; h owever, employees were encouraged to share additional insights as they determined appr opriate.

• Given that we are committed to a hybrid work environment, what sorts of activities do you think are most effectively done in-person, in the office? W hat is better done virtually? How do we best leverage both types of interactions?

• What is your view on the amount of in-person, in-office engage ment needed to sustain a healthy organizational culture and develop our people? What is the right balance between in-office and virtual presence?

• How can we best use a hybrid environment to help our new staff understand our culture and feel like they are a part of the team?

• What are your concerns about the existing FTTW policy in gener al? What would you do differently? How would you evaluate whether a FTTW request s hould be granted?

Do you see a difference between local FTTW and remote FTTW?

• What haven't we asked that you would like to share?

65 l P age Listening Session Participation

The TPIWG held four employee listening sessions. Two of the ses sions were held in a hybrid format where TPIWG attended in-person, and two were held virtua lly. A total of 1,057 employees (unique) attended the listening sessions and 63 emplo yees provided comments verbally. There were several employees that attended multiple s essions; therefore, a higher number of participants is indicated in the chart below. Further more, TPIWG held one virtual listening session for supervisors. A total of 312 participated in supervisor listening session and 22 supervisors provided comments verbally.

Session Date/Time Virtual In-Person Verbal Attendance Attendance Commenters

Employee - Thursday, August 25, 2022 404 employees 2 employees 18 Hybrid 9:30-11:30 am ET Employee - Thursday, August 25, 2022 364 employees 1 employee 21 Hybrid 1:30-3:30 pm ET Employee - Tuesday, August 30, 2022 Virtual 2:00-3:00 pm ET 496 employees n/a 13 Employee - Wednesday, August 31, 2022 Virtual 10:00-11:00 am ET 411 employees n/a 11 Total 1,675 3 participants 63 comments participated (unique) provided (not (1,054 unique unique) participants)

Supervisors - Wednesday August 31, 2022 312 participants n/a 22 Virtual 1:30-3:00 pm ET commenters (unique)

Summary of Employee Listening Session Feedback

The purpose of this summary is to highlight common themes based on feedback and ideas shared throughout the listening sessions and provide suggestion s for the TPIWG consideration for enhancing NRCs telework policy and implementation.

Considerations for In-Person, In-Office Presence

Generally, employees strongly felt that in-person presence need s to be intentional and purposeful. Employees shared thoughts on activities where they felt were most effectively done in-person or in-office, as well as shared challenges with curre nt in-person interactions.

When In-Person Presence is Most Effective:

• Onboarding new staff (meet

• Public meetings team/branch)

• Technical Training Center Training

• Knowledge transfer activities

• Conferences

• Inspections

• Briefing senior management

• Audits

• Meeting with external stakeholders

• Counterpart meetings

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• Reviewing and handling classified

• Hearings Brainstorming meetings for work/materials strategic plans

• All Hands Meetings (when intent is

• Making decisions to introduce new commissioner/new

• Charting new paths sr. management)

• Social connections

• Headquarters Operation Officer

Challenges with Current In-Person Interactions:

• Spontaneous interactions as intended by the current policy are not taking place

• Noise is an issue and distraction while in the office with oth er employees taking virtual meetings from their office.

• Being in-person is more of a hassle and a distraction; employe e finding they need to go home to get work done.

• Quality of MS Teams connectivity and network connection is wor se in the office than at home

• NRC mission is to do the work and not just come into the offic e to socialize

• Employee shared there is not a need to come into the office wh en they are doing online training

Considerations for Virtual Presence

Generally, employees provided feedback on virtual interactions based on the benefits of working virtually. When sharing thoughts on what is most effectively do ne virtually, employees felt most engagements are and can be accomplished successfully and effect ively in a virtual environment, especially given the technology tools. Additionall y, employees shared challenges being experienced when working virtually.

Benefits of Virtual Presence:

• Nocommuting

• Water cooler has changed - it is

• More productive at home Teams now

• Provides opportunity for rotations

• Mentoring outside permanent office/duty station

• Collaboration on work documents (ex. regional employee rotation to

• Teams meetings are a tremendous headquarters) help in improving total interaction for

• More inclusion now that employees person who has hearing disability are using available technology

• Enormous improvement in

• Use of technology to connect with collaboration between the regional people and build relationships staff and HQ staff

• Online training from home

• Life/work balance

• Ability to have social virtual meetings

Challenges with Working Virtually:

• Unable to print at home

• People are not using their camera

Organizational Culture and Health

Employees shared general comments around the NRCs organization al culture, particularly noting that the culture at the NRC has changed since COVID and there is a need for change.

