Defense Transformation
DOD's Proposed Civilian Personnel System and Governmentwide Human Capital Reform Gao ID: GAO-03-741T May 1, 2003DOD is in the midst of a major transformation effort including a number of initiatives to transform its forces and improve its business operations. DOD's legislative initiative would provide for major changes in civilian and military human capital management, make major adjustments in the DOD acquisition process, affect DOD's organization structure, and change DOD's reporting requirements to Congress, among other things. DOD's proposed National Security Personnel System (NSPS) would provide for wide-ranging changes in DOD's civilian personnel pay and performance management, collective bargaining, rightsizing, and a variety of other human capital areas. The NSPS would enable DOD to develop and implement a consistent DOD-wide civilian personnel system. This testimony provides GAO's preliminary observations on aspects of DOD's legislative proposal to make changes to its civilian personnel system and discusses the implications of such changes for governmentwide human capital reform. This testimony summarizes many of the issues discussed in detail before the Subcommittee on Civil Service and Agency Organization, Committee on Government Reform, House of Representatives on April 29, 2003.
Many of the basic principles underlying DOD's civilian human capital proposal have merit and deserve serious consideration. The federal personnel system is clearly broken in critical respects--designed for a time and workforce of an earlier era and not able to meet the needs and challenges of our current rapidly changing and knowledge-based environment. DOD's proposal recognizes that, as GAO has stated and the experiences of leading public sector organizations here and abroad have found, strategic human capital management must be the centerpiece of any serious government transformation effort. More generally, from a conceptual standpoint, GAO strongly supports the need to expand broad banding and pay for performance-based systems in the federal government. However, moving too quickly or prematurely at DOD or elsewhere, can significantly raise the risk of doing it wrong. This could also serve to severely set back the legitimate need to move to a more performance- and results-based system for the federal government as a whole. Thus, while it is imperative that we take steps to better link employee pay and other personnel decisions to performance across the federal government, how it is done, when it is done, and the basis on which it is done, can make all the difference in whether or not we are successful. One key need is to modernize performance management systems in executive agencies so that they are capable of supporting more performance-based pay and other personnel decisions. Unfortunately, based on GAO's past work, most existing federal performance appraisal systems, including a vast majority of DOD's systems, are not currently designed to support a meaningful performance-based pay system. The critical questions to consider are: should DOD and/or other agencies be granted broad-based exemptions from existing law, and if so, on what basis? Do DOD and other agencies have the institutional infrastructure in place to make effective use of any new authorities? This institutional infrastructure includes, at a minimum, a human capital planning process that integrates the agency's human capital policies, strategies, and programs with its program goals and mission, and desired outcomes; the capabilities to effectively develop and implement a new human capital system; and, importantly, a set of adequate safeguards, including reasonable transparency and appropriate accountability mechanisms to ensure the fair, effective, and credible implementation of a new system. In GAO's view, as an alternative to DOD's proposed approach, Congress should consider providing governmentwide broad banding and pay for performance authorities that DOD and other federal agencies can use provided they can demonstrate that they have a performance management system in place that meets certain statutory standards, that can be certified to by a qualified and independent party, such as OPM, within prescribed timeframes. Congress should also consider establishing a governmentwide fund whereby agencies, based on a sound business case, could apply for funding to modernize their performance management systems and ensure that those systems have adequate safeguards to prevent abuse. This approach would serve as a positive step to promote high-performing organizations throughout the federal government while avoiding further human capital policy fragmentation.
GAO-03-741T, Defense Transformation: DOD's Proposed Civilian Personnel System and Governmentwide Human Capital Reform
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United States General Accounting Office:
GAO:
For Release on Delivery Expected at 9:00 a.m. EDT:
Thursday, May 1, 2003:
Defense Transformation:
DOD's Proposed Civilian Personnel System and Governmentwide Human
Capital Reform:
Statement of David M. Walker
Comptroller General of the United States:
GAO-03-741T:
GAO Highlights:
Highlights of GAO-03-741T, testimony before the Committee on Armed
Services, House of Representatives
Why GAO Did This Study:
DOD is in the midst of a major transformation effort including a number
of initiatives to transform its forces and improve its business
operations. DOD‘s legislative initiative would provide for major
changes in civilian and military human capital management, make major
adjustments in the DOD acquisition process, affect DOD‘s organization
structure, and change DOD‘s reporting requirements to Congress, among
other things.
