INTERNAL AUDIT REPORT 
Operational Audit 
Time Approval Controls 

January 2023 – April 2024 






Issue Date: June 4, 2024 
Report No. 2024-04

           Time Approval Controls 

TABLE OF CONTENTS 

Executive Summary ................................................................................................................................................. 3 
Background ............................................................................................................................................................. 4 
Audit Scope and Methodology ............................................................................................................................... 5 
Schedule of Observations and Recommendations ................................................................................................ 6 
Appendix A: Risk Ratings ....................................................................................................................................... 13 













This report is a matter of public record, and its distribution is not limited. Additionally, in accordance with
the Americans with Disabilities Act, this document is available in alternative formats on our website. 


2

           Time Approval Controls 
Executive Summary 
Internal Audit (IA) completed an audit of the Time Approval Controls for the period January 2023 through
April 2024. The audit was performed to assess the effectiveness of internal controls related to time entry
and approval. The audit scope was determined based on our risk assessment procedures, as well as
our preliminary interviews with various Port managers. 
Port of Seattle (Port) payroll costs are the largest operating costs, representing a little over 60% of total
operating costs. Payroll costs are budgeted to increase in 2024 by approximately $29 million to $384
million. The Port has disparate systems, collective bargaining agreements with multiple pay codes, and
both hourly and salaried employees. This  creates obstacles to establishing one process that is
systematically understood and followed by all departments. 
Our audit focused only on Aviation Maintenance and in general, we concluded that Port management’s
internal controls aligned with policies and procedures. However, our audit identified opportunities where
internal controls could be enhanced or developed. These opportunities are listed below and discussed
in more detail beginning on page six of this report. 
1. (High) There is no formal review and approval process performed over employees’ timesheets
assuring the accuracy of hours submitted every pay period. 
2. (High) A policy limit to control the amount of overtime employees work has not been
established. Without a limit, the likelihood of accidents could increase, and employee well-being
could decline due to individuals who work excessive hours. 
3. (Low) During testing, Internal Audit noted that for some of our selections, supporting
documentation was missing and/or unavailable. 
We extend our appreciation to Port management and staff for their assistance and cooperation during
this audit. 


Glenn Fernandes, CPA 
Director, Internal Audit 




Responsible Management Team 
Katie Gerard, Senior Director, Human Resources 
Mike Tasker, Director, AV Maintenance 
Brendalynn Taulelei, Sr Manager AVM 


3

           Time Approval Controls 
Background 
The Port of Seattle (Port) employs approximately 2,532 people, comprised of both represented and nonrepresented
employees. Internal Audit determined the appropriate scope based on our risk assessment 
procedures, as well as preliminary interviews with managers from different departments within the Port.
As such, this audit primarily focuses on Aviation Maintenance (AVM), specifically represented hourly
employees within the department. As seen in the table below, AVM is comprised of 421 total employees.
Our audit focuses on the three departments with the largest headcount: AV Electrical & Electronic Sys,
AV Mechanical Systems, and Facility, Fleet, Sys & Grounds. 
Department          Number of Employees 
AV Electrical & Electronic Sys               135 
AV Maint Asset Mgt & Logistics             41 
AV Maint Business & Fin Mgmt             1 
AV Mechanical Systems                  124 
Facility Service Contract Mgmt               4 
Facility, Fleet, Sys & Grounds               116 
Total AVM Employees:              421 
At the end of every shift, hourly represented employees are supposed to enter their hours worked in
Maximo prior to leaving, with the exception of a handful that submit directly to PeopleSoft. Hours in
Maximo, including any overtime, vacation, sick leave, etc., are tracked and linked to specific work orders.
Ideally, supervisors (such as crew chiefs and chief foremen) review their crew’s time on a weekly basis
to verify the accuracy of hours submitted. Then, at the end of every 2 weeks, everyone’s time is
submitted in Maximo and reviewed by the AVM Time Administrator. 
The AVM Time Administrator runs various reports to check each employee’s timesheet, particularly as
to whether each employee has at least 40 regular straight time hours submitted for each week in the
pay period, whether each employee has at least 8 or 10 straight time hours a day, and whether or not
the proper combination of pay codes are being used to report the different types of hours worked in the
period. When errors are spotted and needed to be corrected, the Time Administrator emails the
respective chief foreman and employee, as well as the manager, of the affected department. Due to the
required quick turnaround in order to process payroll timely, the managers will either investigate and
make the necessary adjustments themselves (by adding a note in Maximo to explain the change made 
or emailing each employee directly) or they will have the affected employee make the adjustments by 
themself. In 2023, there were over 3,400 payroll adjustments remedied and as of April 2024, over 430 
adjustments have been required. 
After all the necessary adjustments and changes are made, the Time Administrator runs a Validation
Report in Maximo to verify that all records have been processed and that there are no longer any errors.
Once this is finished, the Time Administrator is then able to “Approve Time” in Maximo by batches, as
Maximo is only able to process 2,000 records at a time. When all the records have been approved, a
“Submit” report is then run in Maximo to finish the entire process. Once everything in Maximo is
completed, a Maximo Integration report is then run in PeopleSoft in order to essentially transfer all the
information from Maximo to PeopleSoft. Lastly, the Time Administrator will make any necessary final 
manual adjustments, such as FMLA, before running the final “Payable Time Report” in PeopleSoft. This
will  then  be  approved  by  the  Administrative  Supervisor and  communicated  to  Payroll  once  fully
completed. 