67 l P age Participants shared that the new NRC culture needs to be more f orward leaning in an innovative way and embrace more telework because in-person presence is not necessary to maintain organizational culture. It was suggested that the agency consid er activities to improve the culture and that morale is going to be an issue if the agency c ontinues to force staff to come into the office. Additional concern was shared that a threat to the NRC culture is the workload and being overscheduled and the endless dr ive to do everything fast er.

We can either move backwards or forwards from here - I know it s a massive cultural shift for managers that remember the vibrant culture from pre-p andemic. It has changed and it is never coming back. We need the best and brightest - i ndustry is already saying we cant keep up. We have mid-career people that are leaving fo r FTTW and promotions elsewhere. We need to make this shift and it will be hard - peo ple wont like it, but it needs to happen.

Being a person that is new to agency and joined during pandemi c, the culture was very happy as they were teleworking. Culture has changed significant ly.

Additionally, employees shared concerns related to broken trust between staff and management. It was shared that staff do not feel supported and trusted that they are doing their jobs while working in a virtual environment, nor that they are able to navigate working relationships on their own. It was expressed that trust has bee n eroded since re-entry, as agency leaders praised workers throughout the pandemic for bein g able to meet the mission and being productive, however are now being told that we need t o be in the office and remote work is being retracted. Participants expressed that they did n ot have confidence that changes will be made, and staff feel that they are not being heard. A f ear was shared that management will push for more in-person meetings to justify the need to be in the office.

Employees spoke about COVID and health concerns. They shared th at COVID is still here, and that the virus still informs many employees decisions about whe ther to come into the office. It was suggested that the agency consider max flexibilities when a facility is in HIGH transmission. Concerns were also shared related to re-entry and decision being made before child vaccines were made available and the impact that personal ly caused.

Telework Policy: General Comments and Impacts of Current Policy

Generally, employees shared perspectives that the current telew ork policy lacks clarity and transparency, fairness, and is inconsistent. More specifically:

• Inequity in the telework approval process is very apparent and causing low morale.

• Telework policy is arbitrary and capricious.

• Inconsistency and not a standardized policy across the agency that accounts for onsite time as in-office.

• Lack of transparency, clarity, consistency, and decision-makin g speed. Unclear what the current agency policy actually is, how decisions are being made, the rationale for why decisions are being made, and final decisions can take many mon ths, which leaves the employee in limbo/high levels of uncertainty.

In addition, several employees shared perspectives on the impac ts the agency is experiencing as a result of the current policy and its implementation, speci fically related to recruitment and retention, growth, and development, and acclimating new employe es.

68 l P age Recruitment and Retention

• Losing key staff from earlier-than-planned retirements and lat erals to other agencies because we have limited full-time remote telework.

• People are not applying for jobs due to lack of remote options, losing potential qualified staff.

• NRC cannot compete with external organizations offering remote positions

• People cannot afford to live in DMV area and do not apply or h ave left NRC

• Federal government pay is around 23% lower than private sector

Growth and Development

• Promotion announcements may not be receiving the best/most qua lified applicant pool when a physical move is required to HQ or another geographic re gion.

• Current telework policy deters employees from applying for pro motions. Promotion opportunities for remote workers are not available. Remote work ers lose the risk of their agreements not getting approved and the agency risks not gettin g qualified individual for a job. This is limiting the pool of candidates and it is unfair ly punishing those of us that are full-time telework

• Lack of willingness to promote remote employees just because t hey were not at an NRC facility

Acclimating New Employees:

Differing perspectives were shared on acclimating new employees, from employees who have been at the agency and those who identified themselves as new e mployees. Some employees shared concerns that it was more difficult in a hybrid environm ent to get acclimated into the culture and to meet people, while others shared that they have been able to connect and build relationships in a virtual environment.

• New staff we are hiring that they may not get the interaction, get that experience, and culture that we all gained over the years of in-office interact ion

• Shared concern about how to pass on the institutional knowledg e to new hires

• As new person, I had a hard time connecting with people onlin e. Its a challenge to connect with people. First you have to build relationships to m aintain them.

• "All those previous in-office interactions" that organically h appened in the pre-pandemic workplace cannot be artificially regenerated under the new real ities. We cannot artificially recreate the past. We need to figure out a path fo rward given the new realities.

• Rather than assuming telework will hamper new employee develop ment, the agency could make it our goal to develop a best-in-class virtual onboa rding process.

• Staff shared perspectives, as a new employee, they were able t o manage building relationships, onboard, meet teammates virtually and did not ex perience issues or share the same concerns being expressed.

Considerations for Telework Policy Changes:

General Comments:

• Discourage TPIWG from doing top-down one-size-fits-all approach.

• Decisions need to be transparent

• Eliminate big broad, wordy processes, etc. Make general agency guidance.

• Allow staff to come into the office voluntarily

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• Consider how allowing telework opens opportunities for staff i n geographically different locations promote or work for organizations in other locations.

