civil service evaluation: the evolving role of the u.s. office of

Civil ServiceEvaluationThe Evolving Role of theU.S. Office of Personnel Management

A Report ConcerningSignificant Actions of theU.S. Office of Personnel Management

A REPORT TO THE PRESIDENT

AND THE CONGRESS OF THE UNITED STATES

BY THE U.S. MERIT SYSTEMS PROTECTION BOARD

U.S. Merit Systems Protection Board

Ben L. Erdreich, Chairman

Beth S. Slavet, Vice Chairman

Susanne T. Marshall, Member

Office of Policy and Evaluation

DirectorJohn M. Palguta

Project ManagerHarry C. Redd III

Project AnalystsKaren Gard

Keith BellLigaya Fernandez

Bruce Mayor

ii CIVIL SERVICE EVALUATION: THE EVOLVING ROLE OF THE U.S. OFFICE OF PERSONNEL MANAGEMENT

A REPORT BY THE U.S. MERIT SYSTEMS PROTECTION BOARD iii

Civil Service Evaluation:The Evolving Role of the U.S. Office of Personnel Management

Contents

Executive Summary .......................................................................................................................................... v

Chapter 1. Introduction ................................................................................................................................... 1

Purpose of the Study .................................................................................................................................... 1

Background .................................................................................................................................................. 1

Information Sources and Methods............................................................................................................. 2

OPM Review and Comment ....................................................................................................................... 2

Chapter 2. How The Program Operates and What Has Changed ........................................................... 3

Structure ........................................................................................................................................................ 3

Operations .................................................................................................................................................... 4

Focus ............................................................................................................................................................. 5

Methods ........................................................................................................................................................ 5

The Role of Field Components ................................................................................................................... 6

Added Oversight Activity ........................................................................................................................... 7

Use of Statistical Information ..................................................................................................................... 7

Internal Communications ........................................................................................................................... 8

Chapter 3. Resources Committed to Oversight ........................................................................................ 11

Chapter 4. Today’s Oversight Program Goals: Context and Status ....................................................... 13

Goal: Protecting and Promoting a Merit-Based Federal Civil Service .................................................. 13

OPM Leadership and the Agencies’ Role .......................................................................................... 13

Regulatory Compliance and Results Versus Process ....................................................................... 14

Beyond Compliance .............................................................................................................................. 17

iv CIVIL SERVICE EVALUATION: THE EVOLVING ROLE OF THE U.S. OFFICE OF PERSONNEL MANAGEMENT

Goal: Identifying Opportunities for Improving Federal Personnel Policies and Programs .............. 18

Improving HRM in a Results-Oriented Environment....................................................................... 18

Governmentwide Improvements ................................................................................................ 19

Agency Improvements ................................................................................................................. 20

Increased Effectiveness in Influencing HRM Improvements ........................................................... 21

Sharing MSO&E’s Information ................................................................................................... 21

Strengthening Self-Assessment................................................................................................... 22

Goal: Helping Agencies Meet Mission Goals Through Effective Recruitment, Development, andUtilization of Employees ............................................................................................................................ 23

Defining “Help” .................................................................................................................................... 23

Improving Oversight Unit Capabilities .............................................................................................. 24

Personnel .......................................................................................................................................... 24

Reports .............................................................................................................................................. 24

Improving Information Sharing to Help Agencies Meet Their Goals ............................................. 25

Chapter 5. Continuing Challenges to Effective Oversight ........................................................................ 27

Focusing on Results .................................................................................................................................... 27

Evaluating Without Clear Standards ....................................................................................................... 30

Accountability and Authority: The Line Manager/Personnel Office Relationship .......................... 31

Limitations of HR Staff Numbers and Quality ........................................................................................ 34

Increased Reliance on Automation ........................................................................................................... 35

Chapter 6. Conclusions and Recommendations ........................................................................................ 37

Conclusions ................................................................................................................................................. 37

Program Goals ................................................................................................................................. 37

Challenges to Goal Accomplishment............................................................................................ 38

Recommendations ...................................................................................................................................... 39

Appendix OPM Comments ........................................................................................................................... 41

A REPORT BY THE U.S. MERIT SYSTEMS PROTECTION BOARD v

Executive Summary

The Government’s program to oversee Federal personnel systems has existed in some form sinceWorld War II, when rapid expansion of the civil service necessitated the delegation of personnelauthorities to individual agencies. Today the law requires the U.S. Office of Personnel Manage-ment (OPM) to assure that Federal agencies operate their human resources management pro-grams in accordance with the standards of fairness, efficiency, and objectivity embodied in thelaw’s merit system principles. To do this, OPM maintains an oversight program that monitorsthe effectiveness of Federal personnel laws, regulations, and policies, and agency compliancewith them.

The program has undergone many changes over the years, the most recent a 1995 reorganiza-tion that focused attention on the importance of the merit system principles to Federal personnelactivities. Because the oversight program is important to OPM’s mission and to the health of thecivil service, and because significant changes in human resources management are challengingthe program’s effectiveness, the U.S. Merit Systems Protection Board (MSPB or the Board)undertook a study of how, and how well, OPM performs its oversight function.

The study findings reveal an oversight program much improved since 1992, when the Boardlast reviewed it. At the same time, certain refinements are still needed, such as more consistencyin the evaluation approach among field divisions, better use and dissemination of informationobtained in the course of oversight activities, and development of ways to focus oversight atten-tion on line managers as their personnel authority continues to expand. This report discussesour findings, describes the continuing challenges to the oversight program, and suggests actionsthat OPM’s director and department and agency heads can take to improve the Government’ssystem for assessing human resources management.

In 1995, the Office of Personnel Managementestablished a new organization responsiblefor a redesigned and revitalized program foroverseeing human resources managementsystems in Federal departments and agencies.The new OPM component, the Office ofMerit Systems Oversight and Effectiveness(MSO&E) was created from several existingOPM units and given responsibility for threecritical goals:

n To protect and promote a merit-basedFederal civil service;

n To identify opportunities for improvingFederal personnel policies and programs;and

n To help agencies meet mission goalsthrough effective recruitment, development,and utilization of employees.

To understand the effects of OPM’s organiza-tional changes and the results of MSO&E’sassumption of these roles, the Board obtainedinformation through reviews of OPM evalua-tion reports; a focus group meeting withdepartment and agency representatives;interviews in the Washington-Baltimore,Atlanta, and Chicago metropolitan areas; asurvey of the agency members of the Inter-agency Advisory Group Committee on Ac-countability; and a survey of senior human

vi CIVIL SERVICE EVALUATION: THE EVOLVING ROLE OF THE U.S. OFFICE OF PERSONNEL MANAGEMENT

resources management (HRM) officialsthroughout the Government.

We found that reorganization of OPM’soversight program has significantly changedthe program’s internal structure and methodsas well as its external effects and image.Although much of the change has beenpositive, it has been accompanied by internalproblems in consistency and approach thatOPM continues to wrestle with. Externalpressures and trends in current Federalhuman resources management are alsoaffecting the manner and success with whichOPM is performing oversight.

Findings1. OPM’s oversight program enjoys a highdegree of top-management support withinOPM, and a generally improved imageamong Federal agencies.

Structural changes within OPM have giventhe oversight function far better access toOPM’s director than in the past, and fundingfor the oversight program comes from theagency’s appropriations, rather than throughthe sale of staff members’ services to otheragencies. These changes are indicators of thefunction’s elevated position within the OPMmission. OPM has also expanded the over-sight program’s coverage to include subjectsof specific interest to the organizations beingevaluated, rather than relying exclusively onan OPM agenda for agency HRM reviews.This approach has increased the program’svalue to agencies and has consequentlyincreased their acceptance of it.

2. Agencies believe that OPM’s success inachieving the program’s three stated goalshas been uneven.n For the goal of protecting and promot-ing a merit-based Federal civil service, 52percent of the 23 departments and largestindependent agencies rated MSO&E’seffectiveness as “very great” or “consider-able.”

n For the goal of identifying opportunitiesfor improving Federal personnel policies

and programs, 26 percent rated MSO&E’seffectiveness positively.

n For the goal of helping agencies meetmission goals through effective recruitment,development, and utilization of employees, 22percent gave a positive rating.

3. The abolishment of OPM regions in 1995has led to a number of improvements in theway oversight field components are used,but there remain issues of consistency inapproach and philosophy that OPM contin-ues to address.

As a result of restructuring, organizationallines within the oversight function have beenclarified. Field divisions are now given re-sponsibility for review of an entire agency(rather than geographically defined compo-nents), and field division staff participate inreviews in geographic areas other than theirown. These changes permit adjustments instaffing or other resource needs and haveprovided the opportunity for field office staffto demonstrate their abilities and versatility.The changes have also contributed to anoversight program goal of “one program, oneteam.” This goal, however, is a work inprogress because it involves the formidabletask of transitioning from the varying philoso-phies of six former regional oversight unitsinto one uniform approach to oversight.

4. Oversight program effectiveness isinfluenced by a number of environmentaland philosophical issues that have arisen inthe HRM community and the Federal work-place as a whole. These are:

n Emphasis on measuring programsuccess on the basis of results rather thanprocess. This requires balancing the flexi-bilities managers need for achieving theirdesired program results against the focus onprocess that remains essential to complyingwith certain legal and public policy require-ments (such as reductions in force or veter-ans preference in hiring, both of which areheavily process-driven).

n The need for clear standards. Withthe focus on results comes the need to

A REPORT BY THE U.S. MERIT SYSTEMS PROTECTION BOARD vii

determine what should be measured andthe challenge of developing objective mea-surement standards. Because so manyaspects of HRM seem to lend themselvesbetter to subjective assessment than toobjective measurement, this is a particularlydifficult undertaking.

n The shifting locus of HRM account-ability. Since its inception, the oversightprogram has focused on the personneloffice as the point of accountability forhuman resources management. But thetrend towards delegating HR (humanresources) authorities to line managers ischallenging that tradition. Oversightprocedures and practices that focus heavilyon the personnel office will not work wherethe line managers and supervisors areactually making the HRM decisions and areresponsible for their consequences. Thus, itis time to begin developing an over-sightapproach that focuses on the line manager.

5. Although agency heads have a statutoryresponsibility to assure internal compliancewith HRM laws and regulations, oversightof agencies’ HRM programs continues torest primarily—if not exclusively, in someagencies—with OPM.

An overall diminution in agencies’ capacityto carry out their own internal assessment ofHRM is apparent since the Board last re-viewed the oversight program in 1992, with aconcomitant increased risk of errors thatcould damage mission accomplishment andharm the merit-based civil service. Manydepartments and agencies find it hard tomaintain an internal oversight capability inthe face of staff and budget reductions thatgenerally have been disproportionately largein personnel offices, leaving few HR profes-sionals to engage in oversight work. Thus,OPM’s oversight program represents the onlyHRM evaluation that some agencies have,and OPM’s program is spread thinly.

6. Efforts to develop agency self-assess-ment programs lack visibility and receiverelatively little attention from OPM’soversight field staff.

Although OPM worked with agencies sched-uled for HRM reviews in 1998 to develop self-assessment capabilities, and the product theydeveloped is available as a model for others,these efforts were virtually unknown amongagency officials interviewed for this studyoutside the Washington, DC, area. Neitherinternal agency communications nor informa-tion provided by OPM has resulted in thewidespread education of agency field activi-ties about HRM self-assessment. Further,OPM oversight staff in the field are not well-attuned to what OPM headquarters staff isaccomplishing with regard to agency self-assessment efforts, nor are they spending anyappreciable time or effort on them duringtheir agency reviews.

7. The quality of analysis and presentationin OPM’s oversight reports is uneven; inparticular, some executive summaries arewritten in positive terms that are subse-quently contradicted by the description ofproblems and weaknesses in the bodies ofthe reports.

Although more recent reports generally arean improvement over earlier ones, we stillhave a concern that if busy agency managersread only executive summaries, they maycome away with a misleading sense of pro-gram well-being. This could make it difficultfor subordinate managers to initiate changesthat the more detailed text of the reports mayindicate are needed or desired.

8. OPM program offices appear to be incon-sistent in their use of information gatheredby evaluators.

Evaluators regularly provide feedback toOPM program offices, whose officials use thisinformation to help monitor agencies’ under-standing and implementation of OPM pro-grams and to identify areas that need clearerguidance. However, repeated references inoversight reports to a problem do not guaran-tee that OPM will respond with a change inFederal HRM policy or practice. And anyabsence of visible outcomes reflects negativelyon the oversight program and agencies’judgments of it.

viii CIVIL SERVICE EVALUATION: THE EVOLVING ROLE OF THE U.S. OFFICE OF PERSONNEL MANAGEMENT

9. Information that evaluators obtain aboutagencies’ HRM practices is disseminatedinconsistently and relatively infrequently.

MSO&E publishes “Oversight Notes” quar-terly, but the manner of distribution variesamong the field divisions. Information aboutagencies’ exemplary HRM practices is some-times shared with agencies’ top field manag-ers and sometimes with their HR officials, butnot consistently with both. Information onworst practices is not shared with agencies,although OPM has tentatively decided to dothis.

RecommendationsThe following recommendations are forconsideration by the Director of OPM:

1. Continue to lead in the development ofbetter means of assessing Federal HRM onthe basis of results, and in developing thetools and training needed to measure HRMperformance.We believe the leadership effort must concen-trate first on ensuring consistency in howOPM’s oversight staff carry out their task, andthen on how OPM can contribute to thedevelopment of similar HRM assessment skillsin agencies through example, influence,training, and provision of effective tools.

2. Develop or lead in the development ofmeasurable standards to apply when evalu-ating HRM; in determining how best toassess “unquantifiables”; and in finding theproper balance between results and processin HR measures.Although measurable outcome standards areessential, there must be recognition that theproper application of process can be impor-tant to upholding laws or achieving publicpolicy goals.

3. Take the lead in changing the focus ofHRM accountability during oversight re-views from the personnel office to linemanagers and supervisors.

Unless accountability is focused on linemanagers, the risk remains that they will not

be held accountable for the consequences oftheir HR decisions.

4. To encourage agencies to implementeffective HRM self-assessment programs,consider using a delegations agreementapproach similar to that currently used forexamining.Specifically, develop standards and delega-tions agreements which, if agreed to by anagency in writing, would make the agencyresponsible (and accountable) for its ownHRM oversight, and would result in OPM’soversight role being largely one of supportingthe agency and periodically reviewing andaffirming the effectiveness of its oversightefforts.

5. Encourage the OPM oversight staff toshare information with agencies on best andworst HRM practices.This information should be shared with boththe HR community and with line managers,since our review identified problems withlimiting such sharing to only one or the otherof these audiences. We suggest making theinformation available through an OPM website, but not limiting the effort to this means ofdissemination.

6. Encourage other OPM program offices tomake timely and good use of informationprovided to them as a consequence ofoversight reviews, and encourage thoseoffices to share that information with de-partments and agencies as quickly andopenly as possible.

The following recommendations are forconsideration by managers in the Office ofMerit Systems Oversight and Effectiveness:

7. Involve the oversight staff more in thedevelopment and implementation of agencyself-assessment efforts.These are the OPM staff members who,working with staff in the Office of MeritSystems Effectiveness, can lead by exampleand who can offer practical advice and

A REPORT BY THE U.S. MERIT SYSTEMS PROTECTION BOARD ix

guidance on agencies’ efforts. The aim shouldbe a well-coordinated, cooperative oversighteffort involving OPM and the individualagencies.

