A SUPERVISOR’S HANDBOOK TO DISCIPLINE

IN THE IMMIGRATION AND NATURALIZATION SERVICE

TABLE OF CONTENTS

Introduction   

            Chapter 1: The Supervisor’s Role in Discipline     

            The Supervisor as Coach     

            Setting the Climate   

            Communicating Conduct Standards

            Employee Recognition and Discipline         

            Correcting Lapses                

            Chapter 2: Investigation                   

            Meeting with the Employee

            Employee Status during Investigation

            Chapter 3: Determining Appropriate Corrective Action

            Who is telling the truth?       

            Weighing the Evidence         

            What are the options available for Correction?

Identify Aggravating and Mitigating Circumstances.

(Douglas Factors)     

Recommending Formal Action                                 

            You are not alone!     

When OIG or OIA investigations identify misconduct by your employee(s)        

Chapter 4: Delivering Discipline                 

 

Frequent Disciplinary Situations

Chapter 5: Attendance Related Problems   

Absence Without Leave (AWOL) and

            Failure to Follow Leave Procedures            

            Leave Abuse

            Excessive Leave Without Pay         

            Fraudulent Requests for Leave       

            Excessive Unauthorized Absence    

            Leave for an Employee who is incarcerated           

           

Chapter 6: Misuse of Government Property, Vehicle, Credit Card, Time etc      

Phones

Computers

Government Vehicles

            Government Credit Cards    

            Government Time     

            Setting the Example  

Unauthorized Removal of

            Government Property (theft)            

 

            Chapter 7: Insubordination/Failure to Follow Supervisory Instructions    

            Insubordination         

            Failure to Follow Instructions           

            Lax Completion of Directions          

            Chapter 8: Disruptive Conduct at Work                 

            Inappropriate Remarks        

            Personality Conflicts

            Threats          

            Fighting          

            Chapter 9: Misconduct towards or with aliens                    

            Chapter 10: Falsification                  

 

            Chapter 11: Alcohol or Drug Abuse and Other Medical Issues    

            Alcohol or Drug Abuse         

            Other Medical Issues           

            Obligations in dealing with a handicapped person  

            CONCLUSION                     

 

Appendices

A. Douglas Factors

B. Standard Schedule of Disciplinary Offenses and Penalties (DOJ 1752.1A, App. 1)

C. Recommendation for Disciplinary Action

D. List of Servicing INS Labor/Employee Relations Offices

E. Leave Counseling and Leave Restriction Letter

F. April 21, 1995 memorandum on Use of Office and Library Equipment and Facilities

G. Checklist of Supervisory Responsibilities on Workforce Discipline and Performance


A SUPERVISOR’S HANDBOOK TO DISCIPLINE

IN THE IMMIGRATION AND NATURALIZATION SERVICE

INTRODUCTION

Immigration and Naturalization Service (INS) employees are expected to maintain the highest standards of personal conduct and integrity. It is the responsibility of all supervisors to ensure that all their subordinates understand and live up to these high standards. This Handbook provides guidance to first-line supervisors on how to assure that these high standards are followed by employees under their supervision. Maintenance of these standards will promote the efficiency and effectiveness of your work operations and assure compliance with laws and regulations.

Discipline can be both positive and negative. Positive discipline is achieved when individuals hold themselves to high standards of conduct and responsibility because they accept and value those standards. Maintaining discipline in organizations where all employees have this high degree of commitment is easy. However, supervisors need to take positive actions to establish such a positive environment. Setting the example and effective communications can help the supervisor to establish a work environment where employees internalize these high standards.

The second side of discipline is correction and punishment of misconduct. In correcting individual instances of misconduct, it is important that the penalty be the minimum necessary to bring about the desired change. All penalties must be consistent with the facts and circumstances surrounding the misconduct. Fortunately, misconduct is not an everyday occurrence among INS employees, but it is one of the most challenging and difficult aspects of supervision. Dealing effectively with disciplinary problems requires a good understanding of the discipline process and skill in handling a variety of human relations problems.

This handbook is a “how-to” guide for first and second line supervisors. It takes you through the disciplinary process step-by-step. It focuses on the kinds of problems which you, as a supervisor, will be expected to resolve. While you will be provided with information concerning formal disciplinary actions, the focus will be on informal actions which correct inappropriate behavior before it becomes a big problem. It will also provide you with specific guidance on the types of disciplinary problems that you are most likely to encounter as a first-line supervisor.

This handbook was developed as a result of the INS Adverse Action Working Group recommendation. The Group suggested the handbook’s concepts and stressed the necessity of emphasizing the role of the first line supervisor in the monitoring and disciplining of employees. A heart-felt thank you goes out to both the Adverse Action Working Group and the servicing Labor Management and Employee Relations offices for their review of the draft of this handbook and their suggestions for improvement.


Chapter 1

The Supervisor’s Role in Discipline

The Supervisor as Coach: Your job as a supervisor is similar to that of a coach of a high performance athletic team. You are concerned with winning, but you are also concerned that your players follow the rules. You don’t want to lose a game because individual players draw too many fouls. Most of all, you do not want to lose a key player to a suspension caused by a momentary lapse in judgment (Dennis Rodman and Roberto Alomar come to mind). Just like the Chicago Bulls or the Baltimore Orioles, INS employees are subject to close scrutiny by the public and the media. To be a successful coach, you not only need to be sure that the players have the skills and tools to do the job, but that they know the rules of the game and do not violate them.

Setting the Climate: As a coach, the first-line supervisor plays a key role in establishing a work place climate in which each and every employee takes responsibility for maintaining the highest standards of conduct and integrity. As a supervisor, you set the example for the conduct of your subordinates. If employees see you as a role model with conduct beyond reproach, they will respect you and follow your lead. As a supervisor, you are held to a higher standard than your subordinates. More severe disciplinary action can be taken against, you for the same misbehavior as your subordinates. You must make sure that your use of leave is appropriate; that you do not misuse government equipment or government time; that you do not engage in disruptive behavior such as yelling and swearing; that you follow applicable regulations and management directions; and that you do nothing which could be interpreted as a conflict of interest. The behavior which you exhibit is the behavior that you can expect from your employees. You will have very little credibility with them when you counsel them concerning their behavior if you engage in similar conduct.