• If someone isnt meeting performance on telework, should do pe rformance management, not bring them back into office. Performance-based work vs. manager needs to see you to know you are working.

• Difficult to find and retain contractors who also have to come into the office. Many contractors also want to work remotely, and since there are man y contracting positions out there, it is very difficult to find one willing to come int o the office.

Clarification on Telework Policy Terminology:

• Define what is meant by in-office. There needs to be a disti nction between in-office and in-person. Example, if an employee is on travel for work, the i ndividual doesnt click the Telework box, so is this really in-office or not? Leave, holida ys, and travel are considered "in-office" days. (how to document in HRMS and does that count as your in-office day)

• Clearly define terms locality and duty station - differences, impacts etc.

• Define remote vs telework and the differences. Be careful usin g the word "remote" regarding what I assume to mean "non-local." "Remote" is a defi ned term by OPM.

which is defined as "an employee who doesn't report to their no rmal duty station at least twice per pay period." So, what we refer to as "FTTW" OPM refer s to as "remote."

• Change the mindset that "in-person" interactions do NOT includ e phone calls, Teams meetings, etc. Teams chat might feel impersonal, but its still counts as in-person real-time communication.

Enhancements to Telework Process:

• Create templates, ensure they are legally accurate

• Look at the paperwork we are using - improvements can be made; remove redundancy.

Make it a more streamlined process.

• Have a one-stop SharePoint on what telework "per agency policy " means. There are so many sources of information including the CBA and several EDO/C ommission memos on specific topics such as improving the Resident Inspection pr ogram. It is not clear what "per agency policy" means in USA jobs postings.

• Consider having a telework coordinator in each office - this w ill help with preparation of documents, routing, etc.

• Suggestion of creating an appeal process when the employee and supervisor dont agree.

• Guard against preference biases. Sometimes decisions are based on individual preferences. For example, some people are social and would lean towards having everyone in the office.

Signature Authority:

• Signature authority down to the lowest level. Empower supervis ors to make the decisions. Allow first-line supervisors to determine what work is portable, manage interactions, working with their team. They know their staff be st.

• OCHCO should not be approving telework at all - only informed for duty station changes, etc.

Policy Ideas:

• Identify what work is portable to determine work sc hedule

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• 1 -3 days per month mandatory in-office for 4-6 hours of engag ement that would be a good transition and allow more staff telework flexibility.

• Provide incentives for people to come into the office (ex. 10 months local, 2 months from anywhere); better offices (larger, door, window), not by senior ity.

• We need to have a better list of purposes/goals for in-office work. We cannot measure success if we do not have a yardstick to measure against. For r esidents, we have a clear list of tasks and expectations when we go into the site; we also have different list of tasks/expectations when we go into the regional office.

• Need to look at resident inspector (RI) policy. At this time, RIs are only authorized telework up to 8 hrs. per week unless there is a documented nee d for more. The resident program is already struggling with recruitment and ret ention, and I foresee the telework limitations to be a sticking point for program growth/ sustainability.

Full-Time Telework

Considerations for Full-Time Telework (i.e., Remote)

• Consider Full-Time Telework (FTTW) option within the commuting area

• Revise FTTW annual renewal process.

o Change of policy has become stressful due to the new annual re newal of telework agreements.

o Uncertainty of not knowing the agreement will be renewed on an annual basis, causes stress and anxiety.

o Should not have an expiration date.

o Revise justification that training a replacement is needed

• There has been some talk about hiring staff on full-time telew ork, but caution NRC as it would cause major culture issues if not offered to current staf f.

• Use of new employees to justify not offering FTTW is a flims y excuse. (new employees who joined during the pandemic felt they were able to meet team mates and build relationships through use of technology i.e., Teams).

• Bar is too high for approval of FTTW. Seems to be done arbitra rily at this point. We need to be more open to approving FTTW.

• There is no difference between local and remote FTTW.

• Turn it around and ask why management shouldnt grant FTTW.

• Everyone should be able to do FTTW unless their work cannot be done remotely.

• I have heard from others that may be explored more (may take OPM transformational thinking if not already allowed within current regulations or r eally thinking outside the box at least if not legally prohibited) would be the possibility of allowing a person to be pay to be based on the requirement for that individual to live in a sp ecific locality (like DC area, Chicago, etc..), the person could live anywhere and work for th e agency therefore they would be free to live anywhere even the less expensive areas of the US. If a person were to choose to live in San Francisco, that would be their ch oice and ok, but the agency would not have a need for them to live there, therefore, not responsible for paying them at that locality. This could also help offset any t ravel expenses needed for that person to travel to in-person work when needed.