8. With respect to each report that is therecord of an oversight review, monitorclosely the language and tone of the execu-tive summary to ensure that the summaryaccurately conveys the findings reported inthe text of the full report.Because top managers may read only theexecutive summary, it is essential that thesummary does not obscure whatever prob-lems are reported in the full report.

The following recommendations are directedto the heads of departments and independentagencies:

9. Cooperate with OPM in developing waysto assess HRM on the basis of results; in

developing the tools and training needed toaccomplish this change in how HRM’sperformance is measured; in developingmeasurable standards to apply in HRMassessment; in determining how best toassess the unquantifiable aspects of HRM;and in finding the appropriate balancebetween focusing on results and emphasiz-ing process in HRM reviews.

10. Examine the resource commitmentsyour organizations have made to HRM self-assessment, and determine whether thelevels of commitment leave you vulnerableto errors that could damage mission accom-plishment and harm the merit-based civilservice.Join with OPM in finding ways to hold man-agers genuinely accountable for their HRMdecisions and work with OPM in developinga cooperative oversight approach.

A REPORT BY THE U.S. MERIT SYSTEMS PROTECTION BOARD 1

n Recommendations we made in the 1992 report, andn The three goals OPM has articulated for its current oversight program.

The current report also examines ways inwhich recent trends in the delivery of Federalhuman resources services, coupled with linemanagers’ expanded HRM role, have com-bined to create significant challenges to thecurrent capabilities of OPM’s oversight pro-gram. The report concludes with recommen-dations that we believe will help OPM con-tinue its current improvements to its oversightprogram.

BackgroundOPM’s oversight program exists to fulfillcertain statutory responsibilities. The programhas existed in some form since the entry of theUnited States into World War II forced a rapidgrowth in the size of the Federal civil service.That rapid expansion forced OPM’s predeces-sor, the Civil Service Commission, to delegateto agencies personnel authority that previouslyhad been centrally administered. The over-sight program was established to ensureproper exercise of that delegated authority.Increased delegation of personnel authority toagencies—a goal of the U.S. Civil Service sincethe CSRA was passed, and a hallmark ofrecent Government reinvention efforts—hasstrongly influenced the tone of the oversightprogram and expectations for it.

Purpose of the StudyThe Merit Systems Protection Board is requiredby law to report to the President and theCongress on “the significant actions of theOffice of Personnel Management, including ananalysis of whether the actions of the Office ofPersonnel Management are in accord withmerit system principles and free from prohib-ited personnel practices.”1 This report, whichaddresses OPM’s effectiveness in overseeingFederal personnel systems and agencies’personnel programs, complies with thatstatutory responsibility.

This is the fifth Board report concerningOPM’s oversight program since the twoagencies were created by the Civil ServiceReform Act of 1978 (CSRA).2 Such extensivereview of this OPM program over a period ofjust under 20 years highlights two facts: (1)MSPB considers the program to be importantto OPM’s overall mission and to the health ofthe Federal civil service; and (2) the programhas undergone repeated, substantial changesduring this time. We consider it important tomeasure the effects of the most recent changes,particularly with respect to how—and howwell—they address concerns identified in ourprevious reports on this subject.

This report focuses on what has happened toOPM’s oversight program since our last (1992)report, with two points of reference:

1 5 U.S.C. 1206.2 The earlier studies are: U.S. Merit Systems Protection Board, “Civil Service Evaluation: The Role of the U.S. Office of Personnel

Management,” Washington, DC, November 1992; U.S. Merit Systems Protection Board, “U.S. Office of Personnel Managementand the Merit System: A Retrospective Assessment,” Washington, DC, June 1989; U.S. Merit Systems Protection Board, “Report onthe Significant Actions of the Office of Personnel Management,” Washington, DC, May 1986; and U.S. Merit Systems ProtectionBoard, “Report on the Significant Actions of the Office of Personnel Management During 1983,” Washington, DC, December 1984.

CHAPTER 1Introduction

2 CIVIL SERVICE EVALUATION: THE EVOLVING ROLE OF THE U.S. OFFICE OF PERSONNEL MANAGEMENT

In February 1995, the Director of OPM an-nounced an internal reorganization thatincluded establishment within his agency of anew component, the Office of Merit SystemsOversight and Effectiveness. The announce-ment noted that this new organization wouldbe responsible for the following three roles:3

n To protect and promote a merit-basedFederal civil service;n To identify opportunities for improvingFederal personnel policies and programs; andn To help agencies meet mission goalsthrough effective recruitment, development,and utilization of employees.

MSPB has waited for the leadership of thisnew OPM component to plan its direction andassert its style and philosophy over the rem-nants of the predecessor organization. Believ-ing that sufficient time had passed for theeffects of the changes to be observed, reported,and evaluated, we initiated this study in May1997.

Information Sources and MethodsInformation for this report came from severalsources. We administered two surveys: one toall 67 agency members of the InteragencyAdvisory Group Committee on Accountability,and one to the senior HRM official in each ofthe 23 Federal departments and largest inde-pendent agencies and in 27 smaller indepen-dent agencies or major components of cabinet-level departments. Departmental componentswere chosen for this survey from among thosethat had undergone a review by OPM sinceJune 1995 or that were scheduled for such areview during FY 1997.

We conducted a focus group meeting withrepresentatives from 7 departments andagencies, and interviews with more than 40individuals representing 15 agencies andagency components. The agency interviewswere conducted in the Washington-Baltimore,Atlanta, and Chicago metropolitan areas.

In addition, we interviewed nearly 40 OPMofficials and employees, including all MSO&Eheadquarters program managers, the over-sight division directors in Washington, At-lanta, Chicago, and San Francisco, and anumber of evaluators in the Washington,Atlanta, and Chicago oversight divisions. Wealso interviewed eight program managers inOPM’s Employment Service and HumanResource Systems Service, and the directorsand some staff members of the Atlanta andChicago service centers.

We read more than 90 reports prepared byOPM evaluators since the program changeswere initiated. During some agency inter-views, agency representatives discussed withus specifics of their organizations’ reviews,including information about compliance orother followup activity between the reviewingOPM office and their organizations.

Finally, we reviewed OPM’s “Strategic Planfor FY 1997-FY 2002” and an “FY 98 ProgramCoverage Guide” prepared by OPM staff incooperation with the eight agencies scheduledfor review in FY 1998.

Collectively, these sources provided a multifac-eted view of OPM’s current oversight pro-gram.

OPM Review and CommentA draft of this report was furnished to theDirector of OPM for review and comment byher and officials in the Office of Merit SystemsOversight and Effectiveness. A letter from theOPM director providing their comments isappended to this report. Where appropriate,our final report was adjusted to give dueweight to OPM’s comments.

3 Carol Okin, “Federal HRM Oversight Gets a New Start,” The Public Manager: The New Bureaucrat, Summer 1995, pp.20-22.


StructureBefore OPM’s 1995 reorganization, the over-sight program, together with the systemsinnovation and simplification, classification,labor relations and workforce performance,compensation policy, and workforce informa-tion programs, all reported to a single associ-ate director. The oversight program’s relation-ship with these other programs (many ofwhich had significant potential to raise high-profile issues), was marginal at best. Over-sight was not in a strong position to competewith these other programs for the attention ofits own associate director and thus theprogram’s officials were handicapped in theirability to raise issues to the OPM director.

Under OPM’s current organizational struc-ture, oversight is managed by one of threeassistant directors who inturn report to the associatedirector for MSO&E. Asshown in the chart, right, thisgives the oversight functionfar better access to OPM’sdirector than it has had in therecent past.

The three components thatnow make up MSO&E sharea better defined community ofinterest than existed underthe previous organization.They also share a focus on thethree goals that OPM hasestablished for the program,which are identified in the

introduction to this report. The oversightcomponent is by far the most resource-inten-sive, and also is the component most likely toraise high-profile issues. In such a setting, theoversight program should have no problemgetting and holding the attention of top man-agement, including that of the OPM director.

OPM’s Assistant Director for Merit SystemsOversight heads a staff of approximately 120employees who are organized into a head-quarters and 6 field divisions. This organiza-tion also includes a small group who specializein classification appeals and Fair Labor Stan-dards Act determinations.

Direct data analysis support for the oversighteffort is provided by the program analysisdivision, which falls under the Assistant

How the Program Operates and What Has ChangedCHAPTER 2

Associate Directorfor Merit Systems

Oversight andEffectiveness

Assistant Directorfor Merit Systems

Oversight

Assistant Directorfor Merit Systems

Effectiveness

OPM DirectorOPM Deputy

Director

Assistant Directorfor WorkforceInformation


Director for Merit Systems Effectiveness, whoalso directs the work of the program develop-ment division. This organization works withdemonstration projects and has the lead rolein developing self-assessment tools for agen-cies’ use.

The Assistant Director for Workforce Informa-tion heads an organization that was added toMSO&E in 1997. This organization is respon-sible for maintaining OPM’s GovernmentwideHRM data bases, including the Central Per-sonnel Data File (CPDF), and for providinginformation from those data bases to OPMcomponents and other organizations, includ-ing MSPB.

Within the Washington area, communicationand cooperation between the oversight andeffectiveness components appears excellent,and steps have been taken to integrate thenewly acquired workforce information groupinto the MSO&E organization. Oversight fielddivisions outside the Washington area enjoy agood working relationship with the programanalysis division of the effectiveness group, buttheir ties with the work of the effectivenessgroup’s other division (the program develop-ment division) are not so well defined.

OperationsThe oversight program currently is structuredso that OPM can assess the state of HRM in 23departments and major independent agencieson a 4-year cycle. In comparison, when welast reviewed the program, its comparable goalwas to review, on a 5-year cycle, every estab-lishment with 100 or more employees. Theprogram remains capable of conducting otherreviews as data or special requests dictate.And as we discuss later in this report, theprogram is also responsible for continuingreview of delegated examining.

In each year of the current 4-year cycle,several departments and independent agenciesare identified for review. (An undefinednumber of the smaller agencies also may bescheduled each year, as time and resourcespermit.) As each agency is identified for

review, a sample of suborganizations andinstallations sufficient to provide a completepicture of HRM at all organizational levels isprepared. Thus, in FY 1996 the review plancalled for evaluating 7 of the largest agencies,including 120 installation reviews. In FY 1997the plan called for evaluating another 8 of thelargest agencies, again including 120 installa-tion reviews.

While similar to OPM’s previous oversightmethods, this approach to scheduling isdifferent in a key way: work involving aspecific department or agency is concentratedand completed in a given year—an improve-ment for both the agencies involved and forOPM because it results in a comprehensivepicture of agency-wide HRM strengths andweaknesses.

There are other differences that distinguishOPM’s current approach from that of the past.One is that each year an evaluation agenda isdeveloped to obtain information about specificGovernmentwide HRM policies and practicesas well as substantial information about theagencies being reviewed. For example, duringthe FY 1997 review cycle, OPM’s evaluationplan called for the following topic areas to beexamined during all of the year’s reviews: useof incentive awards; appropriateness of non-technical training; appointments of newemployees from outside sources; internalplacements; and downsizing and careertransition activities.

Another difference from past practice is thatOPM staff now work with the agencies underreview to include items of particular agencyinterest in each review agenda. For example,at the Department of Commerce, the add-onto the department’s FY 1997 review was areview of the transformation of the roles andrelationships of HR professionals and linemanagers. Likewise, at the request of theDepartment of Agriculture, OPM addedpersonnel office servicing, streamlining at theDepartment, and partnership/complaintavoidance to the department’s FY 1997 re-view.


Including agency concerns in OPM’s oversightagenda increases the oversight program’svalue to the reviewed agencies. It also canlead to significant resource commitments bythe agency (e.g., when agency staff participatein planning the review or are assigned to thereview team), and opens the way for establish-ing or improving communications betweenOPM’s oversight component and the agencyinvolved.

FocusThe current program is focused on the statu-tory merit system principles much more thanin the past, a development that we find to bepositive because it helps to foster a broadperspective on Federal human resourcesmanagement and prevent a narrow, overlytechnical view. A strong effort is now made tolink all review activity, and all reported find-ings, to one or more of these principles. Thereports now include (in what is essentiallyboilerplate language about the expectedoutcomes) an explanation of how a particularprogram should contribute to accomplishingthe applicable merit system principle(s).

In theory this approach provides a clear linkbetween policy and procedural activity andthe legally expressed values that those policiesand procedures should support. However, asone agency representative observed, thecurrent effort to associate virtually every HRprocess or procedure with one or more meritprinciples creates the potential for trivializingthe principles. Quite simply, not all HR prac-tices and procedures have equal impact, andnot all serve to protect merit equally. Whilethe merit principles exhort agencies to goodbehavior in a variety of areas, not every aspectof HRM is easily associated with a specificprinciple (or multiple principles). And relyingso strongly on merit system principles as astructure for evaluation reports risks detract-ing from the reports’ value as a behavioralguide to line managers and HR officials.OPM’s oversight reports should clearly iden-tify the relative importance of issues theyaddress.

Having a sense for which aspects of HRM areof more or less consequence is particularlyimportant for line managers, who increasinglyare being recognized as the officials account-able for human resources management. Infact, in most cases, managers’ HRM responsi-bilities and accountability are increasing at thesame time that their access to professionalHRM advice and guidance is decreasing.

These managers need to know where to puttheir primary emphasis—which practices andprocedures are absolutely critical to the opera-tion of a merit-based HRM system. But byappearing to treat all procedures and practicesas equal, OPM’s oversight program runs therisk of desensitizing those managers to thetruly important core values and concerns of amerit-based civil service. Since fine-tuning ofthe oversight program is still going on,MSO&E management may find this a fruitfularea for further program refinement.

MethodsOnce the oversight agenda and review loca-tions are set for the particular agency beingreviewed, the review methods are determined.OPM relies heavily for prereview informationon statistical data drawn from its computerfiles, information obtained through contactswith its own program offices, and a question-naire that it administers, before going onsite,to a sample of managers, supervisors, andnonsupervisory employees of the agency. Theteam (which, at the option of the reviewedagency, may include agency personnel) usesthis prereview information to focus its efforts.OPM makes a strong effort to minimize re-quests for advance information from the sitesto be visited.

The onsite phase of each review—generallyscheduled for a week—includes interviewswith managers, supervisors, nonsupervisoryemployees, and staff in the personnel office.The team also reviews personnel records. Inthe end, the review team makes judgmentsabout the state of HRM at the facility andprovides information that is used in the com-posite report for the entire organization (de-


partment or agency). Each onsite review isfollowed by either an oral or written report offindings (often both) and may include bothrecommendations aimed at strengthening orimproving HRM and actions required tocorrect violations of laws, rules, or regulations.

During the onsite phase OPM’s evaluatorsmay function in multiple roles, including HRMprogram expert, consultant, and “policeofficer.” One notable characteristic of therevised oversight program is a change in therelative emphasis placed on each of theseroles, a change remarked on by most of theagencies that have been reviewed since 1995.OPM now emphasizes the consultant andhelper roles, acting in its enforcement role onlywhen absolutely necessary. Both in ourinterviews and in replies to our questionnaire,sources in the agencies indicated that thischange in emphasis—which produces a majorchange in program tone—increasingly isevident.