DOD‘s proposed National Security Personnel System (NSPS) would provide
for wide-ranging changes in DOD‘s civilian personnel pay and
performance management, collective bargaining, rightsizing, and a
variety of other human capital areas. The NSPS would enable DOD to
develop and implement a consistent DOD-wide civilian personnel system.
This testimony provides GAO‘s preliminary observations on aspects of
DOD‘s legislative proposal to make changes to its civilian personnel
system and discusses the implications of such changes for
governmentwide human capital reform. This testimony summarizes many of
the issues discussed in detail before the Subcommittee on Civil Service
and Agency Organization, Committee on Government Reform, House of
Representatives on April 29, 2003.
What GAO Found:
Many of the basic principles underlying DOD‘s civilian human capital
proposal have merit and deserve serious consideration. The federal
personnel system is clearly broken in critical respects”designed for a
time and workforce of an earlier era and not able to meet the needs and
challenges of our current rapidly changing and knowledge-based
environment. DOD‘s proposal recognizes that, as GAO has stated and the
experiences of leading public sector organizations here and abroad have
found, strategic human capital management must be the centerpiece of
any serious government transformation effort.
More generally, from a conceptual standpoint, GAO strongly supports the
need to expand broad banding and pay for performance-based systems in
the federal government. However, moving too quickly or prematurely at
DOD or elsewhere, can significantly raise the risk of doing it wrong.
This could also serve to severely set back the legitimate need to move
to a more performance- and results-based system for the federal
government as a whole. Thus, while it is imperative that we take steps
to better link employee pay and other personnel decisions to
performance across the federal government, how it is done, when it is
done, and the basis on which it is done, can make all the difference in
whether or not we are successful. One key need is to modernize
performance management systems in executive agencies so that they are
capable of supporting more performance-based pay and other personnel
decisions. Unfortunately, based on GAO‘s past work, most existing
federal performance appraisal systems, including a vast majority of
DOD‘s systems, are not currently designed to support a meaningful
performance-based pay system.
The critical questions to consider are: should DOD and/or other
agencies be granted broad-based exemptions from existing law, and if
so, on what basis? Do DOD and other agencies have the institutional
infrastructure in place to make effective use of any new authorities?
This institutional infrastructure includes, at a minimum, a human
capital planning process that integrates the agency‘s human capital
policies, strategies, and programs with its program goals and mission,
and desired outcomes; the capabilities to effectively develop and
implement a new human capital system; and, importantly, a set of
adequate safeguards, including reasonable transparency and appropriate
accountability mechanisms to ensure the fair, effective, and credible
implementation of a new system.
In GAO‘s view, as an alternative to DOD‘s proposed approach, Congress
should consider providing governmentwide broad banding and pay for
performance authorities that DOD and other federal agencies can use
provided they can demonstrate that they have a performance management
system in place that meets certain statutory standards, that can be
certified to by a qualified and independent party, such as OPM, within
prescribed timeframes. Congress should also consider establishing a
governmentwide fund whereby agencies, based on a sound business case,
could apply for funding to modernize their performance management
systems and ensure that those systems have adequate safeguards to
prevent abuse. This approach would serve as a positive step to promote
high-performing organizations throughout the federal government while
avoiding further human capital policy fragmentation.
www.gao.gov/cgi-bin/getrpt?GAO-03-741T.
To view the full testimony, click on the link above. For more
information, contact Derek Stewart at (202) 512-5559 or
stewartd@gao.gov.
[End of section]
Chairman Hunter, Mr. Skelton, and Members of the Committee:
It is a pleasure to appear before you today to provide our preliminary
observations on the Department of Defense's (DOD) proposed National
Security Personnel System (NSPS) included as part of the Defense
Transformation for the 21st Century Act of 2003. As you know, I
testified on Tuesday on the NSPS before the Subcommittee on Civil
Service and Agency Organization, House Committee on Government
Reform.[Footnote 1] We have provided the statement prepared for that
hearing to the Armed Services Committee for the record for today's
hearing. Therefore, in the interests of brevity this morning, I will
highlight some of the major points covered in that statement.
DOD is in the midst of a major transformation and it has undertaken a
number of related initiatives to transform its forces and fundamentally
improve its business operations. As part of DOD's transformation
process, the Secretary of Defense and senior civilian and military
leaders have committed to adopt a capabilities-based approach to
acquisition planning and to improve the linkage between overall
strategy and individual investments. At the same time, DOD has embarked
on a series of efforts to achieve strategic savings and improve its
business processes, including strengthened financial management,
support infrastructure reforms to include base closures, information
technology modernization, logistics reengineering, and more strategic
human capital management. In that regard, I am pleased to serve as an
observer to the Defense Business Practice Implementation Board.