4

           Time Approval Controls 
Audit Scope and Methodology 
We conducted the engagement in accordance with Generally Accepted Government Auditing Standards 
and the International Standards for the Professional Practice of Internal Auditing. Those standards
require that we plan and conduct an engagement to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our engagement objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and conclusions based on our
engagement objectives. 
In some instances, we used judgmental sampling methods to determine the samples selected for our
audit test work. In those cases, the results of the work cannot be projected to the population as a whole.
The period audited was January 2023 through April 2024 and included the following procedures: 
Interviews & Process Walkthroughs 
• Interviewed and performed process walkthroughs with over 15 Port managers and staff within
Aviation Maintenance (AVM), Payroll, and ICT to gain an understanding of: 
o   The current timekeeping processes, including the review and approval processes.
o   Related preventive and detective controls in place.
o   Opportunities for improvement.
Document Review 
• Reviewed key documents related to timekeeping processes, including the following: 
o   Port Policies and departmental policies/procedures.
o   Collective Bargaining Agreements (CBA), defining various aspects of employees’ time
and terms of employment. 
o   Full AVM Employee Listing, including Department, Job Title, and Manager Names.
o   Various Business Intelligence (BI) Reports detailing Overtime Double Time (OTDT)
Analysis, OT Requested and OT Worked, Pay Period Review, and Time Review.
Testing 
• Timesheets Test:
o   Randomly selected a sample of nine represented, hourly employees within AVM across
five different pay periods from January 2023 to April 2024 and noted the following:
 Name, Job Title, Department, & Manager Name.
 Total Number of Hours Worked for the Specific Pay Period, including the type of
hours (i.e. Regular, Overtime, PTO, Sick Leave, Floating Holiday, FMLA, etc.).
 Verified backup supporting documentation for hours submitted (combination of
electronic records, emails, and hardcopy paper slips).
• Overtime (OT) Test:
o   Accessed and reviewed a BI Report showing OT Hours for AVM.
o   Selected the top five employees with the greatest number of OT hours for 2023.
o   Analyzed their job titles, what departments they work for, and the specific Maximo work
orders related to the OT hours (including description of work).
o   Inquired with department manager to gain a better understanding of why OT is needed,
how it is being utilized effectively, and how to assure employee safety and well-being 
despite working OT.