The current program contrasts with the pre-1995 program in other ways as well. Before1995, most of the program’s onsite activitywas conducted through 1- to 3-day “installa-tion assessment visits.” These short visits wereaimed primarily at “gathering personnelmanagement data to supplement those avail-able from OPM’s Central Personnel Data File(CPDF) and used for statistical analyses doneat OPM headquarters.”4 At best the visitsprovided OPM’s oversight staff a minimalpresence in agencies and were not highlyregarded by either the agencies themselves orby MSPB. Installation assessment visits are nolonger part of the program’s methods.In addition to planning and executing itsscheduled annual agency reviews, the over-sight component maintains a capability toconduct “as needed” reviews. These areusually triggered by the receipt of informationthat suggests either a systematic violation ofmerit system principles or the commission ofprohibited personnel practices in an agency.

While the initial information may come fromalmost any source, it typically originates inanother OPM component or with sourceswithin the affected agency. OPM does notspecifically hold back a portion of its oversightcapacity in anticipation of such reviews, butadjusts assignments to make staff availablewhen the need arises. This capacity is similarto the earlier program’s “targeted installationreviews,” which were focused, onsite reviewsused to address a very small number of situa-tions in which OPM perceived specific compli-ance problems at an installation or agency.5

The Role of Field ComponentsAnother key difference between the programof today and that of 6 years ago is in the roleOPM assigns to the field components in itsoversight organization. In the past, the over-sight program was centrally directed butlocally administered. That is, the headquartersstaff determined issues such as the scope ofreviews, organizations and installations to bereviewed, tools to be used in conducting thereviews, and the overall expectations for thetotal program each fiscal year. The actualreviews were carried out by the oversightcomponents in the five OPM regions and asixth operating oversight unit in Washington,DC. This top-down approach did little toencourage innovation outside headquarters.In addition, the regional structure left the fieldoversight components in the difficult positionof serving two masters—their program leader-ship at headquarters and their respectivesenior executive regional directors at the locallevel.

OPM regional boundaries had the effect ofconfining each group of field evaluators to aparticular geographic area and denied themthe opportunity to get to know agency compo-nents outside that area. And strong regionaldirectors placed their own imprints on theoperations of the oversight program withintheir respective jurisdictions. This changed in1995 with the abolishment of OPM’s regions.

4 U.S. Merit Systems Protection Board,“ Civil Service Evaluation: The Role of the U.S. Office of Personnel Management,”Washington, DC, November 1992, p. 6.

5 Ibid., p. 6.


Although that step reduced OPM’s presence inkey cities outside the Washington, DC area (apoint commented on both by agency represen-tatives and OPM staff during interviews), itdid clarify organizational lines within theoversight function and opened the way fordifferent—and improved—use of field evalua-tors. Now, each field division is routinelygiven responsibility for planning and execut-ing one or more of the agencywide reviewsconducted each year. Although geographi-cally still dispersed among the old regionalheadquarters cities (and in some few cases inother locations as well), team leaders from thevarious field divisions now lead teams thatmay include OPM staff from field divisions inother geographic areas. Likewise, staff fromone part of the country may now find them-selves participating in a review in what untilrecently would have been within the geo-graphic jurisdiction of another region.

These organizational and operational changespermit adjustments in staffing or other re-source needs and have provided new opportu-nities for field office staff to demonstrate theirabilities and versatility. These changes havealso contributed to the MSO&E associatedirector’s goal of having “one program, oneteam,” which alludes both to efforts to smoothout the inconsistencies among the formerregions and to her intent to make the work ofthe oversight and accountability componentscomplementary to each other. More will besaid about this goal later.

Added Oversight ActivityAs noted earlier, a further difference betweenthe current and old oversight programs isfound in a change in the organization respon-sible for review of delegated examining units(DEU). Acting for the OPM director, OPM’sassociate director for Employment Servicedelegates examining authority to an agency’stop personnel official. That individual maynot redelegate the authority but may certify aDEU to exercise the delegated authority.Historically, review of DEU activity has been a

responsibility of the OPM component thatconferred the delegated authority. However,recent decisions to fund the employmentservice component largely on a reimbursablebasis (meaning that this component mustsupport itself by selling its services to agencies)created a potential conflict of interest withregard to the employment service staff con-tinuing to review DEU activity. Consequently,DEU oversight was transferred to the over-sight organization. In addition to maintainingits general review schedule, the oversight staffmust also conduct periodic reviews of del-egated examining units. Where possible thesereviews are conducted as part of broaderreviews; often they are conducted indepen-dently of other oversight activity.

Use of Statistical InformationThe oversight program continues to relyheavily on information from the CPDF andother computer data base sources. Since ourlast review of this program, OPM has devel-oped relatively sophisticated data analysispackages and, through local and wide-areacomputer networks, has linked all oversightstaff with the evaluation data base. All evalu-ators receive training in the use of these tools.Prereview use of statistical and other comput-erized information helps focus each reviewteam’s onsite effort. Access to these data alsoreduces the volume of information OPMreview teams request from each installation oragency in advance of a review.

Another change in OPM’s oversight programpertains to one of the earlier program’s prod-ucts. When we last looked at the program,one of its major products was a statisticalsummary called the Personnel ManagementIndicators Report, or PMIR. The PMIR pro-vided aggregate data from the then 22 largestFederal departments and agencies on a varietyof personnel programs. It also rated andranked each agency against a standard score6

and periodically was sent to agency heads.One of its purposes was to provide the OPMdirector and staff with comparative data

6 Ibid., p. 6.


about the personnel programs in each of thelargest agencies.

We noted in our 1992 report that the PMIRwas viewed within OPM “as a major report tothe agencies on how OPM views the agencies’personnel management programs.” But wealso noted that most agencies did not assignthe degree of importance to the PMIR thatOPM did, and we recommended that OPMdiscontinue its distribution to agencies. OPMhas followed through on this recommenda-tion.

While still a tool of OPM’s oversight program,the PMIR no longer occupies the preeminentrole it had. Now it is used routinely onlywithin OPM, where Oversight staff prepare aparticular agency’s report and analyze it inadvance of the agency’s review. In addition toproviding current information concerningnumerous indicators, where organizationshave remained stable the report can provide asmuch as a 10-year historical view. And itremains available for use by agencies

Internal CommunicationsFinally, OPM’s reorganization has resulted intwo important improvements in internalcommunications, while some other improve-ments that should also be a consequence of thereorganization have not occurred. One im-provement already alluded to is the develop-ment of stronger links between the oversightand effectiveness staffs: “Oversight” is succes-sor to the agency compliance and evaluationstaff, while the “Effectiveness” organizationstems from OPM’s former Office of SystemsInnovation and Simplification. Originallytenuous, the links between the two organiza-tions have been strengthened by the reorgani-zation. The effectiveness staff currentlycomplements the oversight function throughhelping develop the evaluation agenda for thenext fiscal year’s reviews, and—using anInteragency Advisory Group accountabilitycommittee—by helping develop a self-evalua-tion approach that agencies can adopt oradapt for their own use. The oversight andeffectiveness staffs have also worked together

to identify ways to use available data toimprove the oversight program.

The other improvement is in communicationswith other OPM components: A good over-sight program should be the eyes and ears ofother program components in OPM. Andbecause it is difficult for generalist evaluatorsto remain up to date on the nuances andtechnicalities of all HRM programs, theireffectiveness at least partially depends uponinformation sharing between them and theprogram offices.

We interviewed a large number of OPMmanagers, both at headquarters and in thefield, who belong to organizational units otherthan Merit Systems Oversight and Effective-ness. We found that MSO&E shares its reportswith OPM program offices before publicationand that most of the program managers eitherpersonally read them, or have members oftheir staffs read and digest the reports forthem. MSO&E also shares its reports withOPM’s Office of the General Counsel when-ever there are unusual or potentially contro-versial findings.

OPM program officials outside MSO&E re-ported that information from the oversightreports improves their ability to monitor theagencies’ understanding and implementationof their programs and helps them identifyareas that need clearer guidance. This hasbeen particularly the case with respect toexternal staffing activity, where evaluators’findings have prompted employment servicestaff to provide delegated examining unitswith additional guidance on a variety oftechnical issues, and especially on alternativerating and ranking procedures.

Evaluators and managers in all of the over-sight locations we visited agreed that theevaluators have open communication to thevarious OPM program offices during theplanning, execution, and followup phases ofreviews. This was confirmed by the programofficials we interviewed. In addition, theoversight divisions and employment service


officials participate in monthly and as-neededconference telephone calls. While the primaryfocus is to keep evaluators informed of recentdevelopments in recruiting and hiring policiesand practices, these conference calls also giveevaluators a regular forum for discussingunusual or questionable staffing situationsthey have observed. This practice appears tohave helped both the oversight and employ-ment service programs. It should also bebeneficial to agencies since it helps ensure thatthey receive timely guidance and are mea-sured against consistently applied rules,regulations, and policies.

Along with these positive findings aboutinternal OPM communications, we encoun-

tered some negative comments. More than oneOPM program manager expressed concern thatthe evaluators were not keeping up to date onhow agencies interpret program regulations.For example, one OPM manager told us thatevaluators were continuing to review a particu-lar program from the perspective of strictcompliance with the language of the regula-tions, while the program office had been tellingagencies for more than 3 years that “if yourinterpretation is not specifically prohibited byour regulations, then you may do it.” The sameprogram manager also expressed disappoint-ment that MSO&E managers wait until afterthe onsite review to seek the involvement of theprogram staff.


One measure of a program’s importance is theresource commitment made to it. At ourrequest, OPM provided us information on thestaff dedicated to the oversight program, aswell as the salary and benefits money associ-ated with those staff resources. We asked thatthe information go back as close to 1992 (theyear of our last report on this subject) aspossible. As the table shows, OPM providedinformation for fiscal years 1993 through 1998:

Although OPM staff reported that these arethe best figures for the period, they raisedsome cautions about the numbers. For ex-ample, resources were tracked in differentways at different times during the reportingperiod. In some years reimbursable dollars forthe oversight function were lumped togetherwith reimbursements for other functions,making it impossible to separate out dollarsassociated strictly with oversight. Also, priorto FY 1996, oversight divisions in field loca-tions received funding from a number ofnonoversight functions such as labor relations

CHAPTER 3Resources Committed to Oversight

or performance management, meaning thatsome staff attributed to oversight divisionswere not always doing oversight work. Beforethe revitalization of the oversight function inthe second half of FY 1995, there was noparticular emphasis on close tracking ofresources or accurate recording of fund shiftswhen regional directors exercised their author-ity to reallocate dollars. Since then, however,oversight’s allocated staff and dollars havebeen carefully tracked.

Despite the imperfections in the records ofstaff and dollar allocations, the records do giveus a general picture of where the oversightprogram has been and where it seems to beheading. First, from FY 1993 to FY 1995 theprogram steadily lost budgeted dollars andunderwent staff reductions. Second, since theprogram was revitalized during FY 1995, ithas experienced a 28-percent growth spurt in1 year followed by 2 years of slow growth inan overall Government environment wherestaff and dollar reductions were the norm.

Oversight Program Staff and Salary-Related Dollar Allocations(Dollars in thousands)

FY1993 FY1994 FY1995 FY1996 FY1997 FY1998*

FTE** 134 115 88 113 117 121Dollars 7,730 6,933 5,716 7,549 8,042 8,672

______________________* FY1998 figures are projections.** Each “FTE” is a “full-time equivalent” position, or 2,088 hours of staff time in a

year, and may be filled by more than 1 person.


This is tangible evidence of OPM’s commit-ment to maintaining its oversight program.

Some observations about the effects of RIF’s(reductions in force) on the cost of the over-sight program are in order. Some—perhaps arelatively large—portion of the FY 1995 to FY1996 dollar increase resulted from vacantoversight positions being filled by staff mem-bers affected by RIF’s in other OPM units.One immediate effect of these placements—ofwhat usually were longer service, higher paidstaff members who often were experienced invarious personnel specialties, but not necessar-ily in evaluation techniques—was to increasethe oversight program’s salary costs withoutnecessarily providing an accompanyingincrease in the program’s effectiveness.

What is most significant is that the oversightprogram operates without the need to recoverits costs from other agencies. Its funding istotally from OPM’s appropriations, and itsstaff members are, therefore, not dependent

upon selling their services to departments andagencies to stay in business. According tointerviews we conducted for this study andresource information provided by OPM, thatwas not the case during the years immediatelypreceding the 1995 reorganization. Instead, atthat time, OPM found it necessary for part ofeach year to encourage its oversight staff toseek reimbursable work with agencies tosupport their jobs and salaries. In addition tolowering morale among the oversight staff(and contributing to the loss of experiencedevaluators who sought and found employ-ment elsewhere), that approach damaged theoversight program’s image. While the currentfunding approach and an increased oversightpresence have largely repaired this damage,we found that some agencies still questionwhether OPM’s oversight program can addanything of value to their HRM programs.These doubts may be attributed to some degreeto perceptions created by the program’sreduced presence and “wounded duck” imageof the early 1990’s.


As noted earlier in this report, the oversightfunction has three roles:

n To protect and promote a merit-basedFederal civil service;n To identify opportunities for improvingFederal personnel policies and programs; andn To help agencies meet mission goalsthrough effective recruitment, development,and utilization of employees.

The establishment of these three functions asthe goals of the oversight program is sup-ported in law, and the appropriateness of thegoals is reinforced by the human resourcesmanagement needs and environment—dis-cussed in the sections below—that exist inGovernment today.

Title 5 of the U.S. Code, in section 1103(a),makes the Director of OPM (or the director’sdesignees) responsible for enforcing the laws,rules, and regulations governing the Federalcivil service. The law also requires OPM to:

*** [E]stablish and maintain an oversightprogram to ensure that [personnel manage-ment activities] are in accordance with themerit system principles and the standardsestablished [by OPM].

5 U.S.C. 1104(b)(2)

Further, the law makes the OPM director ordesignees responsible for:

[A]iding the President, as the Presidentmay request, in preparing such civil servicerules as the President prescribes, and

otherwise advising the President on actionswhich may be taken to promote an efficientcivil service and a systematic application ofthe merit system principles, includingrecommending policies relating to theselection *** tenure, and separation ofemployees.

5 U.S.C. 1103(a)(7)

Each of OPM’s oversight goals is derived,either directly or indirectly, from these provi-sions of the law. And, in undertaking each ofthem, OPM has faced a variety of issues anddifficulties and has achieved varying degreesof success. Below we address these issues,how OPM is dealing with them, and how welleach program goal is being realized in theprocess.

Goal: Protecting and Promoting aMerit-Based Federal Civil Service

OPM Leadership and the Agencies’ Role.The statutory language regarding protectingand promoting a merit-based Federal civilservice is echoed elsewhere in title 5, but withreference to agency heads rather than theDirector of OPM:

The head of each agency shall be responsiblefor the prevention of prohibited personnelpractices, for the compliance with andenforcement of applicable civil service laws,rules, and regulations, and other aspects ofpersonnel management. Any individual towhom the head of an agency delegatesauthority for personnel management, or forany aspect thereof, shall be similarly re-

CHAPTER 4Today’s Oversight Program Goals: Context and Status


sponsible within the limits of the delega-tion. 5 U.S.C. 2302(c)

Thus, as a matter of law, the role of prevent-ing prohibited practices and promoting meritdoes not rest exclusively with OPM. As wehave long believed, and continue to maintain,an effective HRM evaluation system includes“activities by OPM, by Federal departmentsand agencies, and by individual installa-tions.”7 As the Government’s central person-nel agency, OPM has a leadership role increating this comprehensive oversight ap-proach.