Notwithstanding these ongoing efforts, GAO has reported a range of DOD
challenges for many years. Importantly, DOD also is covered by 9 of the
25 areas on our January 2003 high-risk list, including the area of
strategic human capital management.
The proposed Defense Transformation for the 21st Century Act of 2003
represents a substantive legislative proposal that has far-reaching
implications for the way DOD is managed. DOD's legislative initiative
would, among other things, provide for major changes in civilian and
military human capital management, make important adjustments to the
DOD acquisition process, affect DOD's organization structure, and
change DOD's reporting requirements to Congress. While my written
statement today covers just the proposed civilian personnel reforms, I
have some serious concerns with other sections of the proposed
legislation especially in connection with the acquisition reform and
reporting requirements parts of the DOD proposal, and I look forward to
discussing those concerns with the Committee.
DOD's NSPS proposal recognizes that, as GAO has stated and the
experiences of leading public sector organizations here and abroad have
found, strategic human capital management must be the centerpiece of
any serious government transformation effort. Many of the basic
principles underlying DOD's civilian human capital proposals have merit
and deserve serious consideration. The federal personnel system is
clearly broken in critical respects--designed for a time and workforce
of an earlier era and not able to meet the needs and challenges of our
current rapidly changing and knowledge-based environment. The proposed
NSPS would provide for wide-ranging changes in DOD's civilian personnel
pay and performance management, collective bargaining, rightsizing, and
a variety of other human capital areas. The NSPS would enable DOD to
develop and implement a consistent, DOD-wide civilian personnel system
bringing together the many disparate systems that exist today. DOD
officials have said that the Department's current thinking is that NSPS
will be based on the work done by DOD's Human Resources Best Practices
Task Force. The Task Force reviewed federal personnel demonstration
projects and selected alternative personnel systems to identify
practices that it considered promising for a DOD civilian human
resources strategy. These practices were outlined in a April 2, 2003,
Federal Register notice asking for comment on DOD's plan to integrate
all of its current science and technology reinvention laboratory
demonstration projects under a single human capital framework
consistent with the best practices DOD identified.[Footnote 2]
Given the massive size of DOD and the nature and scope of the changes
that are being considered, DOD's proposal also has important precedent-
setting implications for federal human capital management in general,
and the Office of Personnel Management (OPM), in particular. As a
result, NSPS should be considered in that context. Several critical
questions are raised by the Department's proposal, including should DOD
and/or other agencies be granted broad-based exemptions from existing
law, and if so, on what basis; and whether they have the institutional
infrastructure in place to make effective use of the new authorities.
This institutional infrastructure includes, at a minimum, a human
capital planning process that integrates the agency's human capital
policies, strategies, and programs with its program goals and mission,
and desired outcomes; the capabilities to effectively develop and
implement a new human capital system; and importantly, the existence of
a modern, effective, and credible performance management system that
includes adequate safeguards, including reasonable transparency and
appropriate accountability mechanisms, to ensure the fair, effective,
and non-discriminatory implementation of a new system. Based on our
experience, while the DOD leadership has the intent and the ability to
implement the needed infrastructure, it is not consistently in place
across DOD at the present time.
I believe that it would be more prudent and appropriate for Congress to
address certain authorities that DOD is seeking on a governmentwide
basis and in a manner that assures that appropriate performance
management systems and safeguards are in place before the new
authorities are implemented in any respective agency. This approach
would accelerate needed human capital reform throughout the government
in a manner that assures reasonable consistency on key principles
within the overall civilian workforce. It also would provide agencies
with reasonable flexibility while incorporating key safeguards to help
maximize the chances of success and minimize the chances of abuse or
significant litigation.
Adequate Safeguards, Reasonable Transparency, Appropriate
Accountability, and Governmentwide Reform:
There is growing agreement on the need to better link individual pay to
performance. Establishing such linkages is essential if we expect to
maximize the performance and assure the accountability of the federal
government for the benefit of the American people. As a result, from a
conceptual standpoint, we strongly support the need to expand broad
banding approaches and pay for performance-based systems in the federal
government. However, moving too quickly or prematurely at DOD or
elsewhere can significantly raise the risk of doing it wrong. This
could also serve to severely set back the legitimate need to move to a
more performance-and results-based system for the federal government as
a whole. Thus, while it is imperative that we take steps to better link
employee pay to performance across the federal government, how it is
done, when it is done, and the basis on which it is done can make all
the difference in whether or not such efforts are successful. In our
view, one key need is to modernize performance management systems in
executive agencies so that they are capable of adequately supporting
more performance-based pay and other personnel decisions.