Benefits Shared on FTTW:

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• Telework (TW)/FTTW creates opportunities for NRC staff to comp ete for, rotate in, work in, and promote into offices not geographically co-located. Con sequently, this allows the NRC to tap into knowledge, skills, abilities, and potential in staff not geographically co-located.

• TW/FTTW affords the staff the ability to rapidly transition to work in the morning and to their personal lives at the end of the day. There are positive contributions to morale and mental health.

• TW/FTTW positively contributes to the Administrations goal of environmental justice.

There is an inherent reduction in the number of vehicles on the road and sitting in traffic.

There is also an inherent reduction in the reliance on fossil f uels.

• TW/FTTW reduces the federal governments reliance on contractu al real estate.

• More broadly accepting full-time telework at the agency could allow for a larger population of individuals to apply for jobs at the NRC and ther efore expand the agencys application pool to a more diverse population. Commuting can be an economic barrier for individuals with lower incomes, or a barrier for individual s with disabilities.

• Expanding FTTW could allow individuals to live in different pa rts of the country, which could allow for individuals to live in an area where they are p aid less, that has a lower cost of living, and therefore provides greater dispersion of ec onomic resources throughout the country.

Additional Suggestions for Agency Consideration

Technology

• Portability has nothing to do with the type of information tha t can be accessed remotely.

Ex. DOD has moved to software that allows people to work on sen sitive information remotely. NRC does not have the technology in place to facilita te portable work - i.e.,

there are software solutions to allow work on sensitive informa tion in a remote environment. Suggestion: adopt software solutions that allows w ork on classified and Safeguards Information (SGI) remotely. Use software separation instead of just hardware fixes.

• Ensure agency can handle bandwidth if moving to more FTTW.

• Policies around using Teams and the Chat function

Considerations That May Influence Telework Policy C hanges:

• Office Space:

o Our mission talks about protecting the environment and telewor king will reduce carbon emissions and be a smaller footprint.

o Expanding full-time telework could also allow for a reduction in the amount of commercial office space, saving economic resources and allowing those economic resources to be put to a more productive use. Those of fice buildings could be converted to housing, which is currently in great dema nd and often perceived as too expensive. Conver ting office space to resident ial space

• Increase travel budget for meaningful interactions

• Additional resources in OCHCO to support telework duties - cur rently one person who has multiple duties in additional to managing the entire agency s telework program.

• Need to pay attention to ergonomics, look at the needs of thos e teleworking

• Federal Laws associated with to encourage telework as it: Redu ces pollution from cars, reduces impacts to roads, bridges, etc..., increases diversity, reduces costs to federal agencies by reducing the building usage and associated support resources and reduces

72 l P age impacts of localized natural or artificial disasters. Congress has pushed this idea as it is important to the country as a whole.

• Think of the fall-out from an all-out, FTTW situation. Many re staurants, shops, merchants, etc., that depend on workers being in the office wou ld go out of business thus contributing to the unemployment rate.

Additional Comments:

• Ask that the TPIWG show us and strongly communicate what we ca n do to make sure we are being heard

• Need strong leadership to make the policy work

• Telework is a privilege and not an entitlement

• Commitment from all employees about being intentional with bui lding relationships whether that is in-person or virtual.

• If the agency does believe in-person is valuable in building t he community, then the agency needs to make people want to come into the office.

• Management has asked us to transform majorly in the recent pas t - staff is asking management to do the same related to FTTW.

Summary of Supervisor Listening Session

The purpose of this summary is to highlight common themes based on feedback and ideas shared throughout the supervisor listening session and provide suggestions for the TPIWG consideration for enhancing NRCs telework policy and implement ation.

Considerations for In-Person, In-Office, and Virtual Presence

Generally, supervisors shared that the agency needs to be innov ative and intentional about how we make meaningful connections with our colleagues - both virtu ally and in-person.

We dont need to focus on how much in-person is necessary to s ustain culture and instead need to think about all ways to advance our people and culture.

Max choice coupled with purposeful interactions to give people a reason to get together.

The water cooler is not the water cooler anymore.

In-Person, In-Office Presence:

• Team building activities

• Coaching

• Branch meetings (Benefit to in-person if there is a critical m ass)

• Presence with a purpose; intentional moments

• Brainstorming

• Seeing body language

• Initial training for new employees, hands-on training such as simulator refresher training

• Inspection of licensee activities ex. Training (TTC)

• Quick questions - to get immediate res ponse

• Public meetings

• Audits

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• Knowledge transfer activities

• Regional Counterpart meetings

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• Most regions have "seminars" twice a year in which staff gathe r to socialize, discuss pertinent topics, and build relationships.

• Initial onboarding of a new employee

• Difficult conversations

• Social interactions - occasionally meeting for lunch

Virtual:

• Brainstorming can be very effective virtually if you have all of the right tools to conduct a digital brainstorming session, and most importantly, if all of the impacted individuals know how to utilize any of the digital tools (Whiteboard & Clic k-Up) that may be used. If not, then an in-person session with paper and pen or mind-mappi ng would be just as effective as well.