The reality, however, suggests that this idealof a comprehensive HRM evaluation systemincorporating resources of OPM, departmentsand agencies, and installations is a long wayfrom being realized. Our 1992 report on theoversight program describes OPM’s activitiesaimed at providing leadership to agencyevaluation programs, but concludes thatdespite OPM’s efforts, most agencies don’tperceive the evaluation of HRM activity asimportant to mission accomplishment. Thereport states:

Although the [OPM oversight] programsupposedly was redirected toward linemanagement 20 years ago, OPM, by itsstrategic plan, indicates that it is stilltrying to convince managers to make[HRM oversight] an integral part ofmanagement today. If OPM wishesagency managers to make [oversight] anintegral part of management, a changein organizational culture in each agencyis needed.8

Only limited progress appears to have oc-curred since we made those observations. Infact, we believe that since our 1992 report on

7 Ibid., p. 10.8 Ibid., p. 17.9 During 1997, staff members of OPM’s Merit Systems Effectiveness office spent a considerable amount of time with the agencies

scheduled for review during FY 1998 to develop a self-assessment agenda. Time will tell whether this effort will include adequatefocus on regulatory compliance and merit system oversight issues, and whether agencies will allocate to it the resources necessaryto make it work.

oversight, there has been an overall diminutionof agencies’ capacity to carry out their owninternal assessments of HRM activity. From ourvisits to agencies and installations in 1997 welearned that many departments and agenciesfind it hard to maintain an internal oversightcapability in the face of staff and budgetreductions which generally have been dispro-portionately large in personnel offices, leavingfew HR professionals to engage in oversightwork. In many departments, HRM oversightresponsibility is now assigned to a single staffperson, sometimes as a collateral duty. It isalso possible that the difficulty of establishingappropriate accountability measures in therapidly changing workplace environment hascontributed to this weakness in agencies’internal oversight programs. Whatever thecause, we are concerned with what we per-ceive as a generally diminished agency capabil-ity—or interest— in assessing the HRM func-tion, especially compliance with laws, regula-tions, and Governmentwide HRM policies.

Given this situation, oversight of agencies’human resources management continues torest primarily—if not exclusively, in someagencies—with OPM. It is encouraging,however, that the accountability group ofMSO&E is working with agencies to developmodels for self-assessment.9 Perhaps in timethese efforts will produce agency self-assess-ment systems or programs that seamlesslyinterface with OPM’s oversight efforts. Per-haps in time agency programs will even be-come the primary means for protecting themerit system, with OPM operating in thebackground. But right now, OPM’s oversightprogram appears to be an essential tool forprotecting and promoting the Federal merit-based civil service, and we believe that itscurrent iteration is an improvement over whatit replaced.


10 In 1998 this organization changed its name to the “National Partnership for Reinventing Government” while keeping the“NPR” acronym.

11 National Performance Review, “Creating a Government that Works Better and Costs Less, Reinventing Human ResourcesManagement, Accompanying Report to the National Performance Review,” Washington, DC, September 1993, p. 4.

12 National Academy of Public Administration, “A Competency Model for Human Resources Professionals,” Washington, DC,June 1996, pp. 4-5.

Regulatory Compliance and Results Ver-sus ProcessA large body of laws and regulations exists toensure that actions taken in the Federal civilservice are merit-based. Reviewing agencies’compliance with those laws and regulations iscrucial to the goals of promoting and protect-ing a merit-based Federal civil service. There-fore, OPM’s inclusion of a compliance compo-nent in its reviews is essential to the compre-hensiveness of the oversight program. Inrecent years, however, the concept of regula-tory compliance seems to have taken onnegative connotations, perhaps because of therecurring “let the manager manage” theme ofthe National Performance Review10 (NPR), aswell as the focus on results, rather than pro-cess, that is central to the Government Perfor-mance and Results Act.

There is, in fact, considerable support for thenotion that emphasizing compliance is some-how inconsistent with leadership in the hu-man resources profession. A key 1993 NPRreport urged that “HRM staff advisors shouldbe viewed as part of the management team,not servants of management or the system’spolice.”11 More recently, in a report describinga competency model for Federal HR profes-sionals, the National Academy of PublicAdministration (NAPA) stated that “HRleaders must market their results- and mission-driven role within the agency, assert them-selves as leaders and strategists, and repositionHR from an administrative function to astrategic partner.”12 The NAPA report madeit clear that NAPA does not easily include“policing” (compliance) as one of the roles theauthors envision for HR professionals. Whilethese statements are concerned with theagencies and not OPM, they can lead toquestioning of even OPM’s compliance work.

We agree that managing for results ratherthan focusing on the processes intended to

achieve those results is an appropriate objec-tive. Further, HRM assessment that measuresresults rather than process would, perhapsmore than any other program change, en-hance assessment in the eyes of line managers.At the same time, however, we believe thatinsufficient attention to regulatory complianceis both unfortunate and shortsighted, sinceone of the distinguishing features of a merit-based civil service system is the way in whichit achieves fair and equitable results throughthe consistent application of personnel laws,rules, and regulations. The plain fact is, as wepointed out above, both the agencies and OPMhave a clear statutory enforcement role. Giventhis fact, plus most agencies’ only slight effortsat self-assessment, the issue is not whetherOPM should have a compliance role, butrather, how well it executes that role and howit emphasizes that role relative to other roles.

For some important perspectives on how OPMfulfills its role in protecting the civil service, weturned to Federal department and agencies.In response to a survey question, the depart-ments and agencies gave MSO&E generallyhigh marks for its capacity to protect andpromote a merit-based civil service. Figure 1(page 16) depicts these survey results.

It should be noted that agencies that hadundergone review by OPM since the oversightprogram was overhauled were somewhatmore positive in their views than were agen-cies that had not yet been reviewed under thenew approach. In some cases this may meanthat agencies are predisposed to expect anegative experience, but when they undergothe new approach they find it to be an im-provement over the old one. However, despitethe relatively positive views depicted in figure1, the comments in questionnaires that werereturned to us were not unanimous in praisingOPM, as the quotes about MSO&E that followshow. (The questionnaires were completed by


headquarters representatives of departments,independent agencies, or departmental com-ponents.)

We also conducted interviews with officials ata wider range of organizational levels in orderto get an expanded view of the program.Many of these interviews were with linemanagers or personnel officials in officesphysically and organizationally removed fromtheir agencies’ headquarters. From the van-tage point of field organizations that hadundergone an OPM oversight review since the1995 changes, they expressed a range of viewssimilar to those at headquarters. Most agreedwith their headquarters counterparts thatOPM’s program provides a firm footing forpromoting and protecting a merit-based civilservice, and most indicated that this wasprimarily accomplished through a visibleregulatory compliance presence. A smallnumber of those interviewed, however, char-acterized OPM’s restructured evaluation effortas still focusing too heavily on proceduraldetail and too little on overall outcomes.

To some extent, organizations’ views maydiffer because they have dealt with differentindividual evaluators or evaluation teams.The transition from conducting an oversight

program that for manyyears relied heavily onreview of processes to onethat focuses more on out-comes is not easy under anyconditions. When coupledwith efforts to convert thecollective thinking of sixformer regional oversightunits into one uniformphilosophy, the challengebecomes formidable. Per-haps the relatively fewnegative comments offeredby the individuals weinterviewed are best viewedas an encouraging indica-tion of how the program isdeveloping.

While questionnaire respon-dents were more positive than negative on theissue of MSO&E’s effectiveness in protectingmerit, an adamant minority of them expresseda preference for a reduced OPM compliancepresence. In their view, the extensive flexibil-ity resulting from the new emphasis on out-come rather than process has reduced theneed for the kind of third party complianceoversight (as discussed under the “How theProgram Operates and What Has Changed”heading of this report) that OPM provides.These respondents believe their own organiza-tions should be the point at which oversight isexercised. We’ve already noted that this is avalid view, especially since agencies have alegal responsibility for ensuring compliance.But we don’t agree that OPM is no longerneeded, particularly since we remain con-cerned that many agencies are not exercisingeffective oversight of their own.

In a perfect world all managers’ and supervi-sors’ HRM decisions would be fair and equi-table and require no third-party review. Oragencies would have sufficient internal safe-guards in place to identify and correct all oftheir HRM problems. But in the absence ofsuch perfection, OPM’s oversight programmust remain a part of the system of safeguardsavailable to protect the merit-based Federal

Figure 1. Agency responses to the question, “To whatextent is MSO&E effective in protecting and promot-

ing a merit-based Federal civil service?”

Percent responding:

Very great orconsiderable

Some

Little or no

Don’t know orcan’t judge

5227

26

27

1711

435

Note: Totals may not equal 100 percent because of rounding

23 departments and large independent agencies23 small independent agencies and departmental components


civil service as well as to support other publicpolicy requirements, such as veterans prefer-ence and workforce diversity.

Beyond ComplianceAs important as regulatory compliance is toprotecting and promoting a merit-based civilservice, achieving this goal demands morethan just enforcement. People with delegatedHRM authority must be taught how best tocarry out those delegations with merit inmind, and the proper merit-related valuesmust be instilled in them. Also, OPM mustensure that the rules and regulations thatagencies are expected to follow are rational

and serve the intended purposes. One wayMSO&E is accomplishing this role is throughbuilding and maintaining a close workingrelationship with OPM’s program offices,because those offices’ rules, regulations, andprocedures are the basis for the oversightstaff’s agency reviews.

This close working relationship is best demon-strated through the ties that have been devel-oped between MSO&E and EmploymentService, especially with respect to delegatedexamining. The two organizations interactcontinuously, and all evaluators are encour-aged to take part in meetings and phone

Contrasting Views of OPM’s Office of Merit SystemsOversight and Effectiveness in its “protect and promote

a merit-based Federal civil service” role

PositiveGiven the cutbacks in OPM resources, Ithink the very presence of this office servesas a deterrent to control blatant abuses inthe merit system. I find it helpful to be ableto point to the OPM organizational chartand indicate to senior managers that “*** ifwe don’t follow these rules *** this officewill be looking over our shoulder.”

(An independent agency)

MSO&E is particularly effective in perform-ing effective compliance evaluations ofagency HRM programs. In particular ourcomponents cited the detailed reports theyreceived as being thorough and helpful.

(A department)

We believe the very fact that OPM is “backin the business” of oversight shouldheighten awareness within agencies toensure that merit principles are beingapplied.

(A department)

On-site agency reviews were very construc-tive in the past and are so today. Thereviews have been constructive in providingus with bench marks on our operations andin providing ideas for improvement.

(A departmental component)

NegativeReports have not been particularly useful;they seem to believe that newer [HRM]approaches [by agencies] will underminethe integrity of the system; they seem tohave little trust in Government managers to“do the right thing.”

(A departmental component)

The Oversight review was still a little toodetailed and reactive and the Oversightteam was not aware of flexibilities in keyHR areas which have been given by thepolicy side of OPM. * * * Members of theOversight team also varied in orientationand approach which seemed to createdifferent standards for review based on thecomposition of the team (i.e., a differentteam reviewed each [component] with eachteam independently drafting its own re-port).

(A department)

They duplicate what we are already doingfor ourselves—do not see value added.

(A department)


conferences that bring the two units together.A goal of these regular contacts is to keep theevaluators up to date on the rapidly changingworld of examining, and to allow the evalua-tors to bring unusual situations to the atten-tion of the staffing experts. As we notedearlier, review of delegated examining is arelatively new responsibility for the oversightstaff. They are grappling with finding thebalance between the flexibility that managersneed and the application of the specific exam-ining laws, regulations, and procedures thatexist to protect the merit principles. In thisundertaking, the oversight staff is being givensubstantial assistance by their EmploymentService counterparts.

Goal: Identifying Opportunities forImproving Federal Personnel Policiesand Programs

Improving HRM in a Results-OrientedEnvironmentA traditional theory of managing systemsholds that a key role of any feedback mecha-nism (including an evaluation program)13 isidentifying opportunities for improvement.This has been a stated purpose of OPM’soversight program since at least the 1970’s.14

Today, however, identifying what can andshould be improved in the HRM arena is morecomplicated than it was in the days whenprograms and processes were fairly uniformfrom agency to agency and OPM could initiatechanges by fiat. Emphasis on deregulatingand simplifying personnel processes hasshifted the focus of Federal human resourcesmanagement from processes to results, andmaking the transition is proving difficult formany reasons, including these:

n Most current Federal managers andsupervisors grew up in the old systemand have long been conditioned to thinkof personnel management as somethingthat the personnel office does for them.And personnel staff also grew up under

the old system. Neither group wasparticularly well prepared to make thetransition when it was initiated, andefforts to prepare them for (or reconcilethem to) the changes that are occurringhave been uneven.

n Most agencies had layered theirown additional requirements, almostalways expressed in procedural terms,on top of OPM’s. Removal of OPM’sprocedural requirements has not neces-sarily meant that agency managers haveseen change, since their ownorganization’s requirements may still bein place.

n It has not proven easy to determinehow to measure by results in the HRMarena. What outcomes are to be mea-sured, and how, is something that manyorganizations are struggling with inevery context, including managinghuman resources.

n The aforementioned changes inemphasis and shifts in focus have beenaccompanied by downsizing of theFederal workforce. The downsizing hasintentionally been disproportionatelyhigher in central control functions,including personnel offices. Thus, asmanagers are being “freed” to make HRdecisions, most find themselves with lessprofessional HR support to turn to forassistance. Even optimists may see theseopportunities as somewhat overwhelm-ing.

It may be the effects of these difficulties thataccount, at least in part, for agencies’ morenegative view of OPM’s effectiveness inachieving the goal of identifying opportunitiesto improve Federal human resources manage-ment. As figure 2 shows, our surveyed organi-zations were less positive in their marks forthis goal than the first one. The fact that onlyabout one-fourth (26 percent) say MSO&Eachieves this goal to a “very great or consider-

13 See, for example, Rocco Carzo, Jr., And John N. Yanouzas, “Formal Organization, A Systems Approach,” RichardD. Irwin and the Dorsey Press, Homewood, IL, 1967, p. 336.

14 Federal Personnel Manual Supplement (Internal) 273-73, September 1972.


able” extent is a clear indica-tion that there’s room forimprovement. Again, itshould be noted that agenciesthat had undergone a reviewafter the 1995 reorganizationwere somewhat more positivethan those not yet reviewedunder the program’s newapproach.

Governmentwide improve-ments. The oversight staff isan important element inOPM’s efforts to improvepolicies and programs thatapply to the entire Govern-ment. Not being part of theOPM offices that write oradminister these Government-wide requirements, theoversight staff is in a goodposition to judge, from a disinterested view-point, the real-life effect of these policies andwhether they’re achieving their stated pur-pose. The evaluators’ feedback to the appro-priate OPM program office (or to an agency’spolicy organization) occurs in several ways:direct contact when particular issues arise;summary reports submitted following a re-view; and post-review discussions to explorean issue in more depth. And communicationsare not one-way: OPM or agencies’ programoffices may bring issues to the attention of theoversight staff at any time.

Establishing a special focus for each year’sreview cycle is an example of how MSO&Ehas tried to provide to other OPM programoffices maximum feedback capability from itsefforts. In the course of each nationwidereview of a department or agency, particularpolicies or programs are selected for specialattention, and the evaluation staff provides theprogram office responsible for the selectedprograms a good view of how they’re beingimplemented and what effects they’re having.

