Chicago Police Department Overtime Controls Audit Follow-Up Inquiry

The City of Chicago Office of Inspector General (OIG) has completed a follow-up to its October 2017 audit of the Chicago Police Department’s (CPD) overtime controls. Based on the Department’s responses, OIG concludes that, of the 13 corrective actions related to the audit findings, CPD has fully implemented 2, substantially implemented 2, partially implemented 7, and not implemented 2.

The purpose of the 2017 audit was to determine if CPD effectively managed regular-duty overtime to prevent waste and abuse. Our audit found that CPD’s operational controls did not adequately prevent unnecessary overtime, deter abuse of minimum time provisions, or ensure that overtime was paid in compliance with policies and procedures. We also found that CPD management controls did not adequately prevent officer fatigue, control costs, or detect and prevent fraud, waste, and abuse. Finally, OIG found that CPD directives related to timekeeping did not reflect current practice, did not provide adequate detail to ensure consistent application of Department policies, and did not include policies to prevent excessive overtime, prevent officer fatigue, or control costs.

Based on the results of the audit, OIG recommended that CPD,

  1. work with the Office of Budget and Management (OBM) to implement an automated timekeeping system that includes the controls necessary to ensure that timekeeping records are accurate, verifiable, and complete;
  2. immediately implement the necessary manual controls to prevent the operational errors and potential abuse described in the audit;
  3. conduct a routine reconciliation between the data in the Department’s management reporting and payroll processing systems;
  4. ensure that all CPD members, timekeepers, and supervisors are trained on policies related to timekeeping, and are following and/or enforcing these policies appropriately and consistently;
  5. prioritize timekeeping oversight and set a “tone at the top” that emphasizes individual accountability for all CPD members;
  6. establish clear expectations regarding unit management responsibilities related to overtime;
  7. ensure that supervisors have the tools they need to monitor overtime, and require that they actively use such tools;
  8. hold unit management accountable for excessive or unjustified overtime use;
  9. ensure that all directives are included in its directives system, are up-to-date, and reflect actual practice;
  10. routinely review directives to confirm that the documented policies conform with both CPD’s obligations under the current Collective Bargaining Agreements and the Department’s current processes;
  11. ensure that all directives provide sufficient detail to promote consistent application across the Department;
  12. train supervisors how to determine whether overtime is warranted; and
  13. limit the number of hours officers may work in a given period, including secondary employment, as is already the practice in other jurisdictions.

In its response to the audit, CPD described corrective actions it would take regarding most audit recommendations, but disagreed with OIG’s recommendation that the Department limit the number of hours officers may work in a given period, including second jobs.

In June 2019, OIG inquired about corrective actions taken by CPD in response to the audit. Based on CPD’S follow-up response OIG concludes that the Department has initiated a systemwide overhaul of its overtime system, but that reform is still a substantial work in progress. CPD described several new systems it has introduced to monitor timekeeping and overtime usage. As of September 30, 2019, all members are required to swipe in and swipe out during their regular tour of duty shift using an automated time and attendance system. This system, already used in many other City of Chicago departments, electronically records CPD employees’ start and end times. However, CPD does not use the system’s biometric component, which is designed to prevent an employee from swiping in or out for another employee.

Further, CPD stated that, in April 2019, it moved overtime requests from a paper-based system to an electronic system called CLEARNET. Among other features, CLEARNET allows CPD members to track overtime requests and supervisors to view requests in real time.

The third technology CPD implemented is Jaspersoft, which allows management to analyze overtime data at an individual, unit, and bureau level. CPD includes overtime data in its CompStat meetings. OIG did not evaluate the effectiveness of these new tools, which would require a new audit with full testing.

Throughout the process of implementing these technologies, CPD conducted multiple trainings for timekeepers, members, and supervisors on new policies and procedures. The Department has updated 8 out of 17 Department directives related to payroll and timekeeping since the publication of the audit.

We urge CPD to fully implement its new timekeeping and overtime policies, with particular focus on swiping compliance and proper overtime request approval, and to conduct internal audits of the effectiveness of the swiping system and its utilization by Department personnel. While supervisors have more tools to manage overtime in their units, we urge the Department to identify potential patterns of waste or abuse and to provide supervisors with the appropriate training and tools to address such patterns. CPD should also continue to update the remaining directives related to payroll and timekeeping, ensuring that they reflect current practice and are periodically reviewed and updated.

CPD has not implemented OIG’s recommendation to create a policy limiting the total hours officers work, including secondary employment, in order to ensure officers are well-rested and ready to effectively serve the public. We continue to urge CPD to implement such a policy.