• Virtual training, being able to take it at home vs. coming into the office

• Most interactions can take place virtually

Telework Policy: General Comments and Impacts of Current Policy

Generally, comments were shared about existing policy challenge s and concerns including inconsistency with requirements, decisions, implementation and guidance

• Based on the last 2 years, everyone coming into the office is easy, everyone working virtually is easy, but trying to do this hybrid thing is diffic ult.

• Inconsistency with requirements for RI across the agency

• Not enough flexibility and not enough trust.

• Local FTTW verses remote FTTW was a mistake when the new polic y changed.

Leverage the ability for the regional staff to work at HQ is im portant.

• No one-size-fits-all approach

• One of the biggest problems we saw as consistency across the b oard for decisions made. We need to make sure that we are consistent otherwise it s not going to work.

• The hybrid work environment has only been partially implemented - and that is mostly the "positive" part. All of my employees are work-at-home 60% b ut they all still have offices. We are trying to hire new people but now have no offic es available. We don't have clear policies on limitations and penalties, so (as an exa mple) people seem to think they can take an extra WAH day when they schedule a medical app ointment because they don't feel it is worth it to drive to work for the rest of the day. Or they feel they can work only 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at work and 3-4 hours at home in one day beca use the rules are vague. Work hours have also gotten blurred, and some people are virtually working and taking more of a first 40 attitude rather than following a fixe d schedule. Please build the rest of the policy.

• OCHCO should not have ability to deny FTTW approved by the off ice director or regional administrator.

• I'm really struggling with the idea that people are "entitled" to telework. Why should we have to incentivize people to com e into the office? We already to - it's called a paycheck.

• Its not entitlement, its a benefit and we need that benefit in order to compete for employees against other job options.

Comments were shared about concerns with recruitment and retent ion; broken trust; acclimating new hires; low morale and engagement; COVID still e xists.

75 l P age Recruitment and Retention

• Unable hire due to telework policy.

• Todays kids expect to work from home in front of the computer. I want our agency to be able to recruit people. Hope you take the actions that will sat isfy staff. Were going to lose good people and we cant fill the spots

• We may NEED to be more FTTW friendly now to compete, but we ma y very well have to revisit that decision later as the landscape changes.

• The reality is that many midcareer employees are leaving for f ull-time work at home positions in other govt agencies or other companies-we need to get smart about retention and a better use of full-time telework needs to be pa rt of that retention

Culture:

• What I havent heard is our culture in general. We are a regul atory agency that is apolitical. We want the agency out of the news. The culture has permeated down of risk aversion. Weve always done what we were told to do. We are alw ays the first or second to come into compliance. Interesting enough with Bidens decision to come into the office mandate we were the first too. The world has changed but the world doesnt know what weve changed to? DOE, SEC, etc., etc. didnt have pe ople coming in. The pandemic just accelerated what was already happening with peopl e already going remote.

• NRCs senior leadership needs to accept that the landscape of work, work-life and workplace has fundamentally changed forever.

• Employees need to feel that they are receiving at least an equ itable return on their investment of going into the office. Otherwise, there will cont inue to be low morale and disengagement.

Broken Trust:

• The agency's culture was damaged after the decision to re-entr y during the pandemic.

We continue to hear the common theme of telework policies affec ting the perception everyone has of the NRC and the potential effect on our ability to fulfill our safety mission. Please consider allowing greater flexibilities for ful l-time telework as proposed in this meeting. It will demonstrate the agency's openness to b ecome a modern regulator.

• Distrust is the leading indicator (we are seeing that in this and the employee session) that I believe will be followed by an increase in retirements a nd loss of new/mid-term employees (lagging indicator)

• Arbitrary days in the office when an organization is telework ready conveys an immediate reflection of distrust in staff.

• If we want staff to come into the office, then we should ensur e that we have an office worth coming to. I dont think we can have the appetite or abil ity to do that. We dont even have a cafeteria. Moreover, were modifying the facility i n an unpopular way. Decisions like these have destroyed trust in the organization.

• Employees and their direct supervisors should be trusted to wo rk collaboratively to determine when and where to work that makes the most sense for the mission, their work units, their stakeholders, and themselves.

Acclimating New Employees:

• Concern with an expansion of TW as an agency is new employee d evelopment...... this is something that first-line supervisors are going to need to be d eliberate about addressing (and that may mean Teleworking staff need to come in more often)

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• I am worried about all the new staff we are hiring that they m ay not get the interaction, get that experience, and culture that we all gained over the ye ars of in-office interaction... how are all the new staff going to get that. We can say that teams will allow that, but it does not in my experience. We still need some in-p erson interaction.