The oversight staff also are used to conductspecial studies, such as a classification accu-racy review they conducted and subsequently

reported on to the appropriate OPM programoffice. Presumably the review’s findings willbe useful as future changes in Federal classifi-cation or compensation practices are explored.In this case, the results have been used onlywithin OPM so the value of this effort andresource commitment to the wider Federalcommunity is not yet readily apparent. How-ever, staff in the appropriate OPM programoffice expressed satisfaction that the informa-tion has proven useful.

Officials whom we interviewed in other OPMprogram offices cited how oversight reviewshave contributed to improvements, particu-larly in the broad areas of performance man-agement/performance evaluation and staff-ing. The examples the program officialsoffered primarily focused on information thatprompted new policies or practices or that ledto incremental improvements to existingpolicies.

We noted earlier, however, that repeatedreferences in oversight reports to a problem donot necessarily ensure that OPM will respondwith a change in Federal policy or practice.Perhaps any absence of action noticed byagencies contributes to the less positive view

Figure 2. Agency responses to the question, “To what extent isMSO&E effective in identifying opportunities for improving

Federal personnel policies and programs?”

Percent responding:


Some

Little or no


26

16

4321

2126

937




they hold of MSO&E’s achievement of thisprogram goal compared with the first goal weexamined. As an example of inaction (delayin this case), many of the oversight reports weread noted that the reviewed organizationwas referring job applicants through internalmerit promotion procedures without firstranking the candidates if there were fewerthan 10 qualified applicants. In a stand that isgenerally unpopular with agencies, OPM haslong contended that this practice is inconsis-tent with the first merit system principle andin 1996 proposed a regulation change thatwould require ranking even small numbers ofcandidates. (How and by whom the rankingwas to be accomplished would have beendecided by the agencies.) However, theproposed regulation has neither been madefinal nor withdrawn, even though manyoversight reports have focused attention onthe situation.

Even worse, although evaluators identifiedthese candidate referrals as a problem in anumber of agencies, their criticism of theagencies is virtually indefensible, because inmost cases the evaluators cited the proposedregulation as their authority. A proposedregulation simply has no force. And when weinterviewed OPM staffing officials, theyexpressed surprise that evaluators were rely-ing on the proposed regulation to defendOPM’s position. It is not clear whether thereis disagreement between MSO&E and Employ-ment Service concerning what agencies shoulddo in these situations; neither is it clear why afinal decision has not been reached concerningthis draft regulation. Many agencies wouldprefer that this provision of the proposedregulation not be made final. However, somefinal resolution of this particular issue is inorder, even though there is no consensus onthe solution.

Returning to our point about the use that ismade of information from nationwide agencyevaluations, our concern is that even when theoversight group provides what may be usefulor essential information that could result inimprovements in HR practices, agencies maynot see any change in Governmentwide

policies or programs for a long time, if ever.This absence of visible outcomes does reflecton the oversight program and how agenciesjudge it. At the same time, while it is the jobof the oversight group to identify the need orpotential for changes, it’s not within theirpower to compel those changes. This is,however, something over which OPM’s direc-tor has significant influence.

Agency improvements. OPM’s oversightprogram also is capable of serving as eyes andears for the agencies with respect to their ownHR policies and procedures. MSO&E’s evalu-ators can measure and report how, and howwell, an agency’s components implement theiragency’s own regulations, just as they do forGovernmentwide regulations. And since eachagencywide review includes HRM issues orHR programs chosen by the agency itself to begiven particular attention, agencies andinstallations stand to gain substantial informa-tion from each OPM review.

Interview comments and survey responsesindicated that most agencies view OPM asmaking a positive contribution to their man-agement goals when they include in theirreviews issues identified by the agencies. Hereare two typical comments from departments:

During [the review of our department]we asked OPM to add to their programagenda an assessment of the nature andlevel of delegations of our various per-sonnel authorities. OPM was more thanwilling to add this to their reviewagenda and helped us develop theparameters of the study. The results oftheir review confirmed what we hadbelieved; that is, that, in many cases,delegations have not gone beyond thebureau level to line managers as washoped. When they had been furtherdelegated, few managers expressed thedesire to have any additional delegation.

The Office of Merit Systems Oversightand Effectiveness is doing the followingvery well: * * * Tailoring agency reviewactivity to address identified Federal andAgency human resources management


issues instead of statistical coverage ofgeneral topics.

Increased Effectiveness in InfluencingHRM Improvements.Sharing MSO&E’s information. What, exact-ly, do agencies think MSO&E could do toincrease its effectiveness in identifying oppor-tunities for improving Federal personnelpolicies and programs? Several agenciessuggested something that MSO&E officialshad told us they already were doing (and thatother agencies agreed is being done): shareinformation about exemplary practices so thateach installation or agency doesn’t have toreinvent the wheel.

MSO&E’s predecessor organization publisheda “Digest of Exemplary Practices,” but only onan occasional basis. The published digest wasaddressed to agency HR officials, a practicethat drew criticism from several survey re-spondents who commented that they believethat line managers are a more appropriateaudience for this type of information. MSO&Eprepares a different publication, “OversightNotes,” on a quarterly basis, and its method ofdistribution varies by field division. We believethis somewhat unstructured distributionapproach represents a missed opportunity forthe oversight program.

From our visits to OPM field offices we learnedthat OPM’s oversight field divisions havemade a concerted effort to share best practicesinformation, particularly through the FederalExecutive Boards (FEB’s) in their respectivelocations, but that HR officials in most fieldlocations we visited have not benefited fromOPM’s efforts. If managers are getting bestpractices information through forums such asFEB’s, but that information is not being sharedwith agencies’ HR officials, an important loopis not being closed and maximum value fromthe information is not being obtained.

Some organizations are positive about OPM’sinformation-sharing of best practices. Surveyresponses from three departments expressedsatisfaction with OPM here. These agencies’views may be influenced by the fact that the

information came in the OPM reports on theirHRM programs, reports that contain sectionsspecifically headed “Noteworthy Practices.”This is useful to the reviewed organization, butoffers no assistance to other organizationsbecause OPM restricts the distribution of itsoversight reports to the agency concerned.

Although the sheer size and geographicaldispersion of the Federal Government’s manycomponents work against any easy mecha-nism for sharing such information as that onbest practices, and there will always be occa-sions for communications breakdowns thatmay prevent widespread dissemination of theinformation, OPM is paying attention to thisissue. At MSO&E’s 1997 annual businessmeeting, its managers and evaluators from allover the country discussed dissemination ofbest practices information and affirmed thepractice. MSO&E is conducting a review ofhow frequently the information should bemade available, the appropriate audience, andother factors in order to improve its bestpractices information sharing.

Another topic discussed at MSO&E’s 1997annual business meeting was the value ofpublishing information on worst practices. Inthe current environment of broad HR delega-tions, agencies vary widely in the degree towhich they are willing to explore the limits ofwhat decisions and actions are permissible foragencies under existing HR rules and regula-tions. At the annual meeting, MSO&E tenta-tively decided to share with all agenciesexamples of HR decisions and actions thatwent beyond the acceptable limits. We believethat is a good decision. Just as best-practicesinformation may help keep agencies fromhaving to expend resources determining howto do something, worst-practices informationmay discourage agencies from decisions thatcould harm both them and their employees.

In today’s “on-line” world, we think MSO&Ecould greatly improve its visibility and useful-ness to agencies if it were to share both kindsof information through a home page or website of its own, as well as by periodic hardcopy publication of the information. OPM has


a very visible presence on the Internet already,and agencies’ managers and HR staffs increas-ingly have access to information there. Plac-ing information about best and worst practiceson the Internet seems to be a logical next step,and one we encourage.

Strengthening self-assessment. A secondsuggestion offered by several agencies forincreasing OPM’s effectiveness in improvingFederal personnel policies and programs wasfor OPM to direct more of its oversight re-sources towards helping agencies develop andstrengthen their own self-assessment capabili-ties, and then monitoring how well the agen-cies apply those capabilities. This is consistentwith a recommendation contained in our 1992report.

We’ve already noted that internal self-assess-ment programs are essential to maintaininggood human resource management in theFederal Government, and that OPM can’t dothe job alone. Further, we’ve observed thatmost agencies have less internal oversight orself-assessment capability now than they hadin or before 1992. Generally speaking, agen-cies have taken their lead from OPM withrespect to oversight activity. When OPM’sprogram was perceived as being in decline,agencies allowed theirs to follow suit. Now,with OPM’s program in ascendancy, manyagencies are finding it hard to resurrect theirown programs because of strong internalcompetition for scarce resources.

In advocating the strengthening of agencies’self-assessment efforts, we should make clearthat we are not necessarily recommending areturn to the labor-intensive personnel man-agement evaluation processes of the past. Norare we necessarily suggesting that HRM self-assessment processes need to be carried out bythe HR office staff. There is substantial roomfor innovation in who does self-assessment,and in how it is done. But there should belittle room for debate on whether such self-assessment is conducted, and there should beno question of the value of linking internalefforts to the efforts of OPM. A cooperative,coordinated approach would conserve both

OPM and agency resources and would makethe evaluation process smoother from bothperspectives.

Within MSO&E, leadership for agency internalassessment efforts has been assigned to theeffectiveness staff. When we discussed thework of that MSO&E component with agencyofficials during our field visits, we found thatthe effectiveness staff was virtually unknownoutside the Washington, DC, area. This is notto say that their work isn’t good; simply that itisn’t reaching beyond the Beltway. Even inthe departments and agencies with whichOPM worked to develop a self-assessmentcapability to prepare for the FY 1998 cycle ofreviews, field installations where we con-ducted interviews were not aware of this jointagency-OPM effort. This lack of informationin the field appears to be a problem best solvedthrough agencies’ internal communications,something beyond OPM’s control.Through interviews we also found that OPM’sfield oversight staff had few contacts with theeffectiveness staff concerning agency self-assessment and generally did not appear well-attuned to what the effectiveness staff areaccomplishing in that area. We also foundlittle evidence that the field oversight staffwere spending any appreciable effort or timeon agencies’ self-assessment programs. Theoversight staff’s time is taken up with theirprogram review agendas, and self-assessmentjust isn’t one of the topics they cover. Yetimproved agency self assessment, particularlyif linked to OPM’s oversight efforts, is a key toidentifying opportunities to improve Federal(and agency) personnel policies and programs.

We believe MSO&E can substantially improveits achievement of the goal of identifyingopportunities for improving Federal personnelpolicies and programs by improving the effortto promote self-assessment. Perhaps if itsoversight effort were to be more visibly con-cerned with agency self-assessment efforts, theagencies would respond by increasing thoseefforts. And if OPM provided guidance toshow how each agency’s program could workin conjunction with OPM’s, then OPM and theagencies could share the oversight workload.


Since most agencies believe they are in a betterposition to assess their HRM efforts than OPMis, we think MSO&E should make everypossible effort to draw the agencies into awell-coordinated cooperative self-assessmenteffort in which OPM’s oversight staff have aclear presence. Such an approach couldperhaps work along the lines of OPM’s currentapproach to delegating examining authority:agencies with self-assessment programs meet-ing certain criteria established by OPM couldoperate with a generally reduced OPM over-sight presence, and OPM’s focus in thoseagencies could be largely on measuring theadequacy of those agencies’ self-assessmentprograms.

Goal: Helping Agencies Meet MissionGoals Through Effective Recruitment,Development, and Utilization of Em-ployees.

Defining “Help”Of OPM’s three oversight program goals,helping agencies manage human resources toaccomplish their missions may be the mostdifficult to define and achieve. Based onagencies’ comments made during field visitsand in response to our questionnaire, this goalraises the fundamental question of how andby whom “help” is defined. Most agencieswant maximum freedom for their operations,including those that affect employees. Sowhen OPM evaluators determine that agencieshave misinterpreted the language or intent ofa personnel law or regulation, and as a resultneed to make a correction or program adjust-ment, OPM is seldom perceived as helping,despite OPM’s and the agencies’ sharedobligation to ensure the proper application ofpersonnel rules and regulations.

Likewise, agencies are not favorably inclinedtowards OPM’s help when it takes the form ofrecommendations for changes in HRM policiesand procedures that the agencies are alreadysatisfied with, even if the changes could resultin efficiencies or economies. For example,OPM suggested changes in one agency’sawards policies to reduce the number ofquality step increases granted annually and to

make greater use of other, less expensive,awards. OPM saw this suggestion as advanc-ing the values expressed by the fifth meritsystem principle (“[t]he Federal work forceshould be used efficiently and effectively”),while also supporting the third merit systemprinciple (“appropriate incentives and recog-nition should be provided for excellence inperformance”).

The agency countered that its actions werewithin its delegated authority and wereconsistent with the third and fifth meritsystem principles, and also with the second,which calls for all employees to receive fairand equitable treatment in all aspects ofpersonnel management. Since the agency hasthe money to conduct its awards program inthis manner, the fact that OPM’s recommen-dations are sensible from a fiscal stewardshippoint of view is seen as largely irrelevant.Agency managers see the program as meetingtheir own and their employees’ needs andapparently have no intention of changing it. Ifnothing else, this single example shows howdifficult “helping” can be, especially if per-ceived within the context of the broadlyworded merit system principles.

Indeed, our questionnaire respondents wereleast satisfied with MSO&E’s performance inthis particular area. In figure 3 (page 24), notethat about 30 percent of both response groupschose the negative (to “little or no” extent)response. Only 22 percent of departments andlarge independent agencies and 14 percent ofsmall independent agencies and departmentalcomponents responded with the most positivechoice of to a “very great or considerable”extent). In this case, there was virtually nodifference in response patterns betweenorganizations that had undergone a reviewafter the 1995 reorganization and those thathad not.

Improving Oversight Unit CapabilitiesPersonnel. Achievement of the goal thatcenters on helping agencies accomplish theirmissions depends substantially on how, andhow well, individual evaluators approach


their jobs, since it is through their eyes and thereports they produce that agencies’ efforts areunderstood and judged. Several factorscombine to affect this situation, including:

n Evaluators’ past training and expe-rience;

n The ease with which those whowere in the evaluation business whenOPM had regions have been able toadjust to their current management’sapproach to and philosophy of over-sight; and

n The training evaluators have re-ceived since the reorganization in 1995.

The loss of experienced evaluators in the yearsimmediately preceding the reorganizationcreated job vacancies that were almost alwaysfilled by persons who had lost their jobs in thetwo RIF’s that OPM experienced during thatperiod. In this way the oversight functiongained a number of senior, long-service indi-viduals judged to have high potential but whohad little direct experience in evaluation andwhose expertise was not necessarily in thatfunction. These circumstances make develop-ment of these employees critical to the sound-ness of the evaluation program.

We earlier alluded to theefforts MSO&E manage-ment has taken to imbuetheir organization with asingle philosophy andcommon approach (“oneprogram, one team”). Wehave concluded that theseefforts have shown goodresults to date, but thatdifferences in approachamong the former regionspersist. These differencesare recognized both withinMSO&E and in the agenciesthat are subject to theirministrations, so we believethe situation will receive thecontinuing attention itdeserves.