Unfortunately, based on GAO's past work, most existing federal
performance appraisal systems, including a vast majority of DOD's
systems, are not designed to support a meaningful performance-based pay
system.
At the request of Representative Jo Ann Davis and Senator George
Voinovich, we identified key practices leading public sector
organizations both here in the United States and abroad have used in
their performance management systems to link organizational goals to
individual performance and create a "line of sight" between an
individual's activities and organizational results.[Footnote 3] These
practices can help agencies develop and implement performance
management systems with the attributes necessary to effectively support
pay for performance.
The bottom line, however, is that in order to implement any additional
performance-based pay flexibility for broad based employee groups,
agencies should have to demonstrate that they have modern, effective,
credible, and, as appropriate, validated performance management systems
in place with adequate safeguards, including reasonable transparency
and appropriate accountability mechanisms, to ensure fairness and
prevent politicalization and abuse. As a result, Congress should
consider establishing statutory standards that an agency must have in
place before it can implement broad banding or a more performance-based
pay program.
At the request of Congressman Danny Davis, we developed an initial list
of possible safeguards for Congress to consider to help ensure that any
pay for performance systems in the government are fair, effective, and
credible:
* Assure that the agency's performance management systems (1) link to
the agency's strategic plan, related goals, and desired outcomes, and
(2) result in meaningful distinctions in individual employee
performance. This should include consideration of critical competencies
and achievement of concrete results.
* Involve employees, their representatives, and other stakeholders in
the design of the system, including having employees directly involved
in validating any related competencies, as appropriate.
* Assure that certain predecisional internal safeguards exist to help
achieve the consistency, equity, nondiscrimination, and
nonpoliticization of the performance management process (e.g.,
independent reasonableness reviews by Human Capital Offices and/or
Offices of Opportunity and Inclusiveness or their equivalent in
connection with the establishment and implementation of a performance
appraisal system, as well as reviews of performance rating decisions,
pay determinations, and promotion actions before they are finalized to
ensure that they are merit-based; internal grievance processes to
address employee complaints; and pay panels whose membership is
predominately made up of career officials who would consider the
results of the performance appraisal process and other information in
connection with final pay decisions).
* Assure reasonable transparency and appropriate accountability
mechanisms in connection with the results of the performance management
process (e.g., publish overall results of performance management and
pay decisions while protecting individual confidentiality, and report
periodically on internal assessments and employee survey results).
The above items should help serve as a starting point for Congress to
consider in crafting possible statutory safeguards for executive
agencies' performance management systems. OPM would then issue guidance
implementing the legislatively defined safeguards. The effort to
develop such safeguards could be part of a broad-based expanded pay for
performance authority under which whole agencies and/or employee groups
could adopt broad-banding and move to more pay for performance oriented
systems if certain conditions are met. Specifically, an agency would
have to demonstrate, and OPM would have to certify, that a modern,
effective, credible, and, as appropriate, validated performance
management system with adequate safeguards, including reasonable
transparency and appropriate accountability mechanisms, is in place to
support more performance-based pay and related personnel decisions,
before the agency could implement a new system. OPM should be required
to act on any individual certifications within prescribed time frames
(e.g., 30-60 days).
This alternative approach would allow for a broader-based yet more
conceptually consistent approach to linking federal employee pay and
other personnel decisions to performance. It would help to assure that
agencies have the reasonable flexibility they need to modernize their
human capital policies and practices, while maximizing the chances of
success and minimizing the potential for abuse. This alternative
approach would also facilitate a phased-implementation approach
throughout government.
Congress should also consider establishing a governmentwide fund
whereby agencies, based on a sound business case, could apply for funds
to modernize their performance management systems and ensure those
systems have adequate safeguards to prevent abuse. This approach would
serve as a positive step to promote high-performing organizations
throughout the federal government while avoiding human capital policy
fragmentation within the executive branch.
Observations on Selected Provisions of the Proposed NSPS:
With almost 700,000 civilian employees on its payroll, DOD is the
second largest federal employer of civilians in the nation, after the
Postal Service. Defense civilian personnel, among other things, develop
policy, provide intelligence, manage finances, and acquire and maintain
weapon systems. NSPS is intended to be a major component of DOD's
efforts to more strategically manage its workforce and respond to
current and emerging challenges. This morning I will highlight several
of the key provisions of NSPS that in our view are most in need of
close scrutiny as Congress considers the DOD proposal:
* The DOD proposal would allow the Secretary of Defense to jointly
prescribe regulations with the Director of OPM to establish NSPS.