5

           Time Approval Controls 
Schedule of Observations and Recommendations 
1) Rating: High 
There is no formal review and approval process performed over employees’ timesheets assuring
the accuracy of hours submitted every pay period. 
Currently, the timekeeping process within AVM is disjointed and fragmented, varying from one
department to another. Based on our interviews and conversations with staff (including crew, foremen,
and managers), we determined that some foremen review their crew’s time on an almost daily basis,
some review on a weekly basis, and some foremen do not review and merely wait to hear from the AVM
Time Administrator regarding corrections and adjustments that are needed to be made. Due to the
inconsistencies in the overall review process, the number of errors and adjustments needed greatly
differ from period to period. Additionally, even though some foremen review their crew’s time, errors and
mistakes are still not caught prior to Maximo submission. 
As a result of this, the burden primarily falls on the AVM Time Administrator. Due to the sheer volume
of hourly employees within AVM (approximately 300 hourly, over 400 employees in total), it is not
feasible and sustainable for this individual to check every timesheet for every pay period. Furthermore, 
the Time Administrator is not aware of everyone’s day-to-day schedules and therefore, not in a position
to verify accuracy. 
Recommendations: 
1.) Develop a formal process of reviewing and approving timesheets. If needed, allocate some
admin time (i.e. 15 minutes every day or 1 hour every week) for approvers (primarily, crew
foremen chiefs) to have adequate & sufficient time to thoroughly review their own crew’s
timesheets. This will assure the accuracy of hours submitted and will hopefully, reduce the
volume of emails back and forth with the time administrator. 
2.) Consider adding physical punch time clocks, which can ideally feed information into Maximo 
automatically, at all AVM workshops and facilities to ensure accurate reporting of employees’
entry and exit during every shift. This will aid in time tracking, as well as streamline the overall
process. 
3.) Increase formal training opportunities for employees to raise awareness about the importance of
submitting time accurately and timely. IA notes that due to various CBAs with different labor 
unions, each employee’s timesheet can vary widely, with numerous different pay codes. As such,
formalized training, either conducted by the Port, or in conjunction with each union, could be very
helpful and valuable for all hourly, represented employees. 
4.) Develop consequences for employees who forget to submit their timesheets regularly or require
corrections and adjustments often. 





6

           Time Approval Controls 
Management Response/Action Plan: 
1)  We concur with recommendation #1 audit observation regarding a formal review and approval
process to ensure the accuracy of employee hours submitted to payroll. Although as a
management team we fully recognize the challenges our maintenance shop supervisors
currently have - with the workload of managing crew work assignments, staffing levels with
limited staff, and for some supervisors, being in the field performing the work themselves due
to high demands - we are fully committed to following through and taking action. 
Action Plan: Aviation Maintenance will develop and implement a time entry review and
approval process for the Maintenance Shop Supervisors to enable the validation of hours
recorded by each employee on work they performed. The process document will highlight the
expectations for each Supervisor to review and approve employee recorded time entries daily
either at the beginning or ending of each shift. The process document will also include
reference for any reporting tools or dashboards built to streamline the review and approval
process for Supervisors. 
Once the process is developed action will be taken to 1) communicate Supervisor roles and
responsibilities for the new process, 2) provide training for each maintenance field employee on
expectations to record hours worked consistently and accurately, 3) provide training for
Supervisors on the process, emphasize any reporting tools provided for compliance monitoring
and 4) emphasize the required actions to take prior to Payroll processing. 
We believe implementing these steps will alleviate the burden on the department timekeeper to
validate and account for employee hours during payroll processing. Process development will
begin Q3 of 2024 with full implementation of by end of Q1 2025. 
2)  In response to recommendation #2 about physical punch time clocks in shop locations, we will
explore opportunities for this option. We recognize that whatever time clock system we put in
place should further improve the current process and prevent having to go back to manual data
entries. 
Action Plan: Work with Maximo industry experts using the current IDIQ Maximo vendor
contract to further investigate opportunities to record data directly from punch time clock into
the EAM (Maximo) system. Determine if off the shelf solutions are available on the market and
assess its feasibility with our current Port processes and systems. 
3)  We concur with recommendation #3. Once the process (see response #1) is developed and
ready for implementation, training will be implemented for all Aviation Maintenance hourly and
represented employees. 
Action Plan: Develop and deliver training for all hourly and represented employees. The
training will emphasize the importance of recording hours worked accurately, as well as
highlight the expectation that each employee should record hours worked on jobs daily. The
training will also educate staff on the various pay time entry codes available and when they
should be used. Training will be aligned with process implementation timeline in Q1 2025.
4)  Most of the represented groups within the Maintenance department do not have annual
performance reviews as part of the CBA. Therefore, we can’t tie consequences to an annual
performance review however we believe with the process training and development of payroll
(labor transaction) reports and/or dashboards for the Supervisors, should make it easier to spot
inconsistencies and inaccuracies in time recording. 