Reports. After reading literally dozens ofoversight reports prepared since the programwas revitalized, we concluded that the qualityof the analysis and presentation of OPM’soversight reports is uneven, although morerecent reports generally are an improvementover earlier ones. In our view, the most glaringweakness is a tendency to write executivesummaries in quite positive terms that oftenseem contradicted by problems and weak-nesses subsequently described in detail in thebodies of the reports. Our concern is that ifbusy agency managers read only executivesummaries, such an approach to summarizingthe findings can create in top managers’ mindsa misleading sense of program well-being.Once such an impression has been fostered, itmay prove hard for subordinate managers toinitiate changes that the more detailed textnarrative may indicate are needed or desirable.

It is not unusual in an organization of over 100potential report authors for there to be varia-tions in the quality of the written products,since those authors bring differing levels ofwork experience and writing skills to the task.But the written report is a key product for theoversight function—the documentation leftwith the agency to reflect both what was andwhat should be. Content and presentation are

Figure 3. Agency responses to the question, “To what extent is MSO&Eeffective in helping agencies meet mission goals through effective

recruitment, development, and utilization of employees?”

Percent responding:


Some

Little or no


22

14

39

14

30

32

9

41




both important ingredients. Thus, we wouldencourage MSO&E to monitor report writingcarefully and to provide training where it willhelp strengthen this part of the staff’s job.

Improving Information Sharing to HelpAgencies Meet Their Goals.Much of our discussion concerning the previ-ous program goal—identifying potential HRMimprovements—is equally appropriate here;that is, better sharing of information aboutbest and worst practices can enhance OPM’scontribution to agencies’ meeting their missiongoals. This is particularly true because today’semphasis on decentralization and delegation

encourages agencies to explore different waysto accomplish basic HR activities. But thisfreedom can come at a price in resources thatquickly discourages many agencies fromexploring very extensively. Thus, agenciesmay proceed to implement HR changes with-out having first properly examined their likelyconsequences. Alternatively, they may con-tinue to follow antiquated HR practices thateither undermine their mission accomplish-ment or that support mission accomplishmentat an unnecessarily high cost. In this environ-ment, OPM’s role as an information brokercould make a tremendous difference to someagencies at small cost to OPM.


Today it is generally acknowledged thatfaithful adherence to proper procedures is arather empty accomplishment if those proce-dures do not result in achieving what laws,regulations, and Governmentwide policiesenvision. One key continuing challenge toOPM’s oversight program is how to implementa change in focus that makes achieving resultsas important as complying with regulationsand procedural requirements. Success inaccomplishing this change in focus is stronglyaffected by a second challenge—the presenceor absence of standards against which tomeasure those results.

A third challenge—closely related to changingoversight’s focus—is how to deal with thequestion of where accountability for HRMoutcomes lies, and how that accountability isto be measured. This already difficult chal-lenge is made even more difficult by theincreasingly common practice in agencies ofusing computer-based systems to carry outmany HRM program activities (e.g., writingposition descriptions and subsequently deter-mining the classification of the positions)—apractice often accompanied by a reduction inthe number of professional HR staff availableto support line managers. The challenge toeffective oversight arises from the loss oftraditional “checks and balances” that existedwhen traditional personnel offices dispensedadvice, exercised control, and processedpersonnel actions, and lines of responsibilitywere clear.

And finally, there is the resources challengethat has faced oversight organizations for as

CHAPTER 5Continuing Challenges to Effective Oversight

long as they have existed: finding the balancethat permits sufficient onsite presence toensure effective oversight while making opti-mal use of information available throughmeans other than onsite visits (e.g., CPDF dataor agencies’ reports). Each of these challengesis discussed in more detail below.

Focusing on ResultsThe focus on results has been a key theme ofGovernment reinvention, often expressed interms such as eliminating unnecessary con-straints, reducing red tape, putting authorityfor decisionmaking as close as possible towhere the effects of the decision are felt, andletting managers manage. One of OPM’shighly publicized actions intended to orientGovernment more toward results was elimina-tion of the Federal Personnel Manual, or FPM,in 1994.

Eliminating the FPM considerably reduced theamount of printed “how to” guidance for bothpersonnel management decisions and theirunderlying personnel administration processesand procedures. When this step was taken,the general expectations were that: linemanagers would assert or reassert their rolesas managers of their workforces; HRM staffmembers would provide those managers withsufficient advice and assistance for the result-ing managerial decisions to achieve the re-quired results; and the details about how eachdecision was reached and executed were oflittle concern so long as the results met thebroad requirements of applicable laws andregulations.


15 See, for example, Markland v. OPM, 140 F.3rd 1031 (1998).

Information gathered for studies since theFPM was abolished has revealed that manymanagers apparently were surprised to learnthat abolishment of the FPM did not meanthat they had been freed to manage theirworkforces in an unconstrained manner—thata whole body of civil service laws and regula-tions and internal agency policies and proce-dures still impose structure on their exercise ofHRM discretion. In addition, MSPB andjudicial decisions have concluded that someabolished FPM provisions may still define themeaning of existing civil service laws andregulations.15

Still, in many instances there really no longeris one prescribed “best way” to achieve HRMtasks. Instead, agencies have whatever free-dom they derive from interpreting the lan-guage of laws and regulations. In the broadestcontext, the test now for each HRM decisionshould be “Does this decision achieve a legiti-mate management goal in keeping with one ormore of the statutory merit system principles?”In a narrower context, the question should be:Does this decision meet the letter and intent ofthe applicable law or regulation? And thereinlies the problem when an organization issubjected to a review by any third party,including OPM’s oversight component: Howdoes the reviewer establish that the interpreta-tion achieves these standards?

Through oral and written comments, agencieswe surveyed expressed a perception thatOPM’s evaluators too often and too quicklyadvance a “one right way” solution in situa-tions where they disagree with agencies’exercise of discretion in interpreting laws orregulations. Agencies accept that such dis-agreements are inevitable in the face of re-duced procedural guidance, and most ex-pressed no or only mild concern over situa-tions where OPM took action to rein in effortsthat it thought represented excessive creativ-ity. A very small number of agencies ex-pressed the view that OPM should not havethe authority to substitute its view for anagency’s when a law or regulation was open

to interpretation, but this position is inconsis-tent with the authority granted to OPM in title5.

The basis for the agencies’ concern is whatthey see as a troubling tendency for OPM’sevaluators to offer their own interpretation asthe only right way to accomplish an action,foreclosing the possibility of other equallyappropriate interpretations. Further, agenciesthat expressed this concern observed thatOPM’s “only right way” was almost invari-ably consistent with the procedural guidancethat had been contained in the old FPM. Ourreview of oversight reports written by OPMdidn’t turn up any instances of this tendency,and we could not measure directly how oftenOPM evaluators might have insisted on theirown interpretations orally during oversightreviews. Agencies reporting these situationsacknowledged that they don’t happen often,but the agencies also stressed that even a fewsuch instances have a negative impact on bothline managers and their supporting HR staffs.Line managers see such instances as disincen-tives to their acceptance of broader HR au-thority, and HR officials see them as under-mining the advisory role that they are beingencouraged to perform.

It is unrealistic for agencies to expect thatOPM will not question their actions (includingsituations involving interpretation of laws andregulations) and will not substitute its judg-ment for theirs when OPM’s representativesbelieve it’s necessary. This is, by law, OPM’sresponsibility.

Still, changes in the roles of HR staffs and lineofficials have in recent years placed moredecisionmaking in the hands of managers andsupervisors and given them the greatestpossible flexibility to manage their employees.That necessarily means focusing less on pro-cess and more on results, but the balancebetween these two points can be shifted onlyso far. Sometimes process is so important toresults or to upholding public policy objectivesthat little opportunity exists for flexibility. (For


example, reduction in force is heavily processdriven, as is the application of veterans prefer-ence in hiring.) A key part of OPM’s oversightresponsibility is to determine and makeknown when adherence to established processis essential. It is equally important for OPM torecognize circumstances when this is not thecase, and to encourage or at least acceptflexibility in those latter instances.

In practice, attaining the proper balancebetween process and results in HRM isfraught with difficulties, and sometimescontroversy. Those who administer Federalpersonnel programs must decide what resultsto measure, how to measure them, and howmuch weight to give to the process used toobtain them. Processes that include adminis-trative exercises that neither the law norcommon sense require are ripe for revision.On the other hand, it is wrong to ignore laws,regulations, and Governmentwide policies inthe process of pursuing results, no matter howworthy they may be. The legal and regulatoryviolations that may result can produce other,negative outcomes that offset the goodachieved in reaching the original results.

For example, in October 1997 OPM publisheda report highly critical of recruiting and hiringpractices in an independent Federal agency.OPM’s report describes an agency that ig-nored or misused processes and procedures inan effort to achieve outcomes that the agencyconsidered desirable. From the agency’sperspective this might well have been viewedas the end justifying the means, a simpleexercise of creativity to address perceivedstaffing needs. But OPM saw a different set ofoutcomes—job applicants misled and deniedemployment opportunities, individuals hiredthrough procedures that were not appropriatefor the jobs involved—and determined that noresult achieved by the agency was sufficient tojustify bypassing required processes andprocedures. In this particular case OPMjudged that the outcomes obtained, no matterhow desirable, were tainted by improperactions and has referred the situation to theOffice of the Special Counsel for investigationand possible prosecution.

Current trends in Federal HRM will not easethe tasks of identifying the right results, theappropriate processes, and the ways to mea-sure them. If evaluators are already finding itdifficult to measure the acceptability of out-comes achieved through alternative processesunder a single Federal civil service system,consider the potential effect of their having todo so under multiple HR systems. A fewagencies have received substantially increasedflexibility through legislation granting themfreedom from many of the legal requirementsfound in title 5 of the U.S. Code. Others seemready to pursue requests for similar “relief”from current rules. To the extent that agenciesachieve this break with the norm, they poseincreased difficulties for OPM or any otherorganization responsible for assuring thatoutcomes achieved and practices followedunder the increased flexibilities are acceptable.Both the requesting agencies and the Congressshould carefully consider the problems thatsuch actions may cause. The example citedabove strongly suggests that the public interestis served through having every agency subjectto some oversight by an outside organization.Until agencies progress much further withsound self-assessment programs that can beoperated in cooperation with OPM, OPMremains the organization best situated toconduct that oversight with regard to HRMpractices. However, a proliferation of HRsystems independent of title 5 could increasethe difficulty of that task.

For the time being, the shift in focus fromprocess to results remains incomplete. Evi-dence from our surveys and the focus groupsuggest that in the area of assessing agencyHRM activity, OPM’s evaluators are makingthe change from judging process to measuringresults, but they are not all making the changeat the same speed, or with the same success.And despite the goal of focusing on results, it isunlikely that attention to process will or evershould be abandoned, because process can be acritical factor in measuring results and ensur-ing adherence to public policy objectives.Within OPM, MSO&E’s managers appears tobe on the right track as they guide their organi-zation toward a focus on results. The next


16 U.S. Office of Personnel Management, Office of Merit Systems Oversight and Effectiveness, Office of Effectiveness, “HumanResource Management (HRM) Accountability in Federal Agencies: Current Efforts and Future Directions,” January 1997.

17 Ibid., p.3.18 Office of Personnel Management, Human Resources Management Interagency Advisory Group, October 21, 1997.19 Ibid., p. 7.

challenge we discuss remains a hurdle toaccomplishing that end.

Evaluating Without Clear StandardsUntil the Government began to focus seriouslyon measuring results, Federal HRM accom-plishments typically were measured by howwell actions complied with procedural require-ments, although there were serious questionsabout whether those measurements actuallymeant anything. MSO&E has been diligent inits efforts to focus attention on results, both foroversight carried out by its own evaluatorsand for self-assessment efforts within agencies.Its evaluators’ guide is a living document thatis regularly updated and revised to accommo-date new techniques and ideas for conductingoversight with an emphasis on results.Another document, published by the Office ofEffectiveness in January 1997, lays out theleadership role it expects to play in helpingagencies develop their own HRM accountabil-ity capabilities.16 One of the activities thatOPM identifies as critical to its leadership is“establishing expectations and providinggeneral assistance, including a framework foragency self-assessment”; another is “maintain-ing forums for information-sharing aboutaccountability and promising approaches, andfacilitating communication among agencies.”17

While these activities are critical to aGovernmentwide, coordinated oversightprogram, the effort still lacks clear standardsagainst which to measure the outcomes ofagencies’ HRM activity. The statutory meritsystem principles are too broad to serve as thenecessary yardsticks. And despite OPM’sefforts to provide in their reports clear opera-tional statements of what outcomes are ex-pected from applying the principles, often thereports’ authors end up defining the strengthsor weaknesses of agency HR programs interms of compliance with procedures.

In the general absence of objective evaluationmeasures, experience and the exercise ofseasoned judgment are essential to an effectiveoversight program. But experience and sea-soned judgment are not enough by themselves.In the case of HRM oversight, efforts must beexpended to develop the proper measurementtools—ones that can be used both by OPM andagencies as they examine how well managersuse their HR authority to achieve their missiongoals, and how well they are supported bytheir HR offices.

In October 1997 OPM published its “FY 98Program Coverage Guide, for HRM Account-ability.”18 This document, developed in coop-eration with the eight agencies scheduled forreview during fiscal year 1998, is OPM’s mostrecent attempt at providing standards formeasuring HRM in agencies. In this particularinstance it is a guide for reviewing agencies’self-assessment efforts.

The guide contains questions which, if an-swered, will establish the framework formeasuring the scope and effect of an agency’sself-assessment efforts. It also suggests sourcesfor the information needed to answer thequestions. In this respect it is a clear improve-ment over the vacuum it replaces. But it willfrustrate anyone who expects clear, tangibleyardsticks, because they are not there.

For example, in measuring how, and howwell, managers are held accountable for theirHRM responsibilities, the suggested questionis, “Are managers, supervisors, and employeesheld accountable for performance? How arethey held accountable * * * ?”19 The question isaccompanied by a list of possible informationsources, but no standard is provided thatindicates what makes a self-assessment pro-gram excellent or poor. Consequently, theperson or organizations attempting the evalu-ation must make subjective judgments to


20 Gary D. Kissler, “The Change Riders, Managing the Power of Change,” Addison-Wesley Publishing Co., Inc., Reading, MA,1991, p. 268.

arrive at decisions about managerial account-ability. And different evaluators in differentorganizations may well use different stan-dards of judgment in applying this programcoverage guide. In an interview, a senior lineofficial in one of the agencies that developedthis guide commented:

A great deal of time and effort went intodeveloping descriptions of intangibles.Why go to all that trouble to measure theunmeasurable? The guide does not havetangible, measurable results. It was anincredible amount of work, brainstorm-ing, and the like with no results that canbe measured.

Even if they had been successful in providingobjective measures for assessing the effective-ness of HRM activity and outcomes, OPM andthe agencies would probably continue toexperience some level of frustration becausethey would constantly be besieged by change.Human resources management is an ever-changing arena even during stable times, andrecent years have been characterized more bychange than by stability. Under such condi-tions, measuring the results of any manage-ment process is at best a tenuous accomplish-ment. As one author has noted:

[T]o maneuver through the turbulence ofchange requires a recognition of howtemporary one’s plans should be. Inshort, [change] itself is affected bychange, and only those who recognize itand continually adjust their path will besuccessful, * * * another paradox thatgoes often unnoticed.20

To reiterate, the guide is a real improvementover the vacuum it replaced. However, it isnot a measurement tool of the sort contem-plated by the Government Performance andResults Act. Consequently, both OPM andagencies must continue their efforts to developtools suitable for agency self-assessment ofHRM activity. Because some HRM endeavorsare inherently subjective or unquantifiable and

are unlikely to be completely measurable byobjective standards, one of those tools is likelyto continue to be the application of seasonedjudgment. But where it is possible to usetangible measures—of actions or events orpeople or results—to evaluate aspects ofhuman resources management, OPM andFederal agencies must make every effort todevelop these objective devices and incorpo-rate them into the oversight program.