Communicating Conduct Standards: Like a good coach, you must make sure that the players know the rules of the game before they take the field. Before you can hold employees accountable for their conduct, it is essential that they know and understand the standards and rules which you expect them to follow. Whenever a new employee begins working for you (even if they have prior INS experience), you need to discuss with him/her your expectations for conduct. You should make clear that you expect an employee to be at work every day on time except when leave has been approved. Explain the procedures which are to be followed for leave approval for sick leave or emergency annual leave. Of special importance, is clear instruction on what to do if you are not available when the employee calls. Review key provisions of the Department of Justice’s Ethics Handbook and/or the Officer’s Handbook (if applicable) with the employee. Do not assume that employees understand these requirements because they were covered in the Academies or employee orientations. If an employee has a question concerning those standards on which you are not sure of the answer, check with your next higher supervisor, your servicing labor/employee relations office, or your Counsel. Also, make sure that employees understand the rules for performing their jobs. For example, make sure that a Border Patrol Agent knows the rules for the use of deadly and non-deadly force and the procedures to follow in reporting their use.

Include conduct reminders in staff meetings or musters. As situations occur, which may tempt employees to stray into unacceptable  behavior., remind them of your expectations. Also, well-placed reminders of your expectations concerning conduct can be included in individual mid-year and end-of-year performance discussions.. Keep notes concerning discussions which you have with employees on conduct. Be sure to include what was said, who was there, and when the discussion was held. In addition, ask the employee to sum up the discussion in his/her own words so you are certain that the employees understands fully. Include this summary in your notes. Provide a copy to the employee.

Employee Recognition and Discipline: A good coach congratulates each team member when s)he makes a good play. One of the best ways to build self-discipline in your employees is to encourage and praise them when they do things right. A supervisor who only points out mistakes and errors, is less likely to be heard by employees. They screen out the negatives and rationalize that the supervisor is too picky,, impossible to please and out to get them. The use of deserved praise enhances morale and also makes employees more receptive to criticism when it is given. It is important to catch your employees in the act of doing things right. A person who is having discipline problems can be especially receptive to positive feedback. For example, if you have an employee who has been having problems with attendance who makes it in to work on a snowy day tell her, “Boy, I am sure glad you made it in today. I know it was hard today. I am short-staffed and I really need your help.” Similarly, praise for an Immigration Inspector with a history of a short temper is in order when he calmly deals with a cranky tourist. Just say: “I notice that the man in the blue jogging suit seemed to be really agitated. I liked the way that you talked to him calmly and did not let him get under your skin. Good Job!” Praise for performance accomplishments throughout the year can also help an employee take constructive criticism better.

Correcting Lapses:  Everybody makes mistakes. The important thing is to identify the mistakes, how they occurred and take corrective actions so they do not happen again. The good coach knows how to correct players so that they are motivated rather than demoralized. As a supervisor, you need to develop this very difficult skill.

The best method of correction is to identify when an employee may be about to make a mistake and correct him/her before the mistake is made. The sooner you correct a mistake the better. Speed is essential to effective correction. It prevents repetition of the mistake and gives employee current feedback. The results of discipline diminish in proportion to the time allowed to elapse between the offense and the disciplinary action. Also, each problem should be dealt with as it occurs and offenses should not be allowed to accumulate. If you say nothing, the employee will think that the behavior is O.K. Worse yet, other employees see that their co-worker is getting by with this behavior, and try it themselves. Letting it ride is very dangerous. At some point you may have a big problem with that same employee. You will want to impose severe discipline, however it may not be justified because it will officially be only a first offense.

In order to be effective, discipline for conduct which is not so serious as to warrant removal needs to be progressive. In a basketball game, a player is not thrown out of the game for the first foul, unless his conduct is really outrageous. Similarly, you do not remove an employee for a first instance of tardiness. Initially, you try the least stringent action which you think will resolve the problem at hand. You also select a punishment to fit the offense. If lesser penalties don’t work, than you may have to catch the employee’s attention with a more stringent penalty and a loss of pay. There is, of course, some conduct which is so outrageous that only removal will resolve the problem. But such conduct is very rare. You will need to keep notes and document your efforts at correction throughout the process.

Chapter 2

Investigation

Initially, you have to know what happened. Since you do not have a game tape to review, you will need to obtain and analyze information before correcting the mistakes. As a super-visor, you learn of problems through observation, by keeping communications open with your employees, through feedback provided by your customers, and through investigation. When you learn that inappropriate conduct by one of your subordinates may have occurred, you need to be prepared before you can effectively correct that employee. You need to obtain the employee’s side of the story, gather information from witnesses, and obtain and review relevant documents, regulations and law. This should be done as soon as possible in order to assure the accuracy of witnesses’ recollections and to correct the problem immediately.

Some incidents may be so serious that corrective action is outside of your authority. Any allegation that an employee engaged in criminal misconduct, abuse of aliens, a conflict of interest, or fraud against the government should be reported immediately to the Office of Internal Audit and the Department of Justice’s Office of Inspector General either directly or through channels. 01 287.1.0 provides complete instructions on reporting misconduct. It divides allegations which are made against employees into four classes. Class I are the most serious and must be reported to both the Office of Inspector General and the Office of Internal Audit. Class II allegations involve any allegation against an employee at the GS-14 level or higher and significant allegations against other employees which are more likely to be resolved in the administrative rather than criminal forum. Examples are unauthorized use or possession of government property, consumption of alcohol on duty, and disorderly conduct. These allegations are to be reported as soon as possible to OIA. OIA will determine whether the employing activity should conduct the investigation. Class III allegations involve allegations of conduct which are important, yet not as serious as Class Il allegations. Examples include disrespectful conduct, insubordination and lesser property violations. These allegations must be reported to the OIA within 24 hours, but the employing office will conduct the investigation. Lesser problems such as attendance problems, minor rule violations, goofing off, and sloppy work, you can handle yourself These are Class IV allegations.

In addition, certain conduct must also be reported under special procedures established to expedite their investigation. Special procedures have been established for investigating specific types of incidents which require a specialized response. Such incidents include those involving discharge of a firearm, the use of non-deadly force, allegations of abuse of aliens, and accidents. As a supervisor, you need to assure that these procedures are followed.

In determining what happened, you need to gather all available facts and information. You need to make sure that you know the following:

1. How the incident occurred.

2. When (date and time) the incident occurred.

3. Where the incident occurred.

4. Who else was involved.

5. Who witnessed the incident.

6. What exactly was done or said.

7. What may have led up to the incident.

8. What was observed by the witnesses.

Meetings with the Employee:  Obtaining the employee’s side of the story is a crucial step in determining what action you will take. Wherever practicable, you should talk directly to the involved employee before talking to other witnesses. For nonsupervisory employees in Border Patrol Sectors, you must advise the employee in writing of the right to be represented by the Union at this meeting prior to taking a written or sworn statement from the employee or when an employee is going to be interrogated before witnesses as provided in Article 31 B(2)b(3) of the Agreement between INS and the National Border Patrol Counsel.