• Having people in the office to help train all the new employee s is important. it gives purpose and builds culture. my new staff felt disconnected in t he virtual environment.

COVID

• Staff are not willing to come into the office on the same day to do team building because of not wanting to get COVID

Supporting In-Office Workers:

• How should the agency support folks who want/need to work in t he office? Specifically, if someone wants to work in the office and all the people the w ant/need to work with are teleworking, it seems we are not support folks working in-offic e.

Considerations for Telework Policy Changes:

General Comments:

• We need to get away from the hybrid, we can determine what eac h branch can do virtually and then if everyone wants it, they can.

• The decision and re-entry was a catastrophic failure of our le adership so Im concerned about how the staff with buy in to this next stage.

• The opportunity to that telework can provide to rotations.

• Want to point out that staff has an overall negative perceptio n of hybrid. That language can be inflammatory. As the working group comes up with changes, a rebranding of the negative connotation of hybrid.

• Instead of identifying what specific in-office days we have, I would suggest that we just identify how many days we are going to do in-person days per pa y period and that way we can be flexible that way we can flex with what is going on w ith meetings and needs for in-office work.

Signature Authority:

• Strong agreement that first-line supervisors are in the best p osition to make decisions on staff work schedules and presence with a purpose.

• Delegating approval authority down to the lowest level.

• All telework approvals should remain within the office.

• Need clearer guidance on exceptions, implementation, etc. I am open to letting the 1st line supervisors make the decision but am afraid that if there are no guidelines in policy then it might put them in a difficult position for those employ ees who have a strong opinion.

• The BC are in the best position to make the decision, but thin gs will change, and this will need to be revisited as things recycle.

• Managers should be given the decision-making for telework beca use they know what their employees' responsibilities are. Telework is a case-by-ca se thing, where we should be flexible.

• Supervisors having the discretion of deciding whether a positi on is full-time telework or not. I believe people would be surprised by how many supervisor s would be open to making a positions FTTW if it meant keeping high performers and /or recruiting great staff.

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• CAUTION - the danger with allowing a front-line supervisor to decide on FTTW is what to do if a new supervisor shows up and disagrees, or the staff member changes jobs -

unless we make those initial decision permanent as long as work is portable.

Process:

• Simplify the telework forms and process

• Need agency high level guidance that we can apply to the varie d work environments across the Offices.

• Working hours - suggest having core hours/traditional hours so business done at a reasonable time rather than waiting till the next day.

• Full employee choice. Let staff decide when or if to come in o n a regular basis and make FTTW available as a recruiting tool. Couple that with peri odic in-person interactions "with a purpose" 3-4 times a year.

• Let the needed activities (team building, training, public mee tings, etc.) drive when people "should" come into the office and then find ways to incentivize people to come in, encourage supervisors to use the activities to encourage people to come in for the activities that make sense, help with the culture, etc.

FTTW (Remote):

• Simplify the process to requesting FTTW.

• The impetus for the comment is based on an inconsistency of th e implementation of the current telework program. If the concept of telework is divided between local and non-local is such a strange thing. If you are going to ask folks to come into the office, the local folks will bear the cost, but if an employee with an agre ement to telework 900 miles away is asked to come into the office, who pays that expense? T he agency or the employee? Is the new policy going to be that there will not be a recoup of that cost?

Just make the policy consistent and impartial.

Additional Suggestions for Agency Consideration

Office Space:

• Suggest reducing footprint and offer agency employees come in on certain days (Tues, Wed, Thurs.)

• Reducing footprint, may be able to hire more people with the s avings.

• Need to consider our space policy with telework policy. Propos als that if <2 days/week, people would not be entitled to an office.

• As part of revising our FTTW policy, we should consider re-eva luating whether regional offices should be consolidated.

• Office design, amenities, culture can/should attract personnel to desire to come to the office... making people do what they don't want to do is bad, o ffering a great environment that enriches their life and work is good

• Really would like it if any updated telework policy also defin e what it means as far as in-office space that folks will have or use.

Engagement Suggestions for TPIWG:

• Conduct small groups where we can help do develop the policy.

• Lets have another listening session about what does the agenc y want to be. What do we want to use our office space for?

• The agency should look at the resident program as a 40 year "r emote work" program.

How do they stay engaged and develop culture then they are sepa rate from their bosses

78 l P age and colleague by long distances? Although every region (and bra nch) may be different, they have common tools such as Temporary Duty (TDY) travel at a frequency that supports collaboration. Counterpart meetings allow RIs to meet regional staff, objectivity visit requirements allow RIs focused time with other RIs. As IT tools have evolved, residents collaborate more with branch staff and other resident s virtually. The key is the expectation to collaborate virtually and defined in-person meet ings with the expectation to travel.