Accountability and Authority: The LineManager/Personnel Office RelationshipIn most agencies one consequence of Govern-ment reinvention and downsizing has been aconscious effort to reduce the resources allo-cated to the HR function. Many agencies havefound that consolidating HR offices is a par-ticularly effective way to achieve such areduction. While consolidated HR offices (inwhich one office may serve thousands ofwidely dispersed managers, supervisors, andemployees) are not new, the current emphasison managerial accountability for HRM hasfocused attention on the problem of howoversight of HRM is carried out in such opera-tions.

The problem stems from how evaluatorstraditionally approach the task of determiningthe correctness of decisions that initiate per-sonnel actions (e.g., reassignments; promo-tions; awards, and almost any other actionthat directly affects employees). Because thesepersonnel actions require an authenticatingsignature within the HR (personnel) office,evaluators focus their attention during over-sight reviews on this duty of personnel offi-cials. This has the appearance, if not theactual effect, of holding personnel officialsaccountable for the decisions (usually made byline managers and supervisors) that the ac-tions represent. In a past era when personnelofficials often actually were control points andline managers frequently did not exercisebroad HRM decisionmaking power, this wasnot an unreasonable approach. But in today’s


environment such an approach is less reason-able for reasons we will discuss below.

The scope of the problem is well defined intwo of OPM’s oversight reports. One of thereports describes an agency that for years hashad a single consolidated personnel office forits nationwide field structure. The otheraddresses a subdivision of a large departmentthat recently reorganized its delivery of HRservices, replacing its full service installation-level HR offices with small staffs of HR advi-sors and large regional HR processing centers.

Here is how OPM described the problem in itsreport of a review of the agency that has longhad a consolidated (centralized) HR office:

[The organization’s] HR staff voicedconcern about the lack of an evaluationmechanism which would enable them toreview actions done by other staff in thefield under delegated authorities. Staff-ing specialists are concerned abouthaving to review and sign off on SF-52’s,“Request for Personnel Actions,” whenthey do not have the documentationshowing that all statutory, regulatory,and agency procedural requirementshave been met. For example, whenseasonal employees are hired by fielddivisions, the staffing specialist in the[HR office] does not know if: (1) veter-ans’ preference was applied; (2) vacan-cies were announced; (3) agency anddivisional procedures were followed.Yet, the specialist is required to sign offon the SF-52, indicating that the requesthas been reviewed. The SF-50, “Notifi-cation of Personnel Action,” is alsoapproved in the [HR office]. Errors byfield [line] managers (at least some ofwhom have not been trained in staffingrequirements) have the potential ofleading to the making of improperselections. This practice of signatoryresponsibility without review is inappro-priate because it calls for the PersonnelManagement Specialists to certify legal-ity and accuracy of a personnel actionwithout any corresponding review.

OPM’s recommended solution is to set up away for the HR office staff to exercise qualitycontrol over vacancy announcements andactions initiated by line managers, because theHR office staff are required to sign off on theseactions. From this it is apparent that OPMconsiders the personnel office responsible forthe action, even though the decisionmakingauthority is delegated to line management.We think that a better solution would be toemphasize line managers’ responsibility fortheir HRM decisions by giving them signatoryauthority and holding them accountable for itsproper use.

Before discussing our proposed alternatesolution further, we turn to OPM’s descriptionof the accountability problem as seen in theagency that has recently reorganized its HRdelivery through regionalizing personneloperations in large processing centers. Duringan interview, the director of one such opera-tions center described to us the relationshipbetween his organization and the installation-based HR advisors: “We’re the factory whilethey are the sales and customer service repre-sentatives.” Here is how one such operation isdescribed in one of OPM’s reports:

Accountability for individual actionsand adherence to the MSPs is a funda-mental issue that must be addressed asthe transition of personnel servicing in[the department] progresses. The [pro-cessing center] is essentially a “produc-tion facility” processing orders receivedfrom a variety of customers. The [pro-cessing center] Director views the role ofthe [center] as ensuring “legal suffi-ciency” rather than accomplishing“regulatory compliance.” A properlyauthenticated Request for PersonnelAction received from a [line] manager isprocessed without question, because the[processing center], with no line author-ity over the [personnel advisors] orinstallation level managers and supervi-sors, accepts the action on its face value.The assumption is that the managerand/or [personnel advisor] submittingthe request is responsible for satisfying


the merit principle requirements by theirsignatures on the requesting or authoriz-ing document. In the process of effect-ing actions many parties become in-volved—the [processing center], the[personnel advisory staff], [installationheads], and [line] supervisors/managers.With the responsibility being fragmentedthere is a clear need to delineate ac-countability, i.e., where the ultimateresponsibility for compliance with lawand regulation rests.

The report tells us that this center processedover 14,000 Notifications of Personnel Actionduring the first quarter of FY 1997 and hasallocated 1 employee to conduct an internalaudit of these actions. While calling this a“commendable” post-audit review effort bythe processing center, the report stresses thatreview earlier in the process is needed to“ensure that errors are detected and avoidedbefore actions are actually taken.” OPM alsoreports that “managers report they are notreceiving timely and sufficient training in howto exercise delegated personnel authoritieswithin the merit principles.” And it ends byreporting that personnel staff advising manag-ers indicate that they have no way of assuringadherence to the merit system principles sincethey are merely “advisors.” The report doesnot offer any recommendation for how theoverall accountability problem should beaddressed, but we know from interviews thatthe OPM oversight field division that led thereview has shared its concerns about thissituation with MSO&E top management.

In OPM’s summary report concerning theparent department for this organization, wefound information concerning how managersand supervisors perceive their HR empower-ment, an issue that has bearing on the issue ofaccountability:

Many managers and supervisors did notperceive the reduction in regulationsthat has already occurred to be empow-ering. In many instances, they pointedto an absence of available onsite person-nel staff as a reason for not exercising

their personnel management authority,rather than viewing it as a freedom toact.

This particular department is large and tradi-tionally has been considered to have a high-quality personnel program. When reviewed,its personnel program was clearly in flux.Whether the report documents only short-termdifficulties or is representative of a long-termproblem is uncertain. What is certain is thatthis review and the other discussed above(which involved a major component of an-other large department) jointly highlight aproblem made visible by current managementthinking: the present approach to determiningHRM accountability isn’t going to work.Having worked to reduce the presence of HRoffices and expand line managers’ HRMauthority, agency top management is unlikelyto permit their HR staffs to set up qualitycontrol mechanisms that limit managers’ability to take actions. And given the reducedsize of most HR offices, it isn’t likely that manywill have the resources to operate very effec-tive controls in advance of the actions beingtaken.

Where does this leave the oversight function?Perhaps with the recognition that traditionalmethods of assessing HRM by evaluating theactivities of HR offices just won’t work if theFederal Government is really going to give linemanagers and supervisors broad authority tomanage the workforce and then hold themaccountable for the results. Oversight proce-dures and practices that focus so heavily onthe role of the personnel office just won’t workin that case.

The Federal personnel office is in danger ofbecoming a nondiscretionary implementer ofdecisions while still being held responsible bylaw for the proper exercise of judgment.Circumstances appear favorable for this trendto continue: fewer HR staff in many agencies,frequently accompanied by their physicalrelocation to sites remote from the managersthey support; reductions in personnel rulesand regulations coupled with expanding


delegations of HR authority to line managersand supervisors; all accompanied in manyinstances by insufficient training to preparemanagers, supervisors, or HR staff for theirexpanded roles.

It appears that it is time for a new approach tooversight, one that focuses attention on theHRM role of the line manager. But beforemoving ahead very far on what would be avery significant change, much more should bedone to prepare all of the players (top man-agement, line managers and supervisors, andHR staffs) for their respective roles. These areboth areas in which OPM should assert itsleadership role, and ones in which the over-sight function can play a significant part.

Limitations of HR Staff Numbers andQualityWhile we already have mentioned the size andquality of HR staffs, the issue needs a shortdiscussion of its own. The Government isexpected to produce the best possible resultsfor the lowest possible cost in all its undertak-ings. This includes its HRM activity, where inrecent years most line managers and supervi-sors have been given expandeddecisionmaking authority, and where HRstaffs have been shrunk and instructed toassist and support line managers with theirdecisions.

In an ideal world the HR staffs would easilyfulfill that consultative role. They would givehelpful and timely advice to managers whowould use it to make wise personnel decisions.The decline in the number of HR professionalswould be of no particular consequence, be-cause those who remained would find thattheir changed roles simply made differentdemands on their time.

Unfortunately, we don’t live in an ideal world,and the realities of the past affect the presentand future. In the past, a relatively largeproportion of HR professional staff werepromoted from the ranks (often the clericalranks) of agencies. Many subsequently pro-gressed to become competent personnelists

capable of performing the tasks of the HR jobsas they then were constituted. But personneljobs and the competencies needed to performthem have changed, and too many of thepersonnelists who were competent in the oldjobs do not possess the qualities to achievesuccess in the new ones. These personnelistsappear not to have kept pace with the chang-ing jobs, a point made in many of OPM’sevaluation reports. And because buyoutsoften were used to avoid the disruption ofapplying reduction-in-force rules, thedownsizing efforts that particularly targetedHR offices have too often left agencies withHR professionals who may no longer be thebest people to perform the new, largely advi-sory, HR role (again something that OPM’sreports have noted). This ultimately—and toooften adversely—affects how well line manag-ers and supervisors carry out their expandedHRM roles.

The size and quality of the HR staff also mayaffect how all employees (not just managersand supervisors) view the quality and timeli-ness of personnel services, as well as theresponsiveness, expertise, and customerservice of personnel office staff. These twoquotes about personnel office services from anoversight report following review of a majorcomponent of a department illustrate thedangers we see:

While [questionnaire] responses indicatesome dissatisfaction with quality andtimeliness, they were more positivewhen reporting on courtesy and respon-siveness. In addition, those supervisorsand employees interviewed onsite didnot hold personnel office staff account-able for the decline in service, but in-stead attributed these conditions todownsizing and the changes broughtabout by reorganizations. It appears,from supervisor and employee responsesto our surveys and interviews, that [thisagency’s] employees have generallylowered their expectations on issues oftimeliness and availability of services inthe human resource management area.


As a result of reorganization/consolida-tion and downsizing (particularlybuyouts), the [agency] has experienced aloss of skilled, experienced, seniorpersonnelists. In addition, there hasbeen a movement of individual staffmembers into functional areas wherethey have less expertise. These eventshave led to several conditions whichhave adversely affected the installationswe visited * * *.

Training the HR staffs may not be the onlysolution to this problem, but it would be astart. We have highlighted this issue herelargely to remind agencies of the importanceof providing training to the “survivors” intheir HR offices and to give very carefulconsideration to the selection process for anynew personnel specialists. We also want toremind OPM of the importance of reviewingthis issue in its oversight efforts.

Increased Reliance on AutomationIncreasingly, agencies are making computer-based HR systems available to their managersand supervisors as substitutes for live HRexpertise. These systems are a key to the realexercise of HR authority by line officials, sincethey permit managers to accomplish a widerange of tasks, including classifying positions,

preparing vacancy announcements, and evenrating and ranking job applicants, with littleor no intervention by HR staff.

The availability of these automated HR sys-tems is a true double-edged sword, however.The freedom to use these tools comes at a priceto the manager: a commitment of time to betrained in the use of these tools; a further timecommitment to actually carry out the neces-sary tasks; and ultimately some mechanismthat will be applied by an outside party toensure accountability for the process andresulting decisions. Another price may be theemergence or growth of “shadow personneloffices,” or staffs of administrative employeesin line organizations to provide the day-to-dayservice no longer available from the officialpersonnel office.

MSPB supports the use of computer-basedHRM systems and any other forms of automa-tion that may lead to efficiency gains. But wecaution agencies that the new tools should bein place, and training in their proper useshould be conducted, before the old tools areabandoned. From our own observations andfrom reading OPM’s oversight reports, it seemstoo often to be the case that the old systemsare abandoned before the new ones are readyto use. That is a recipe for disaster.


ConclusionsOPM’s oversight program has improvedmarkedly since we last reported on it in 1992.It enjoys a high degree of top-managementsupport within OPM and, by expanding itsprogram coverage to include subjects ofspecific interest to the organizations beingreviewed, has also increased its value toagencies and hence its acceptance by them.

Program Goals. The goals established for therevitalized OPM oversight program are logicalones, and much has been done to accomplishthem. Nonetheless, success in achieving themhas been uneven. The greatest success hasbeen achieved with respect to the goal that ismost clearly a statutory responsibility ofOPM’s: protecting and promoting a merit-based civil service. In large part, this goal isachieved through assuring compliance withcivil service laws, rules, and regulations.Agencies understand that compliance with thebroadly worded merit system principles iscritical to the operation of the merit-basedFederal civil service. At the same time, how-ever, there is a widely held belief amongagencies that emphasis on specific provisionsof law and regulation—especially as measuredby procedural requirements—should be re-duced. Despite agency ambivalence aboutOPM’s attention to compliance, MSPB believesthat this is a properly emphasized part of theoversight program that is essential to thebroader “protect and promote” goal.

Another means of achieving this goal isthrough providing assistance and direction toagencies to strengthen or guide their self-

assessment efforts, something hard for them todo in a era of shrinking resources. OPM’sactivity to influence agency programs is foundin the “effectiveness” part of MSO&E, whereconsiderable effort has been spent workingwith the eight agencies scheduled for reviewin FY 1998 to develop a self-assessmentagenda. This effort is only now being imple-mented, so it would be premature to attemptto measure its effectiveness. We agree with atop manager in one of the eight affectedagencies, however: because the self-assess-ment agenda contains no real measurableaspects, its usefulness may be limited. Thepresence of effective agency self-assessmentcapabilities is critical to protecting and pro-moting a merit-based civil service, andMSO&E should continue to assert its leader-ship, encouraging the development andimplementation of such capabilities.

With respect to the goal of identifying ways toimprove personnel polices and programs,OPM has missed opportunities to share helpfulinformation with the agencies. However,MSO&E plans to remedy this situation byimproving its approach to sharing informationconcerning best practices, and most likely bybeginning to share information concerningworst practices as well. Follow-through onthose plans should benefit all agencies, and weparticularly encourage the use of an OPMInternet website to disseminate thisinformation.

Helping agencies meet their mission goals, thethird oversight program goal, is the goal forwhich OPM’s efforts are least appreciated by

CHAPTER 6Conclusions and Recommendations


the agencies. To some extent this is because ofa fundamental truth: help, like beauty, is inthe eye of the beholder. The help that OPMoffers is still widely perceived as more nar-rowly focused and compliance-oriented thanmost agencies want or believe they need.