Remember this initial meeting should be a fact finding meeting and you should keep an open mind. Let the facts lead you. In conducting this meeting, you need to keep the following pointers in mind:

(1)  The meeting should be held in private without interruptions. If you do not have a private office, make arrangements to meet in, a conference room or other private space. Make sure that your telephone calls are held and that visitors will not interrupt you. A box of facial tissue should be present in case the employee becomes emotional. Do not allow yourself to be drawn into the emotional release. If necessary, provide for a short break in questioning until the employee regains composure.

(2)  Never hold the meeting when you are angry or distracted. You must be able to give your full attention to the employee while acting calmly and professionally,

(3)  If a bargaining unit employee requests a union representative, make arrangements for the union representative to be present. If an employee requests a union representative, you can delay the meeting (up to 48 hours) to give the employee a chance to obtain the representative. You can also elect to cancel the meeting and proceed based on the facts gathered elsewhere. However, in most instances, it is preferable to have the employee s side of the story.

(4)  Explain to the employee calmly the facts that’ you have gathered and why you believe the conduct to be unacceptable. Ask the employee to provide an explanation of what happened and why. You may place an employee under oath during your investigation.

(5)  Listen closely to what the employee has to say. Lean towards the employee while looking in his/her eyes. Do not interrupt him/her. Take notes. When an employee reaches a stopping point, paraphrase the points which have been made and ask if you have the information correct. Ask further questions needed to clarify the information presented.

(6) Key factors to look for in the employee interview include:

(a) Are there facts which indicate that the employee did not engage in the alleged misconduct?

(b) Does the employee have a plausible explanation for the circumstances leading up to the incident?

(c) Does the employee recognize the wrongfulness of the conduct, show contrition, and is he/she willing to take corrective action to prevent its reoccurrence?

(d) Is the employee being honest with you or does he/she appear to be hiding information? Is he/she answering questions directly or are key questions being evaded? What is the employee’s demeanor?

(e) Does the information provided require further investigation? Does it resolve the concerns which you have?

(7) Do not argue with the employee or the union representative..

(8) Do not admonish the employee at the meeting.

(9) Summarize in writing the information obtained and provide a copy to the employee.

Employee Status during Investigation: Normally an employee will continue working in their regular duties during the time when an investigation is ongoing. However, there are times where the allegations are so serious that the employee’s continued performance of regular duties could jeopardize the smooth functioning of the service. In these situations, the following options are available:

(1)                           The employee may voluntarily choose to take leave. However, an employee cannot be forced to take leave without following regular disciplinary action procedures.

(2)                            Modify the employee’s duties to exclude duties which may be a problem.

(3)                           Detail the employee to another position where the employee will not be performing the problem duties.

(4)                           Place the employee on administrative leave with pay, and

(5)                           Propose an indefinite. suspension if there is sufficient evidence showing “reasonable cause to believe that the employee has committed a crime for which a sentence of imprisonment may be imposed.” In this situation, notify your servicing labor/employee relations specialist.

 

Determining Appropriate, Corrective Action:

After gathering all available information concerning the incident including verification of information provided by the employee and any other follow-up investigation, you are in a position to determine what action, if any, should be considered.

Who is telling the truth? First, you will need to decide whether misconduct did occur. Where you have conflicting information, you will need to decide which evidence is credible (believable). In making credibility determinations, you need to consider the following:

(1)   the witness’s opportunity and capacity to observe the event or act in question;

(2)   the witness’s character;

(3)   any prior inconsistent statement;

(4)   a witness’s bias or lack of bias;

(5)   the contradiction or corroboration of the witness’s version of events by other evidence;

(6)   the inherent probability or improbability of the witness’s version of the facts; and

(7)   the witness’s demeanor when interviewed. (Frequently called Hillen factors based on a decision by the Merit Systems Protection Board).

Weighing the Evidence: After you have determined which evidence is credible, you will need to weigh that evidence to determine whether the misconduct occurred. For Federal disciplinary and adverse actions based on conduct, an Agency must be able to prove by a preponderance of the evidence that the conduct did occur. A preponderance means the amount of evidence that a reasonable person would accept as sufficient to support a conclusion that a contested fact is more likely to be true than not.

Next you have to determine whether disciplinary action will promote the efficiency of the service. There must be a nexus (logical connection) between the conduct and the efficiency of the service. If the misconduct occurred on duty, there is a presumption of nexus. However, off-duty misconduct needs to be examined further. For example, if an employee is having an affair with a consenting adult who is an American citizen, it is unlikely that there would be a connection to the Service. However, if an Asylum Officer was having an affair with an alien whose case he/she processed, there would be a nexus even if the behavior was consensual. This is because the conduct could impair his/her ability to render an impartial judgment on asylum on behalf of the United States. Some conduct such as murder and child molestation is so terrible (egregious) that a nexus can be inferred from the nature of the conduct.

What are the Options available for Correction? Once you have identified the misconduct requiring correction and determined that there is credible, preponderant evidence of that conduct, then you must determine what corrective action is appropriate in this instance. The key thing to remember is that the punishment should be the minimum necessary to correct the behavior and it should fit the offense. Consistency and fairness should also be considered. Appropriate actions to be considered include:

(1) Systemic Corrections/Adjustment: Making changes in procedures and processes to assure that similar violations do not occur. This might be appropriate when your fact-finding reflects that an employee was unaware or misunderstood the requirement and is committed to not repeating the misconduct.

(2) Counseling or oral admonishment: This would be appropriate where the violation is minor, the employee has a good record with no prior instances of misconduct, and is committed to correcting the conduct. A memorandum documenting the counseling can be provided to the employee. Alternatively, a letter of admonishment signed by the supervisor may be provided to the employee, but no record will be included in an employee’s Official Personnel Folder. Such counseling or admonishment can not be cited in future disciplinary actions as a first offense for the purpose of progressive discipline, but it can be cited to show that the employee knew that such conduct was unacceptable.

(3) Letter of Reprimand: The Letter of Reprimand is the lowest level of formal discipline. In the Immigration and Naturalization Service, a reprimand requires a proposal, an opportunity for an employee’s written response, and a decision. Employees in Border Patrol Sectors covered by the negotiated agreement with the National Border Patrol Counsel may also present an oral response to the proposed reprimand per Article 32. A reprimand is grievable. The decision letter becomes a part of the employee’s Official Personnel Folder for a period of time not to exceed two years and can be cited as evidence of a First Offense for Progressive Discipline. It does not involve any loss of pay or time from work. It is appropriate for first offenses of conduct for which a written record is necessary or where admonishment and counseling have not worked. The proposing official for letters of reprimand in the field is normally either the Deputy District Director or the Deputy Chief Patrol Agent. However, super-visors usually recommend that a letter of reprimand be initiated.