7

           Time Approval Controls 
Action Plan: Perform regular review of the payroll (labor transaction) reports and/or
dashboards to identify discrepancies and noncompliance. Partner with the Port’s Labor
Relations team to discuss consequences (when appropriate) for employees who are
continuously not in compliance with time recording expectations.


















DUE DATE: 03/31/2025 

8

           Time Approval Controls 

2) Rating: High 
A policy limit to control the amount of overtime employees work has not been established.
Without a limit, the likelihood of accidents could increase, and employee well-being could
decline due to individuals who work excessive hours.
Based on our audit procedures, we noted that in 2023, a total of 74,264 OT hours was worked, with
higher hours worked primarily during the summer and winter months. Certain departments within AVM
work a significant number of OT hours.
When discussed with management, they acknowledged the safety impacts of excessive overtime. Our
testing identified an employee who worked a 34-hour shift and another employee who worked a 90-hour
work week. We also identified an employee who worked several 20-hour shifts after already working a
10-hour day.

Job Title                        Total Overtime Double Time
(OTDT) Hours in 2023 
Aviation Field Technician                      1,026 
Aviation Field Technician                       761 
Aviation Field Technician                       760 
Laborer Parking/Fuel Cleaner                 856 
Laborer Parking/Fuel Cleaner                 847 

From the table above, IA noted that the 5 employees with the greatest number of OT hours for 2023 are
all from the Facility, Fleet, System, & Grounds Department. Most of the OTDT work is done over the
span of a couple months throughout the year, depending on necessity and urgency. Additionally, we
noted that the longest streak of consecutive OT performed was four days. 
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) reports many
American workers spend over 40 hours a week at work, sometimes during evening and nights, rotating,
and/or irregular shifts. These schedules can cause worker fatigue. As a result, “Long work hours may
increase the risk of injuries and accidents and can contribute to poor health and worker fatigue. Studies
show that long work hours can result in increased levels of stress, poor eating habits, lack of physical
activity and illness.”
Generally, federal and state law do not limit the number of hours an adult employee can work. However,
several Federal Agencies and National Organizations have developed Fatigue Risk Management
Programs that restrict the number of hours an employee can be on the job. 
Per our discussions, a lot of the overtime hours worked are mandatory (i.e. rubber removal from
runways) and required to be done during off-peak business hours. As a result, the work is usually needed
to be performed during graveyard shifts and weekends. Additionally, some of the work performed is also
seasonal (i.e. baggage handling assistance during cruise season) so staffing is always challenging. 
Lastly, OT is also optional and non-mandatory, apart from snow days. 
In addition to safety and wellbeing, overtime is more costly. In fact, in 2023, the Port paid over $8M in

9

           Time Approval Controls 

total  overtime  labor  costs  versus  the  budgeted  amount  of  $3.3M.  During  our  discussion  with
Management, IA also brought up the possibility of adding headcount to possibly reduce OT hours but
due to the overall nature and timing of tasks, it would ultimately be more costly and there would not be
sufficient work to keep all employees productive. 
Recommendations: 
1.) Develop a Port-wide policy to enforce a formal cap and limit on the number of consecutive
hours that an individual can work within a 24-hour period, highlighting safety concerns and
supporting employees’ overall health and wellbeing. 
2.) Integrate the language from the Port-wide policy into CBAs. 
Management Response/Action Plan: 
We concur with the Audit team’s recommendations #1 & #2. There is a definite need for a Port-wide
policy to enforce a formal cap on the amount of overtime an individual employee can work; we as a
management team share the same concerns around safety and the overall health and well-being of
the employee. We also agree with the plan to integrate the Port-wide policy into each CBA to ensure
standardization across the board. At this time, we will refrain from taking any action related to these
recommendations at the department level.