In addition, the nature and quality of theoversight staff’s contributions to this goal havebeen affected by the degree to which OPM hasachieved a consistency in philosophy andunity of approach in the oversight program.The oversight divisions are composed offormer regional employees (whose approachoften reflected the personas of their strongformer regional directors), employees placedthrough reductions in force elsewhere in OPM(and not necessarily conversant in evaluation),and newer employees hired to replace thosewho voluntarily departed during several yearsof fiscal pressure prior to 1994. The varyingbackgrounds, experience, and philosophies ofthese employees can create hurdles for OPM inachieving the nationwide program consistencythat is its aim. However, MSO&E manage-ment continues to work towards that goal.

Challenges to Goal Accomplishment. To agreat extent, the effectiveness of OPM’s over-sight program is, and will continue to be,influenced by changes that are taking place inthe broad context of the Federal workplace.Emphasis on measuring success on the basis ofresults rather than process has created a seachange in the HRM community, since FederalHRM activity historically has been measuredthrough compliance with processes andprocedures. Three problems arise as the effortis made to focus on results: (1) determiningwhat should be measured; (2) determininghow to measure what is to be measured; and(3) recognizing that some legal requirementsare process-driven, meaning that process mustbe considered as results are considered.

We have noted that it has proven difficult toestablish objective measures for assessingFederal HRM activity. Even the programcoverage guide for HRM accountability devel-oped for the FY 1998 review cycle lacks quan-tifiable measures against which to judge

agency self-assessment efforts. It is likely thatoversight and self-assessment of HRM willcontinue to rely heavily on the application ofseasoned judgment without the benefit ofmany quantifiable measures, although thesearch for such measures will (and should)continue.

Perhaps the biggest challenge facing theoversight program in today’s environment ishow to adjust so that it focuses attention onthe real locus of HRM accountability. Formore than 50 years the OPM program (andthat of its forerunner, the Civil Service Com-mission) has focused primarily on the work ofthe personnel office even as it stressed thatHRM is the dominion of line management.Although line managers and supervisors areincreasingly being recognized as thedecisionmakers responsible for HRM actions,the fact that few actions are final until “some-one in personnel” signs off on them meansthat the “someone in personnel” is still whereOPM’s evaluation program looks for account-ability. OPM, and agencies in their self-assessment efforts, must find a way to placeaccountability with managers and supervisors.

Managers and supervisors increasingly arebeing given new tools—particularly computer-based systems—to expand their HRM capabil-ity and to wean them from over-reliance upontheir supporting personnel offices. But thesemanagers and supervisors may not be receiv-ing timely or adequate training to properly usethose tools. Neither does it appear that theyare always provided adequate support fromthe remaining HR specialists in their agencies.Both line officials and their supporting HRstaffs are being cast into roles that requireskills and knowledge different from what wastypical only a few years ago. Giving goodHRM tools to managers untrained in their useand expecting those managers to be givenHRM advice and assistance by personnelspecialists unprepared to serve in this advisoryrole, is a double recipe for trouble.

Managers, supervisors, and HR specialists allneed to be made comfortable with the newreality. Training of individuals currently in


these positions and a sound approach toselecting their peers and replacements areimportant to reaching that comfort level. So isthe decision about who’s ultimately respon-sible for personnel actions. If the managerswho make the personnel decisions are trulyresponsible and have the delegated authority,they must be held accountable. Until this isaccomplished, “let the manager manage” maysimply mean that managers can take actionsthey find expedient, and the personnel officewill take the heat for any results that arecontrary to law, regulation, or policy. Theaccountability conundrum is one that OPMleadership, in conjunction with agencies, mustaddress and ultimately solve.

RecommendationsThe following recommendations are for con-sideration by the Director of OPM:

1. Continue to lead in the development ofbetter means of assessing Federal HRM onthe basis of results, and in developing thetools and training needed to measure HRMperformance.We believe the leadership effort must concen-trate first on ensuring consistency in howOPM’s oversight staff carry out its task, andthen on how OPM can contribute to thedevelopment of similar HRM assessment skillsin agencies through example, influence,training, and provision of effective tools.

2. Develop or lead in the development ofmeasurable standards to apply when evalu-ating HRM; in determining how best toassess “unquantifiables”; and in finding theproper balance between results and processin HR measures.Although measurable outcome standards areessential, there must be recognition that theproper application of process can be importantto upholding laws or achieving public policygoals.

3. Take the lead in changing the focus ofHRM accountability during oversight re-views from the personnel office to linemanagers and supervisors.

Unless accountability is focused on line man-agers, the risk remains that they will not beheld accountable for the consequences of theirHR decisions.

4. To encourage agencies to implementeffective HRM self-assessment programs,consider using a delegations agreementapproach similar to that currently used forexamining.Specifically, develop standards and delega-tions agreements which, if agreed to by anagency in writing, would make the agencyresponsible (and accountable) for its ownHRM oversight, and would result in OPM’soversight role being largely one of supportingthe agency and periodically reviewing andaffirming the effectiveness of its oversightefforts.

5. Encourage the OPM oversight staff toshare information with agencies on best andworst HRM practices. This informationshould be shared with both the HR commu-nity and with line managers, since ourreview identified problems with limitingsuch sharing to only one or the other of theseaudiences.We suggest making the information availablethrough an OPM web site, but not limiting theeffort to this means of dissemination.

6. Encourage other OPM program offices tomake timely and good use of informationprovided to them as a consequence of over-sight reviews, and encourage those offices toshare that information with departments andagencies as quickly and openly as possible.

The following recommendations are for con-sideration by managers in the Office of MeritSystems Oversight and Effectiveness:

7. Involve the oversight staff more in thedevelopment and implementation of agencyself-assessment efforts.These are the OPM staff members who, work-ing with staff in the Office of Merit SystemsEffectiveness, can lead by example and whocan offer practical advice and guidance on


agencies’ efforts. The aim should be a well-coordinated, cooperative oversight effortinvolving OPM and the individual agencies.

8. With respect to each report that is therecord of an oversight review, monitorclosely the language and tone of the execu-tive summary to ensure that the summaryaccurately conveys the findings reported inthe text of the full report.Because top managers may read only theexecutive summary, it is essential that thesummary does not obscure whatever problemsare reported in the full report.

The following recommendations are directedto the heads of departments and independentagencies:

9. Cooperate with OPM in developing waysto assess HRM on the basis of results; in

developing the tools and training needed toaccomplish this change in how HRM’sperformance is measured; in developingmeasurable standards to apply in HRMassessment; in determining how best toassess the unquantifiable aspects of HRM;and in finding the appropriate balancebetween focusing on results and emphasiz-ing process in HRM reviews.

10. Examine the resource commitments yourorganizations have made to HRM self-assessment, and determine whether thelevels of commitment leave you vulnerableto errors that could damage mission accom-plishment and harm the merit-based civilservice.Join with OPM in finding ways to hold man-agers genuinely accountable for their HRMdecisions and work with OPM in developing acooperative oversight approach.


Appendix

The Honorable Ben L. ErdreichChairmanU.S. Merit Systems Protection Board1120 Vermont Avenue, NW.Washington, DC 20419

Dear Mr. Erdreich:

I read your draft report on the activities of OPM’s Office of Merit Systems Oversight and Effectiveness(O&E) with great pleasure and satisfaction. The report conveys a real understanding of the challengesthis agency faces in discharging its responsibilities for oversight and improving human resourcesmanagement throughout Government Your observations are insightful and your recommendations righton target. Thank you for acknowledging the progress our Oversight and Effectiveness programs havemade, and yes, I agree, there is much we have yet to do.

I particularly want to thank you for the feedback you conveyed from our agency clients. Their appraisalof our progress corresponds to our own. We must do a much better job of identifying opportunities toimprove personnel policies and help agencies meet their mission goals through effective human re-sources management. Your encouragement to agencies to work more closely with OPM to improve theirhuman resources self-assessment efforts and to more adequately support them is much appreciated. Asyou know, OPM is pursuing a number of legislative and administrative initiatives that should go a longway towards making these improvements. I know that O&E will take each of your recommendationsseriously. Our efforts to respond to these recommendations are described in the enclosure.

Finally, I want to commend the professionalism of your staff who conducted this review, led by HarryRedd, and to thank you for acknowledging the cooperation of my Associate Director for O&E, Ms. CarolJ. Okin and her staff. I look forward to our continued cooperation in the years ahead as both of ouragencies pursue the common goal of a civil service that well and faithfully serves the American people.

Enclosure


OPM’s Response to the Recommendations of the U.S. Merit Systems Protection Board

Recommendation #1

Your positive assessment of O&E’s progress in shifting its focus from HRM process to results is greatlyappreciated. O&E is mindful that the flexibility the NPR called for and the requirements of the Results Act clearlyestablish the need to exercise oversight in a manner that appropriately emphasizes bottomline results rather thansimply process. We agree that HR results are more important to managers than HR process. However, we alsorecognize, as you do, that it will be a continuing challenge to get managers to accept that some processes arevital to certain legal and public policy requirements, such as veterans’ preference. Future efforts by O&E toeducate managers will reemphasize the need to achieve this proper balance.

We agree that one of the first steps to take in exercising leadership for establishing results-focused HRMassessment is to ensure that all O&E staff approach the agency oversight in a consistent manner. Since yourvisit, O&E has intensified its efforts to improve the consistency of its approach and of its products. Theseefforts include strengthening the O&E Council’s role in strategic planning, developing a model for the system-atic assessment of accomplishments; continuing to refine the Evaluation Handbook (the bible for line evalua-tors); ongoing discussions among division chiefs to achieve corrective action consistency; involving alldivisions in data analysis and the design of agency evaluation plans and program coverage guides; increasingthe involvement of the lead divisions in preparing and editing bureau-level and installation reports; administer-ing the Client Assessment Feedback forms following each evaluation; and developing a corporate trainingstrategy to provide staff with new analytic tools and a common method and vocabulary for situational analysis,problem solving, and decision making.

Working through the IAG Accountability Task Group, O&E will work harder to share its knowledge and tech-niques with agencies and encourage them to join in the development of better means for assessing HRMeffectiveness across Government. The Evaluation Handbook will be made available to agencies as part of thisleadership effort.

Recommendation #2

We fully support this recommendation. O&E’s Office of Effectiveness has the leadership for working withagencies to develop measurable standards for assessing HR results. OPM’s first attempt to develop HR stan-dards was, as you pointed out, the Personnel Management Indicators Report (PMIR). While well-intended,the PMIR was not embraced by agencies. Many saw it as a report card that did not recognize their vastdifferences, HR objectives, cultures, and strategies. Ultimately, the Board recommended that it no longer bedistributed. OPM agreed.

Developing quantifiable HR measures and universally accepted standards is very difficult since each agency hasits own unique and defining characteristics which dictate measures and standards which may not be applicablegenerally. Recognizing this, O&E is working with 16 agencies through the IAG Accountability Task Group toconstruct a framework of generic self-assessment measures (an HRM Accountability System DevelopmentGuide) that agencies can adapt to their particular environments.


Much of this framework is built around the outcomes-focused model that O&E is using to assess adherenceto the merit system principles during onsite evaluations. The model includes measures that track key HRsuccess indicators, such as OPM’s Merit System Principles Questionnaire, data from the Central PersonnelData File, agency personnel data, and client assessments. Agencies will be able to overlay this model withadditional measures and standards tailored to their individual accountability needs.

While OPM certainly must lead the effort within the Executive branch to implement measurable HR stan-dards, the success of our efforts depends greatly upon agency willingness to collaborate with us and makethe necessary investment required to have viable systems. The recommendations you have directed to theheads of departments and independent agencies are strongly commended, and we pledge our support andcooperation to make them a reality.

Recommendation #3

O&E does have a logical role in ensuring that the focus of HRM accountability is placed at the proper level.The Accountability Program Coverage Guide, which O&E is using in its FY 98 agency reviews, is helpingto draw managers’ attention to their responsibilities, authorities, and accountability for HRM. The roles andrelationships between personnelists and managers are in a state of transition and vary from agency toagency. In fact, each party is accountable but in different ways. Accountability systems must exist for HRadministration as well as HR management.

To help all parties better understand their HR roles, O&E has produced the Merit System Principles Educa-tion package. This package, which has been received enthusiastically by agencies, contains instructor andstudent guides on the principles, a brochure that lists the principles and prohibited personnel practices, anda Merit System Principles Mouse Pad that lists the principles. The idea is to keep the merit system principlesconstantly in sight, in a variety of ways.

O&E is carefully reviewing its oversight reports to make sure that the findings accurately reflect the respec-tive roles of managers and HR staff and that requirements for correction are directed to the appropriate,accountable party.

Recommendation #4 Note: This is recommendation #7 in this final report.

O&E is taking steps to involve its Oversight staff much more in the development and implementation ofagency self-assessment programs. As a first step, the Oversight staff are joining the Effectiveness staff onthe interagency task force that is developing the HRM Accountability System Development Guide. Inaddition, both staffs are meeting early with representatives of the agencies scheduled for review in FY 99 tofacilitate a proper integration of Oversight staff into agency self-assessment strategies. The Oversight staffwill be extensively involved in activities to revise the Accountability Program Coverage Guide to focusmore directly on HRM strategic planning, the roles of managers and HR professionals, and the effects of HRconsolidations and reductions on the delivery of agency services.


Recommendation #5 Note: This is recommendation #4 in this final report.Your recommendation that O&E develop written oversight agreements with agencies in order to encour-age agency self-assessment programs is very interesting and will be given serious consideration as O&Econtinues to evolve. Agencies must strengthen their self-assessment efforts if there is to be genuineHRM accountability. O&E’s efforts to help agencies develop accountability systems are laying thegroundwork for such oversight. The status or health of an agency’s accountability efforts already has alot to do with how an agency-focused review is designed. As agency and OPM efforts to developaccountability models and standards progress, we will find more opportunities to transform the oversightof those agencies that have effective accountability systems.


The recommendation to share best and worst HRM practices with both the HR community and withmanagers is one we are working on right now. O&E is doing this through the Oversight Notes. The Notespublicize lessons learned and the innovative practices that are identified during oversight reviews. Theformat is concise and easy to read, avoiding personnel jargon and technical language that may beunfamiliar to managers. Distribution is quarterly to installation heads and appointing officers and willsoon be made to Federal Executive Boards and Federal Executive Associations. Several agencies haverequested and received an electronic version for distribution through their e-mail systems. O&E willexplore electronic and other means of distribution that will retain the informal character of the Notes.

O&E plans to explore other forums that can be used to discuss OPM’s oversight findings and foster theadoption of best practices, such as participating in agency conferences, holding special-purpose work-shops for agencies, IAG presentations, and satellite broadcasts. We intend to take full advantage of suchopportunities in the future.


It is essential, as you point out, that the executive summaries of O&E oversight reports accurately reflectthe significance and the tone of the findings in the body of the reports. We have identified this sameconcern. O&E is carefully reviewing these summaries to make certain that they focus top management’sattention on the key issues that require intervention or involvement at that level.


OPM has made a strong effort in recent years to improve effectiveness of our information sharing, bothinternally and externally. As noted in the report, O&E has made a point of passing on information torelevant program offices, and the offices are making good use of this information. We will certainlycontinue in that vein, recognizing too that the Governmentwide policy making process is a complex andsometimes lengthy endeavor. Issues must be vetted, stakeholders consulted, and the regulatory orlegislative process completed before the information gathered by O&E can actually be translated into newor improved policies. We certainly agree that it is essential to keep the focus of the Oversight andEffectiveness program on issues that are critical to the Federal HRM community and to use the informa-tion gathered by that program to develop and implement effective HRM policies and programs.

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