(4) Suspensions of one to fourteen days: This is appropriate for a moderately serious first offense or a second offense of minor misconduct. A suspension is a permanent record and an employee loses pay and time from work. A notice of proposed action, an opportunity for the employee to reply orally and/or in writing and a decision is required. As in the Letter of Reprimand, an employee may grieve this action. The proposing official in the field is normally either the Deputy District Director or the Deputy Chief Patrol Agent. ‘However, supervisors frequently recommend action.

(5) Suspensions of fifteen days or more: This is considered a major action and is appropriate for extremely serious first offenses where there is some potential for rehabilitation of the employee, second offenses of moderately severe misconduct, and third offenses of minor misconduct. A 30 day notice, right to respond orally and/or in writing, and decision is required. Bargaining Unit Employees can appeal this decision under the negotiated grievance procedure or they may file an appeal to the Merit Systems Protection Board. Other employees have appeal rights to MSPB.

(6) Indefinite Suspension: In cases where there is “reasonable cause to believe that an employee has committed a crime for which a sentence of imprisonment may be imposed,” an indefinite suspension may be proposed pending the outcome of investigation and/or criminal prosecution. The notice in these cases will be 7 days. The appeal rights are the same as for suspensions of 15 days or more.

(7) Demotion: An employee is reduced in grade permanently. This action is usually reserved for serious misconduct which calls into question the employee’s ability to serve in the current position, but does not preclude employment in a position of lesser responsibility. This is frequently proposed for supervisors who are no longer suitable role models for their subordinates. These are fairly rare actions and require that there be an available position for which the individual is qualified. The procedures and appeal rights are the same as for major suspensions.

(8) Removal during the Probationary (Trial) Period: Whenever a probationary (trial) employee is engaged in repeated minor misconduct or any misconduct which is more than minor, he/she should be removed once you have determined that the employee knew that the conduct was unacceptable. A single notice is sufficient except where the action is for preemployment reasons (i.e. falsification of application). If the action is for preemployment reasons, the employee is entitled to a notice of proposed action, an opportunity to respond and a decision notice. Employee appeal rights are limited to allegations of discrimination due to partisan political affiliation or marital status. Employees who are terminated for preemployment reasons may also appeal whether proper procedures were followed.

(9) Removal: (Career, career conditional, and excepted employees who have completed the probationary or trial period) This is the capital punishment of Federal discipline. It should be used only for very egregious first offenses (such as rape of an alien, embezzlement of thousands of dollars from the government or other felony criminal misconduct). It is also appropriate for lesser misconduct where prior progressive discipline can be shown to have been ineffective. INS will not normally tolerate four or more instances of the same misconduct within two years, even where relatively minor. Because of the severity of removal, MSPB and Arbitrators, who review removal actions under the negotiated grievance procedure, look very carefully at these cases to assure that the penalty is not excessive. They frequently mitigate the penalty to a lesser penalty such as a sixty-day suspension. The appeals rights for removals are the same as for suspensions of 15 days or more.


Employees can also choose to raise allegations that any of the above actions were taken in whole or in part because of discrimination based on race, color, religion, national origin, sex, age, or disabling condition under the provisions for filing an Equal Employment Opportunity Complaint.

Identify Aggravating and Mitigating Circumstances Douglas Factors): In deciding what action to take, the deciding official must consider such factors as the seriousness of the offense, how it impacts the employee’s position, and whether there have been prior instances of misconduct. This requirement comes from a landmark decision, Douglas v. YA, 5 MSPB 313 (1981) and are called Douglas Factors. A complete list of Douglas factors is attached for your information as Appendix A. Failure to give appropriate consideration to any one of the factors applicable to the case could result in a third party reducing the penalty which has been selected by the INS. Also, if any charge which served as a basis for the action, is not sustained by the third party, the third party will reapply the Douglas factors and likely reduce the penalty further if the sustained charge or charges do not reasonably support the action imposed.

The penalty which you select should be consistent with the Department of Justice Standard Schedule of Disciplinary Offenses and Penalties. (See Appendix B).

Recommending Formal Action, If after fully investigating the alleged misconduct, you determine that formal action is required, prepare a memorandum to the proposing official for your organization. This memorandum should include the information found in Appendix C.

You are not alone!  Much of the information provided above is technical and can be intimidating. You are not expected to be an expert in this process. There are trained Labor/Employee Relations Specialists who will guide you through this process and help you make sure that your actions meet all regulatory and legal requirements. Appendix D provides a listing of the heads of the operating employee/labor relations offices at Headquarters and for each Region. In addition, some of the larger sectors and districts have Employee/ Labor Relations Specialists available to assist you. These offices include: Los Angeles District, San Diego Sector, New York District, Miami District and the EI Paso Sector. Please contact your servicing employee/labor relations specialist if you have any questions about the disciplinary process.

When OIG/OIA investigations identify misconduct by your employee(s).  When there are serious allegations of misconduct against an employee, trained investigators of the OIG/ OIA will conduct the investigation. Their findings and investigative report will be provided to the Proposing Official for your organization who will decide the type of action which is appropriate. In these cases, you will need to provide information to the deciding officials on the following Douglas factors: How the alleged conduct impacts the employee’s job, how it impacts your confidence in the employee’s ability to do the job, what adjustments that you have had to make to the employee’s work during the pendency of the investigation, any mitigating circumstances surrounding the offense of which you are aware, and your estimation of the employee’s potential for rehabilitation. It is very important that you make sure the Proposing and Deciding Officials have this information. INS has had actions reversed or reduced when actions were taken without consideration of this information. Even though you are not in a position to recommend action in these cases, you do have crucial information which will impact the proposal and decision in these cases.

 

Chapter 4

 

Delivering Discipline

The method which you use to deliver notices proposing or deciding discipline can influence the effectiveness of that discipline in deterring future misconduct. The following pointers can improve the effectiveness of your discipline:

1. Schedule the delivery for a time when it is likely to be least disruptive. You should make sure that you have sufficient time -to deliver the discipline without interruption. The appropriate time to deliver both proposals and decisions is dependent on the circumstances. Factors to consider in selecting a time include the type of work place, the personality of the employee, and the type of misconduct involved. It may be appropriate to provide the employee administrative leave for the remainder of the shift after consulting with higher level management. Needless to say, the notices must be delivered before the effective date of any suspension, downgrade, or removal.