• Has TPIWG reached out to the resident inspector recruitment wo rking group to determine a telework solution for resident inspectors? At this time, we are only authorized telework up to 8 hrs. per week unless there is a doc umented need for more.

The resident program is already struggling with recruitment and retention, and I foresee the telework limitations to be a sticking point for program gro wth/sustainability.

Summary of Insights from Employee Feedback via Email and Open Door

In addition to insights and feedback shared directly during the listening sessions, the TPIWG obtained feedback from 26 employees via email or during open do or. Below is a summary of the feedback shared.

General Comments

• Transparency, consistency, equity in granting FTTW.

o Multiple comments related to the training your replacement/su ccession strategy language in the current FTTW policy (e.g., What is the purpose of this requirement, and what happens to me after my replacement is tra ined?)

o Once FTTW is approved, what is the basis for denying FTTW to o thers in a similar role?

• Transparency, consistency, and equity in telework

• We were successful in implementing FTTW during the pandemic. W hy cant we do it now? (reasons include better productivity, no commute time, COV ID safety, work-life balance, cost savings, reducing carbon footprint, etc.)

• Recruitment and retention concerns.

o Make an easy path for FTTW for rotations.

o Being able to pick the best-qualified candidate even if they a re remote

• Concerns regarding the reluctancy for FTTW employees to apply for other jobs because it is unclear whether they will be able to retain FTTW

• PwP (return on investment of going into the office)

• Improve/modernize the telework paperwork process

• Decisions regarding telework should be at lowest possible leve l (e.g., branch chief; regional administrators/office directors for FTTW)

• Onboarding should be performed in-person.

Other Items for Consideration

Incentivization. Consider incentives for those who would not be able to take advantage of liberal telework policies by the nature of their jobs and for s taff that would rather work in the office (e.g., offer private offices or higher priority in choos ing office space)

Use job functions/position descriptions. Create classes of po sitions or functions that are eligible for FTTW. Utilize the position description to determin e what work can be done remotely and what needs to be in-person.

79 l P age Comments on In-Person Presence.

• Some examples where new employees did not feel involved with t he agency while staff were remote.

• Fully remote work leads to most interactions being transaction al in nature, which leads to a decline in culture.

• Seeing coworkers in-person creates a closer personal relations hip

Implementation Items

• Consider developing a process for when the supervisor and empl oyee disagree on a telework schedule.

• Notification timeline for employees on FTTW (e.g., 2-hour adva nced notice for local-remote and 48-hour advanced notice for remote-remote)

• There are mixed feelings on camera usage.

• Provide training to those not used to teleworking or working i n a hybrid environment

• Consider providing examples where it would be appropriate for a branch chief to revisit/cancel a FTTW agreement (e.g., shift in policy)

Potential Ideas to Help Supervisors

• Regular weekly or biweekly meetings with a senior staff branch member for knowledge management and to discuss challeng es with the employees projec ts

• Branch Chat on Teams where staff can feel encourage to drop a message to ask questions or request thoughts.

• Devote some branch meeting time so that, instead of staff prov iding personal work status updates, staff generate discussion to get insights on 2 or 3 challenges the branch is facing. These can be incredibly valuable and are better than getting feedback one-on-one as people feed off each others ideas.

• Devote some branch meeting time for staff to share personal li fe updates such as weekend activities. Patrice Reid would use a system called the 4 Hs. This could be done around once a month.

• Short biweekly meetings with branch chief to get status update s on work

Thoughts Staff New to NRC

• Culture Team has many resources describing the desired culture. Division or branch management should share these resources and behavioral expectat ions.

• New staff member can send email introducing self to branch. Th ere should also be a division wide communication welcoming the new staff member.

• Pair new employees with a staff member who can share the same in-person days (maybe even from a different office/branch to increase the pool of people).

• New employees shouldnt have to come into the office more than anyone else ONLY because they are new (consider in-person activities that are oc curring, such as licensee site visits, TTC training, etc.).

• Consider a probationary period until new staff demonstrate the y can FTTW effectively.

Insights from EDO Town Hall Information

TPIWG reviewed approximately 110 comments that were related to telework (and most comments had multiple likes) from meetings held between Febru ary 2021 and July 2022.

80 l P age General Comments:

• Transparency, consistency, equity in granting FTTW. This inclu des providing the definition of rare with regards to FTTW approval. There were also multiple comments suggesting that management provide specific information to staf f re: how many employees are currently on FTTW.

• Employees should all be FTTW since we were successful during t he public health emergency (reasons include better productivity, no commute time, COVID safety, work-life balance, cost savings, reducing carbon footprint, etc.)

• Recruitment and retention concerns

• Transparency, consistency, and equity in telework (e.g., some offices had to return, and others did not; some staff were asked to return even though the ir office directors did not; other agencies have more liberal telework policies than we do; etc.)