DUE DATE: 12/31/2024 

1 0

           Time Approval Controls 
3) Rating: Low 
During testing, Internal Audit noted that for some of our selections, supporting documentation
was missing and/or unavailable. 
Within AVM, different departments have varying policies regarding requests for Vacation, Leave without
Pay (LWOP), Family and Medical Leave Act (FMLA), etc. In general, requests for absences from work
must be submitted to respective managers, either via hard copy (filling out a paper slip and having it
physically signed by his/ her manager) or more recently, electronically (via a SharePoint request).
In the testing we performed, out of 45 total samples, we had eight items specifically, which supporting
documentation could not be provided since they were either missing, lost, or non-existent. Of the eight 
selections, three were related to LWOP, four were related to Vacation, and one was related to FMLA. 
Based on our discussions with respective managers, there were varying responses as to why support
could not be provided. For the LWOP selections, no supporting documentation exists so nothing could
be provided as back-up. For the selections related to Vacation, IA was told that a shop flood in the past
year may have destroyed written documentation and support. As a result of this, nothing could be
provided as well. Lastly, for the selection regarding FMLA, there was no backup available as the FMLA
email and worksheet prepared by HR was non-existent and could not be found. 
Since supporting documentation could not be provided for 8 out of 45 selections, IA was not able to
verify and substantiate that these hours were indeed approved appropriately. 
Recommendations: 
1.) Streamline the entire request process and develop an AVM-wide policy regarding Vacation and
Leave Requests. Going forward, IA recommends the usage of electronic requests for all of AVM
to avoid any possible loss and misplacement of supporting documentation. This will aid
departments in overall recordkeeping, as well as document retention.
2.) Coordinate with Port’s HR regarding employees’ FMLA requests to develop a more formalized
and standardized process to avoid any delays and errors when processing timesheets for payroll.
This ensures that employees’ FMLA requests are processed timely and less retroactive
adjustments are needed to be done. 

Management Response/Action Plan: 
1.  We concur with IA’s recommendation #1. AVM has an electronic leave request process
developed in SharePoint. The SharePoint leave request form is currently being used by nonrepresented
employees and some of the maintenance represented employee shop teams. We
agree that a standard process or department policy is needed to ensure the whole department
is using the electronic SharePoint leave form. 
Action Plan: Improve and implement the standard department electronic leave process for all
maintenance teams and eliminate the use of paper leave requests. Internal department teams
will work with the Administrative Supervisor to improve the current SharePoint form to be used
more broadly for all teams. We will identify the teams who will transition from paper leave
requests to the electronic process and ensure all shop employees that are currently using
paper are trained on the electronic leave request form. Send out department communication to 

1 1

           Time Approval Controls 
highlight transition dates and when these changes will be implemented formally.
2.  We concur with recommendation #2 on the FMLA process. FMLA is a process that is owned by
the Port’s HR department. 
Action Plan: Partner with HR to identify the gaps in the current process and collaborate to
improve the process, streamlining the steps and communication related to FMLA. This process
affects and involves all these roles currently - the AVM employee, AVM Manager, AVM
Timekeeper, Corporate Payroll, HR Benefits team, and Sedgwick. 
















DUE DATE: 12/31/2024 

1 2

           Time Approval Controls 
Appendix A: Risk Ratings 
Findings identified during the audit are assigned a risk rating, as outlined in the table below. Only one
of the criteria needs to be met for a finding to be rated High, Medium, or Low. Findings rated Low will be
evaluated and may or may not be reflected in the final report.
Financial                                                              Commission/
Rating                       Internal Controls  Compliance    Public 
Stewardship                                                    Management 
Non-          High probability for
Missing or not      compliance     external audit        Requires
High          Significant     followed           with Laws,     issues and / or      immediate
Port Policies,    negative public       attention 
Contracts       perception 
Moderate
Partial
Partial controls                        probability for
compliance
external audit        Requires
Medium      Moderate                    with Laws,
Not functioning                      issues and / or      attention 
Port Policies
effectively                               negative public
Contracts 
perception 
Mostly         Low probability for
Functioning as                                         Does not
complies with   external audit
intended but                                            require
Low         Minimal                      Laws, Port     issues and/or
could be                                              immediate
Policies,         negative public
enhanced                                          attention 
Contracts       perception 
Efficiency     An efficiency opportunity is where controls are functioning as intended; however, a
Opportunit y  modification would make the process more efficient.










1 3