2. If at all possible, the person signing the notice should also deliver the notice.

3. The notice should be delivered in private and arrangements should be made to prevent interruption.

4. There is no entitlement to union representation since you are not questioning the employee concerning conduct.

5. When delivering the notice, calmly explain the notice. Ask the employee if he/she understands his/her rights to respond or appeal. Do not engage in an argument over the merits of the case. When delivering a decision, where the action is less than removal, emphasize to the employee that you expect him/her to return to work fully committed to following the rules and that you will welcome him/her back as a full member of the team. Emphasize, however, that any further misconduct will not be tolerated and will likely result in more serious disciplinary action including possible removal.

6. Have the employee sign the Receipt copy of the notice. Emphasize that the signature does not indicate agreement with the notice’s contents, merely acknowledgment of receipt. If the employee refuses to sign, call in a witness. Write on the receipt copy, “Delivered to (name) on (date). Employee refused to sign. (Your signature) (Witness’s signature) (date/time).”

7. Sometimes you are unable to arrange personal delivery to an employee. This can occur where the employee is being removed for “excessive absenteeism” and is not at work, where the employee has been on administrative leave, or the employee is located at a remote worksite. In those situations, the notice can be delivered by certified mail. Another acceptable delivery method is personal service off the work site. If all else fails, you may tape the decision on the employee’s residence door. If any of the above options are used, a copy of the letter should be annotated to reflect the method of delivery. Another option is to deliver a copy of the decision to the representative designated by the employee. (Caution: The alternatives in this paragraph should only be used when personal delivery is not feasible.)

 

FREQUENT DISCIPLINARY SITUATIONS


There are some disciplinary situations which are frequently encountered by first level Supervisors. The following chapters provide guidance to you on dealing with these common situations.

Chapter 5

Attendance Related Problems

 

Absence Without Leave(AWOL) and Failure to Follow Leave Procedures, Employees are expected to be at work on time unless they have requested and obtained approved leave in advance. Exceptions are made for illness and during periods of emergency. When an employee is absent, has no leave scheduled, and does not contact the supervisor using established leave procedures, he/she may be considered Absent Without Leave (AWOL). Whether such an absence is finally charged as AWOL depends on the circumstances of the situation. If the employee returns to work with a valid reason for both the absence and the failure to contact the supervisor, leave for the period of the absence should be approved on a retroactive basis and no disciplinary action taken. In some instances, employees will have a valid reason for leave, but fall to follow proper procedures. In these cases, you would approve the leave and counsel the employee on the proper procedures to follow. If this has occurred more*- than once, you may consider appropriate disciplinary action such as an admonishment or a letter of reprimand for “failure to follow established leave procedures.” If there is no excuse for the absence, you should take appropriate disciplinary action for both AWOL and “failure to follow established leave procedures.”

This is an area where you need to exercise sound judgment. For example, during the early morning hours, an employee is notified his son has been involved in a serious car wreck and has been rushed to the hospital for emergency surgery. The employee hurries to the hospital and remains there all day. He is so distraught that he neglects to contact you. The next day, he returns to work and explains what happened. No action would be appropriate in this case. In another instance, an employee stays home with a daughter sick with the chicken pox. She did not notify you of her absence even though she was at home near a telephone throughout the day. The reason for the absence would be approved and she would be entitled to leave. However, counseling or a letter of reprimand is appropriate for failing to follow established leave procedures. In another instance, an employee decides it is such a beautiful day and that he would prefer to stay at home to work in his garden. He does not call to request leave. AWOL would be appropriate in this case. You should also take or recommend appropriate discipline which can include a letter of admonishment, a reprimand or a short suspension based on the individual circumstances.

Leave Abuse: Sometimes, an employee’s pattern of attendance has become a problem for the organization. Even though the reasons provided by the employee are plausible, the overall number of absences seem much too high. There may also be a pattern in the taking of unscheduled leave which leads you to believe that there may be abuse. Some indications of leave abuse are a low or non-existent leave balance for an employee with many years of service, frequent unplanned absences on Fridays, Mondays or near holidays, or absences every time that the employee is scheduled for an assignment which he/she does not like, such as giving a briefing.

In these cases, you need to counsel the employee about your concerns. As long as you are counseling the employee and not questioning him/her about conduct, the employee does not have the right to a union representative in this meeting. Advise him/her that you are concerned with the pattern of attendance. Using a calendar, show him/her the days on which unplanned absences were taken. Explain the impact these absences had on getting the work done and other employees. Advise the employee that you expect an improvement in attendance and that continued use of unplanned leave may result in your placing the employee on leave restriction. Discuss with the employee options for resolving problems contributing to the poor attendance such as unreliable child care or transportation. Explain that all future unplanned leave requests must be made directly to you or another person designated to approve the leave in your absence. Warn him/her that you will not automatically approve leave on an emergency basis in the future. If leave is disapproved, he/she will be carried on an AWOL status and could be subject to disciplinary action. Advise the employee if there is a personal problem which is contributing to the poor attendance, that the employee is encouraged to contact the Employee Assistance Program. Document your counseling in writing and give a copy to the employee. (See Appendix E).

If the employee continues to have attendance difficulties, issue a letter restricting the use of leave. The Leave Restriction letter requires that an employee provide satisfactory medical documentation for all sick leave or leave without pay (LWOP) due to illness or incapacitation for either the employee or a family member. Some Districts and Sectors require that a leave restriction letter be coordinated with higher level management. Assure that you have followed applicable local procedure before you issue such a letter. A sample restriction letter is also contained in Appendix E.

Continue monitoring the employee’s attendance. Verify that correct procedures were followed for each instance of absence. Do not approve leave where it would cause hardship to the work, except where competent medical evidence indicates the employee or a family member is truly incapacitated. Make sure that you are properly contacted, and the employee provides the needed documentation. If the employee’s attendance is improving, let him/her know. In any case, where the employee does not follow the procedures which you establish, place him/her on AWOL and follow through with appropriate discipline such as a letter of admonishment or a letter of reprimand.

Excessive Leave Without Pay Sometimes, you have an employee whose services you need on a full-time basis, but who has legitimate medical problems which preclude their availability for work. They have exhausted available leave balances and have taken substantial leave without pay (LWOP). While all employees are entitled to unpaid leave under the Family Medical Leave Act of up to 12 weeks in a calendar year where they have requested the leave and provided the necessary documentation, you need not tolerate an employee’s absence for an indefinite period of time. You may inform an employee that you will no longer be able to approve LWOP and you will be required to place him/her on an AWOL status. This disapproval should be based on work load requirements. It is important that you understand that it is not appropriate to take disciplinary action against an employee for absences which you have approved except under extremely limited circumstances.