• PwP

Other Items for Consideration:

COVID Concerns. Though our policy is written based on the assum ption that it is meant to be applicable long-term, COVID is still a concern amongst staff, a s demonstrated in the comments.

This will likely be a question in future roll-out meetings that will need to be answered. This could also be a consideration for information/tools that will need to be provided to supervisors during the pilot (i.e., what to do for staff who fall into this catego ry).

• Response provided in the Town Hall Notes: Our special circumstances telework policy provides a process for employees to request telework for a relatively short period of time due to a personal incapacitation or personal hardship and is approved on a case-by-case basis. Decisions for initial special circumstance requests lie with the office directors and regional administrators. Employees should discuss their concerns with their supervisor, division management, or office director.

Amenities. There were several questions related to the availabi lity of amenities such as the HQ cafeteria, gym, etc.

Work Schedules vs. In-Office Days. Would there be any differenc es to the policy for an employee that works a 4-10 schedule or a compressed schedule (i.e., more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in a day?).

Risk Assessment. There were several comments related to whether a risk assessment was conducted to support the current telework policy.

Concerns with Telework. There were multiple comments (with mult iple likes) related to more telework not being good for the agency because of staff being m ore siloed; more negative association with employment; learning more in-office than on Te ams; failure to create community for new employees due to lack of in-person events, et c. There was also concern about speaking up against the tide.

Why Hybrid? This is the response provided in the Town Hall note s for consideration in the event we need to add this as a talking point with staff (consis tency in messaging).

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• At the outset of the NRCs maximum telework in response to the COVID-19 pandemic, agency leadership clearly communicated that the maximum telework posture was temporary.

• As indicated by several surveys weve conducted, most of our staff want a hybrid working model with some telework and some time in our buildings.

• Our model will also strive for all employees to have some in-person interactions. Our experiences over the last 16 months have shown our ability to adapt to working outside of our traditional settings and processes while reminding us of the importance of in-person interactions.

• Our success during the pandemics virtual environment is likely due, in part, to our leveraging of strong relationships and partnerships that we developed through in-person interactions.

• Based on feedback (from staff, affinity groups, and new employees), our assessment of scholarly works, and the best judgement of NRC leaders, the long-term benefits of having some face-to-face interactions has enhanced our ability to achieve our mission and we want to continue, after full re-entry, to have those benefits.

• We will continue to acknowledge that we have demonstrated much success working almost entirely virtually, but the nearly all-virtual environment will end at full re-entry in light of the important benefits we want to continue to derive from in-person interactions.

• We appreciate the staffs professionalism and continued focus on the NRCs mission as we move forward with re-entry.

82 l P age : TPIWG Selected List of Key References

Doane,M. (2021, July 28). Message from the EDO - Important Upda tes on Agency Re-Entry Plan, Implementation, and Announcement of Full Re-Entry Date.

Kidson, A. (2022, September 20). The Changing Experience of Cul ture in a Hybrid Work World

[Webinar]. Gartner Inc.

Government Executive: Preparing for Re-entry into the Physical Workplace: Lessons from NASA

Gratton, L. (May-June 2021). How to do Hybrid Right. Harvard Bu siness Review

NRC Culture Team: Considerations for Face-to-Face and Remote Wo rk in a Hybrid Environment

NRC Culture Team: Considerations for Camera Use in a Hybrid Wor k Environment

NRC Culture Team: Employee Resources for Working in a Hybrid Wo rk Environment

NRC Culture Team: Best Practices for Hybrid Meetings

NRC Culture Team: Hybrid Work Insights

NRC Culture Team: Meeting Facilitation Tool

NRC Culture Team: NRC Hybrid Environment Assessment and Review Team Report (ML22271A894)

NRC - Hybrid Work Environment Lessons Learned and Other Resourc es (Nuclepedia Article)

NRC White Paper - Considerations for Face-to-Face and Remote Wo rk in a Hybrid Environment

Region I - Distributed Work as a Team (Top 10 Tips)

Telework Policy and Implementation Working Group Charter, dated July 14, 2022

Policy Documents:

NRC:

• OCHCO Telework Website Resource: https://intranet.nrc.gov/ochco/catalog/317

• MD 10.166, "Telework"

• Collective Bargaining Agreement

• Telework Glossary

• Re-Entry Guidance (Memo)

• Re-Entry Information from OCHCO (PPT)

• Resident Inspector Telework Guidance

83 l P age External Guidance:

• 5 CFR § 531.605 - Determining an employee's official worksite.

• Fact Sheet: Official Worksite for Location-Based Pay Purposes

• A Guide to Telework in the Federal Government

• Telework.gov - the official website of the Federal Government's telework pro gram

• Telework Overview (GSA)

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