Fraudulent Requests for Leave: Disciplinary action may also be appropriate where an employee obtains sick leave fraudulently, even where there is no prior history of leave abuse. For example, an employee calls in on a beautiful Friday morning saying that he has the stomach flu, and cannot possibly come into work. You approve sick leave. While driving to a checkpoint in your sector, you see the employee playing golf on a course which you pass. In this circumstance, you should confront the employee to obtain his story. If you are not satisfied with his explanation you should place him on AWOL and initiate appropriate discipline. Since this conduct involves fraud, you should also notify OIG/OIA of the incident.

Excessive Unauthorized Absence: May be charged when an employee simply chooses not to report to work over an extended period of time. Prior to taking action to remove an employee on this basis, you need to send him/her a letter directing him/her to report to duty and advising him/her that failure to report will be grounds for proposing removal action against him/her.

Leave for an employee who is incarcerated. Employees may request annual leave for periods of incarceration. Approval or denial is up to the employee’s supervisor and should be based upon whether the employee’s services can be spared. Normally, leave for incarceration will not be approved for periods of time exceeding a week because of the impact of the extended absence on the work. If leave is disapproved, the employee should be carried in an AWOL status and the employee removed if the absences are excessive.

Chapter 6

 

Misuse of Government Property, Vehicle, Credit Card, Time . Etc,

Employees are provided equipment and other tools to assist them in carrying out their Governmental functions. Sometimes, employees will improperly treat government equipment as if it were their own. Sometimes the lines between personal and official use blur. Employees are prohibited from using government property for personal business except where that use involves negligible additional expense to the government.

(See Appendix F)

Phones: It would be impractical to forbid employees to use telephones for necessary personal business that cannot be conducted outside of working hours. Examples of personal calls which can be accomplished on government phones include calls

(1)   to or from a child’s school,

(2)   to or from the home to verify a child’s safe arrival, and

(3)   to make or confirm an appointment with a physician. These calls must be short and can not incur additional costs to the government. It is not appropriate, however, to have long, chatty calls with friends or to conduct business such as selling Avon products on government phones or on government time.

Computers : Another type of equipment which is prone to. improper personal use is the computer. Government computers are not to be used to write a novel, keep records of personal finances, or play games - whether it be solitaire or more complex war games. Use of a government computer to conduct work for an outside business is also prohibited. Limited personal use of computers or other office equipment and library facilities are authorized where the cost to the Government is negligible. The occasional writing of a short letter during an employee’s lunch hour is permissible, while the writing of a book on the employee’s favorite hobby is not. In some cases, an employee who is taking work-related courses, may use the computer for school work. The key is whether there are any significant costs incurred. If so, the usage is prohibited. Another major concern in the use of the computer, is the improper use of data maintained in a government data base for personal reasons. Using information from a data base to find an address to set up a date or to check up on the criminal record of a neighbor or acquaintance is an invasion of privacy and a serious violation. Such a violation must be reported to the OIG/OIA for investigation.

Government Vehicles: The intentional misuse of a government vehicle is a serious offense with a statutory mandated penalty of a 30 day suspension without pay, [31 U.S.C. 1344 & 1349(b)]. Employees are not normally allowed to use government vehicles as transportation to and from the workplace. They can conduct errands which are incidental to the official use of the vehicle such as eating at a restaurant or stopping at a convenience store in route, but they cannot make a substantial deviation for personal reasons. A twenty mile detour to go to a scenic water front restaurant is not appropriate. Carrying unauthorized passengers such as family members or hitchhikers is also prohibited. These violations should be reported to OIA (Class 2 allegation).

Government Credit Cards: Employees are issued government credit cards to be used for expenses incurred in connection with official travel. They are not to be used for personal purchases, whether at home or while on travel. Employees agree not to use the card for personal purchases when they apply for the cards. Appropriate uses include air tickets, hotel expenses, restaurant meals, rental cars, gasoline and taxi/limousine fares where these expenses are incurred in connection with official travel. Using the credit card for the same expenses for personal travel is not authorized. Similarly, personal expenditures while on official travel such as clothing and toiletry purchases, entertainment, and personal transportation for sightseeing are not to be charged to the government card. Employees are encouraged to carry a personal credit card to cover such charges. Audits are conducted to assure appropriate use of the cards. Substantial expenses incurred near home or at retail stores such as J.C. Penney’s or Sears tip off the auditors to inappropriate charges. If the employee is unable to show that the purchase was for official business, disciplinary action will be recommended. If you become aware of an employee making inappropriate use of a government charge card, you should report this to OIA (Class 3 allegation).

This has become one of the most common bases for disciplinary action in INS. As a supervisor, you can save your employees embarrassment, if you remind them of the restrictions on the cards. It is particularly helpful to remind them of these restrictions immediately before travel, especially if the employee has not traveled recently. Also, if your employees frequently travel, you should periodically remind them of this requirement.

Employees are also expected to timely pay their outstanding balances on the government credit card. If they cannot make a payment on time, perhaps due to late payment of a travel voucher, they should notify American Express and make arrangements for a delayed payment, They should also not carry balances over from month to month. Failure to pay this government-connected bill could be a basis for a formal disciplinary action.

Government Time: Every employee should provide a full day’s work for a full day’s pay. Employee’s must not use official time to sleep, read novels, play games, or conduct outside business. Employees do and can occasionally chat about their families and the latest, ball game, but such conversation should not be prolonged so as to interfere with the accomplishment of the work. As a supervisor, it is your responsibility to make sure that employees have enough work to keep busy and that they do not spend government time in non-productive pursuits.

Setting the Example. Your example is particularly important in assuring that there is no misuse of government time, property, or vehicles. If employees observe you conducting personal business on government time and equipment, they will consider this acceptable behavior and do so also. In some situations the problem is office wide, while at other times, only one individual is involved. If there is a problem throughout the office, you need to notify your employees in a staff meeting or by other appropriate means of the behavior You expect, An individual employee whom you observe in misuse should be orally counseled as a minimum. If the behavior Continues, you should initiate more stringent action, such as a written admonishment or letter of reprimand. These actions should clearly state that further such action will result in more serious discipline. This should be sufficient to stop most misuse situations. If there are further instances of’ misuse, you should investigate and recommend appropriate further discipline. Intentional misuse of a government vehicle should be reported to OIA.

Unauthorized Removal of Government Property (Theft): If you have any reason to believe that one of your employees has stolen or taken government property and converted it to his/her own use, you should report the information which you have to OIG/OIA for investigation (Class I allegation). Once an investigation confirms that property was taken, a disciplinary action for “unauthorized removal of government property” is appropriate. Disciplinary action for “theft” is seldom taken since it requires proof of intent to permanently deprive the government of the property which can be difficult to prove. The penalty selected will vary depending on the value of the property, the position held by the employee and employee contrition.

Chapter 7

 

Insubordination/Failure to Follow Supervisory Instructions

 

Insubordination: Subordinates are obligated to follow the proper orders of supervisors. Subordinates cannot decide for themselves what they will and won’t do after they have been given proper and explicit supervisory instructions. If the employee is displeased by his supervisor’s instructions, except in unusual circumstances, ‘he/she is expected to comply first and grieve later.

When faced with a situation of possible insubordination, you need to ask three questions:

1.Were instructions (orders) clear and complete so that the employee could understand and follow the directions? 2 Are the instructions proper? An order which requires an employee to do something that is immoral, illegal, unsafe, a violation of regulations, or requiring a feat beyond his/her capabilities is not enforceable.

3. Was the employee’s failure to comply intentional? Employee remarks such as, “You can’t make me do that!” or “Hell, no, I am not going to do that!” show intent to disobey the order. To take action for insubordination, you must be able to answer yes to all three. A formal disciplinary action such as a letter of reprimand or a suspension is appropriate for a first offense of a deliberate refusal to follow an explicit and proper order.

When an employee’s words or body language communicate that he/she intends to disobey your instructions, you may call in another supervisor as a witness and give the employee a direct order. Including in your instruction the words, “direct order,” can remove any doubt as to whether the employee knew that your request was an order.

Failure to Follow Instructions: However, there are some cases where the direction was clear and proper, the employee did not follow it, but you cannot prove that the failure to follow the direction was intentional. It appears the employee didn’t follow through due to such reasons as inadvertence, incompetence, obstacles created by individuals beyond the employee’s control, or poor time management. In these cases, counseling is appropriate in the first instance. Talk to the employee about the direction which you gave to make sure that he/she understood it. Find out from the employee why the direction was not followed. Work with the employee to remove any barriers to following through with the directions. Make sure that the employee clearly Understands what is to be accomplished and when. Document your discussion in a letter of counseling and provide a copy to the employee. Monitor the employee to make sure the direction is followed. If the employee continues not to follow your directions, YOU may request formal action be taken against him/her.

The line between conduct and performance can blur in cases involving the failure to follow instructions. An alternate approach, where the failure is connected to one of the employee’s critical performance elements and the problem involves a general failure to perform rather than a single instance, is to place the employee on a Performance Improvement  Plan. If you have this situation, contact your servicing Employee/Labor Relations Office for assistance.

Lax Completion of Directions:     If an employee carries Out an order grudgingly and deliberately does the work improperly or delays completion beyond a reasonable time disciplinary action may be considered for “Failure to properly carry out assigned work” or “Unreasonable delay in carrying Out assigned work.”

Disruptive Conduct at Work

Disruptive conduct at work can take many forms. Some are very minor, while others are very serious. All, however, should be dealt with immediately and consistently. If minor disruptive comments by an employee are ignored, the behavior can escalate and create conflict throughout the work force and even cause physical violence. Such conduct can include inappropriate remarks, personality conflicts, threats, and fights.

Inappropriate Remarks: There are a wide range of comments which employees make which are inappropriate in the work force. These comments can include rude remarks to customers and co-workers, vulgar language and profanities, remarks which demean individuals or groups because of their race, national origin, religion, sex, age, color, disabling conditions etc., and expressions of disgust concerning customers, co-workers, superiors and subordinates. Such comments are easy to ignore, but if left alone, can create a work place environment which no INS employees should have to tolerate. Your failure to deal with such problems can lead to subordinates filing EEO complaints and/or grievances against you for not correcting the problem, complaints by customers, disciplinary action against you, high attrition as employees escape a poisoned work environment, and a reduction in productivity as employees grouse and gripe among themselves.

This is one area where your example is crucial. If you use language which is rude, vulgar, demeaning, or disgusting, your subordinates will consider the behavior acceptable and engage in it also. Also, you will lose good employees who will look for other jobs where they do not have to tolerate such language.

Immediate correction of subordinates is essential. When you hear an employee use inappropriate language or learn of such a remark being made, you should call the employee aside and privately counsel him or her that such language is inappropriate. If the employee continues to make such inappropriate remarks, you need to begin the process of progressive discipline. In disciplining an employee, you need to focus the attention of the employee on the wrongfulness of the conduct and work on gaining his/her commitment to improving. There may be some instances where the comments create embarrassment for the agency or are accompanied by gestures and a tone of voice which warrant more serious discipline. In any instance, you should include in your discipline, a warning to the employee that the comments are unacceptable and that further such statements could lead to more stringent discipline.

Personality Conflicts: Sometimes your employees simply do not get along with each other. They come from different backgrounds, with different standards and work ethics, and have different (or too similar) personality styles. This can cause conflicts which interfere with work accomplishments. As a supervisor, it is your responsibility to identify these problems and take action to assure that your subordinates work together civilly.

Some symptoms of this problem include:

(1)   employee complaints that a fellow employee is a jerk, lazy, creepy, nasty or mean,

(2)   sulking behavior,

(3)   tattling and complaining to you about another employee by one or more of your employees,

(4)   loud and cross conversations between employees, and

(5)   requests by one of tile employees for you to take his/her side in a personal dispute.

In intervening in such a problem, you need to be careful that you do not appear to be taking the side of one or the other of the employees. You also must work with them to open their lines of communication, assist them in developing a solution which resolves the problem, and identify how your own behavior may be contributing to the problem. Taking classic disciplinary action is unlikely to resolve this problem by itself

You may want to consider mediating the dispute between the involved individuals. You need to. get the two of them together to find out what the problem is and have them develop solutions. You should make sure that you have ample time for this discussion, and that you will be free of any interruptions. You should open the session by advising the involved employees of your observations which concern you and how you feel that it is affecting their work. You should than ask each one what the problem is from his/her perspective. While an employee is giving his/her version of the problem, you should listen carefully without interruption. When the employee pauses, paraphrase what he/she has told you and ask whether this is what was meant. Watch the reactions of the other employee. Proper reading of body language can help you to identify the major areas of disagreement. Also, reduce the interruptions from the other employee while an employee is presenting his/her side of the story. Ask questions to clarify the information presented. After one employee has vented his/her concerns, ask if there are any more. Then give the other employee the same opportunity to voice his/her concerns. If one of the employees is reluctant to participate, you should ask further questions. You can also consider talking to employees alone, with the understanding that both will have the same opportunity to talk with you alone and that any solutions will be worked out jointly. After each employee has given his/her side of the story, ask each of them how you may have contributed to the problem. Then have them brainstorm alternatives for resolving this problem. Have them work out a solution to the problem. Make sure that the solution is something that you and other employees can live with. Write down what each of them and you agree to do. Have them sign a summary of the action plan and hold them accountable to that plan.

It is possible that an employee may consider your questions to be on a matter for which discipline can be taken and may request union representation. You can either permit the union representative to be present or discontinue. Also, so long as the discussion is limited to matters between the two employees, it is not a matter involving general working conditions and the Union need not be present. If a problem is so large that it involves several employees, you may have a meeting involving general working conditions to which you should invite a union representative. Also, if a grievance has been filed by one of the employees implicating the other, a union representative should be given an opportunity to attend.

Another alternative which may be used in very sensitive, confusing, or controversial cases, is employing the services of a professional mediator to assist in resolving this problem. You should check with higher level management and your servicing Labor/Employee Relations specialist if you would like to consider this option.

In this meeting, one or both employees may admit to a personal problem such as alcoholism or family problems which is contributing to his/her behavior. If this is the case, you should defer any discussion of the personal problem to a private meeting with that employee. At the private meeting, you should refer the employee to the Employee Assistance Program.

Personality conflicts are fairly common, require sensitive handling, and can escalate into much more serious problems if not resolved in the early stages.

Threats: Any communicated intent to inflict physical or other harm to a person or property is a threat. However, it is important to distinguish between idle talk (jokes) and genuine threats. A person who laughingly tells a co-worker, “Sometimes I just want to kill my boss when he rejects my work” is probably not communicating a threat, but merely expressing frustration. An actual threat occurs when threatening remarks are accompanied by behaviors which a reasonable person would consider an intent to carry through with the threat, and the listener perceives the statement as a threat. In determining whether a threat occurred, you need to determine

(1)   the listener’s reaction,

(2)   the listener’s apprehension of harm,

(3)   the speaker’s intent,

(4)   any conditional nature of the statements, and

(5)   the attendant circumstances.

If the listener does not perceive the comments as a threat, there probably is no threat, even when the literal language appears threatening. If the listener is not concerned by the remarks, believes that the speaker was blowing off steam or otherwise takes no action to protect himself or others from the threat, the actions will not be considered a threat. Such statements are, however, disruptive and should be handled in the same manner as other disruptive remarks (see above). When the listener is fearful and takes protective measures, a threat is likely to be found. Examples of protective measures include:

(1)   avoiding the speaker,

(2)   notifying the police,

(3)   carrying a weapon when lie/she would not normally do so,

(4)   installing security devices, or

(5)   requesting a restraining order. The speaker’s intent can be determined from the actions accompanying the statement. Was lie angry? Loud? Glaring? Did he use hand gestures in a threatening manner such as punching, chopping, stabbing or shooting motions? Does he have the capability to follow through on the threat? Is he stalking or following the person whom he indicates he will harm?

As a supervisor of an employee who has communicated a threat, you first need to take immediate action to protect your employees. If you hear an employee make a threat or are advised that an employee is threatening others, you should make sure that appropriate security personnel are notified. You should talk to the threatening person calmly and stall for time, while maintaining eye contact and listening attentively to his/her concerns. Be patient and courteous, while not making any sudden moves. If the employee is threatening you or others with a gun, knife, or other weapon, follow his/her instructions. Do not try to grab the weapon. Watch for a safe chance to escape to a safe area. After the incident has been resolved, notify higher level management and OIG/OIA for investigation (Class I allegation). It is also appropriate to remove the employee from the work site, and provide administrative leave for the remainder of the day. You need to make sure that appropriate measures are taken to protect yourself, other employees, and customers. You also will want to refer the threatening employee to the Employee Assistance Program. Assistance from the Employee Assistance Program for the employees who witnessed or were the target of the threats should also be requested.

Threats are very serious and may be the basis for a removal action even for the first offense. During the investigation, you may want to keep the employee away from the workplace. You cannot force an employee to take annual leave, sick leave or LWOP , but if he/she requests it, you may approve the leave. If the employee does not request leave, you may consider granting administrative leave to the employee in accordance with Regional or other governing policy, or assigning him/her to other duties where he/she will not constitute a threat to others. At a minimum, you should relieve the employee from any duties requiring the use of weapons. Another option that can be considered is the use of an indefinite suspension. You should consult your servicing Labor/Employee Relations officer, security personnel for your worksite, and higher level managers in determining appropriate action to take during the pendency of the investigation.

Fighting: Physical altercations between employees are serious offenses warranting discipline. Such attacks are also criminal violations (Class I allegations) and should be reported to OIA/OIG for investigation in all instances. Such fights can include fist fights, slapping, biting, stabbing, and throwing objects at each other. In such instances, you should call security personnel to break up the fight. Also notify higher level management. In evaluating the information concerning a fight, you will need to determine if the fight was provoked by actions or comments of the person who appears to be the victim. Such actions will also be a basis for discipline. Just as in cases of threats, you will need to consider whether you want to keep a violent employee(s) out of the work place during the conduct of the investigation. (see above).

Chapter 9

 

Misconduct towards or with Aliens

Any allegation that an employee is abusing an alien or engaging in an inappropriate personal relationship with an alien is very serious. If you receive any information that your subordinates have engaged in such behavior, you should immediately notify OIG/OIA (Class I allegation) and higher level management. You should also take action to assure the employee will have no contact with the alien(s) involved during the pendency of the investigation. If the investigation supports that such violations occurred, major adverse action up to and including removal, is appropriate.

Chapter 10

 

Falsification:

As a supervisor, you have a right to expect your employees to be honest, trustworthy and candid. Falsification of a government document or providing of false information to supervisors or investigators strikes at the very heart of the employee/employer relationship. Complete truthfulness by a law enforcement officer is especially crucial, since his/her testimony at a trial or hearing could be impeached if there is any record of falsification.

A disciplinary action for falsification or fraud requires that the information be inaccurate and that the employee intentionally provided false information. Action can also be taken when the employee provided inaccurate Information with a “reckless disregard for the truth.” Falsification can be found in many types of government documents which an employee completes. These include job applications, questionnaires for sensitive positions, time and attendance records, leave requests, travel vouchers, workers compensation claims, incident reports, investigation statements, and accident reports. Many of these forms, such as travel vouchers and time and attendance records, require supervisory approval before submission. If you approve a form as true and correct. when you have reason to believe otherwise. you could also be subject to falsification charges. As a supervisor, you should carefully review such documents. If you notice a discrepancy, you should ask the employee for clarification. In most cases, the errors are inadvertent and the employee will quickly correct them. In such cases, counsel the employee on the importance of paying attention to detail. If the employee refuses to correct the error or you discover later that the employee may have submitted a fraudulent document, notify OIG/OIA (Class I or Class 2 allegation depending on circumstances) and request an investigation.