However, unlike the legislation creating the Department of Homeland
Security (DHS), the Defense Transformation for the 21st Century Act
would allow the Secretary of Defense to waive the requirement for joint
issuance of regulations if, in his or her judgment, it is "essential to
the national security" which is not defined in the act. Therefore, the
act would, in substance, provide the Secretary of Defense with
significant independent authority to develop a separate and largely
autonomous human capital system for DOD.
* As I have noted, performance-based pay flexibility for broad-based
employee groups should be grounded in performance management systems
that are capable of supporting pay and related decisions. DOD's
personnel demonstration projects clearly provide helpful insights and
valuable lessons learned in connection with broad banding and pay for
performance efforts. At the same time these projects and related DOD
efforts involve less than 10 percent of DOD's civilian workforce and
expanding these approaches to the entire department will require
significant effort and likely need to be implemented in phases over
several years.
* Similarly, the NSPS would increase the current total allowable annual
compensation limit for senior executives up to the Vice President's
total annual compensation. The Homeland Security Act provided that OPM,
with the concurrence of the Office of Management and Budget, certify
that an agency has performance appraisal systems that, as designed and
applied, make meaningful distinctions based on relative performance
before an agency is allowed to increase the annual compensation limit
for senior executives. NSPS does not include such a certification
provision. On the other hand, the Senior Executive Service needs to
take the lead in matters related to pay for performance.
* The NSPS would include provisions intended to ensure collaboration
with employee representatives in the planning, development, and
implementation of a human resources management system. As discussed at
the Civil Service and Agency Organization Subcommittee, Committee on
Government Reform hearing on Tuesday, direct employee involvement in
the development of the NSPS legislative proposal has thus far been
limited. Moving forward, and aside from the specific statutory
provisions on consultation, the active involvement of employees will be
critical to the success of NSPS, or for any human capital reform for
that matter.
* The legislation has a number of provisions designed to give DOD
flexibility to help obtain key critical talent. These authorities give
DOD considerable flexibility to obtain and compensate individuals and
exempt them from several provisions of current law. While we have
strongly endorsed providing agencies with additional tools and
flexibilities to attract and retain needed talent, the broad exemption
from some existing ethics and other personnel authorities without
prescribed limits on their use raises some concern. Congress should
consider building into the NSPS appropriate numerical or percentage
limitations on the use of these provisions and basic safeguards to
ensure such provisions are used appropriately.
* The NSPS proposal would provide DOD with a number of broad
authorities related to rightsizing and organizational alignment.
Authorities such as voluntary early retirements have proven to be
effective tools in strategically managing the shape of the workforce. I
have exercised the authority that Congress granted me to offer
voluntary early retirements in GAO in both fiscal years 2002 and 2003
as one element of our strategy to shape the GAO workforce. In DOD's
case, while it has used existing authorities to mitigate the adverse
effects of force reductions in the past, the Department's approach to
those reductions was not oriented toward strategically shaping the
makeup of the workforce. Given these problems, there is reason to be
concerned that DOD may struggle to effectively manage additional
authorities that may be provided. Importantly, the NSPS provisions
would create an uneven playing field among agencies in competing for
experienced talent.
* The legislation would also allow DOD to revise Reduction-in-Force
(RIF) rules to place greater emphasis on an employee's performance. I
conceptually support revised RIF procedures that involve much greater
consideration of an employee's performance. However, as noted above,
agencies must have the proper performance management systems in place
to effectively and fairly implement such authorities. Furthermore, DOD
proposes to lower the degree of preference provided to veterans under
current law.
* The proposed NSPS would allow the Secretary, after consultation with
the Merit Systems Protection Board, to prescribe regulations providing
fair treatment in any appeals brought by DOD employees relating to
their employment. The proposal states that the appeals procedures shall
ensure due process protections and expeditious handling, to the maximum
extent possible. This provision is substantially the same as a similar
provision in the Homeland Security Act of 2002 allowing DHS to
prescribe regulations for employee appeals related to their employment.
Given the transparency of the federal system dispute resolution and its
attendant case law, the rights and obligations of the various parties
involved are well developed. It is critical that any due process
changes that DOD would make under this authority are not only fair and
efficient but, importantly, minimize any perception of unfairness.
Concluding Observations:
In summary, many of the basic principles underlying DOD's civilian
human capital proposals have merit and deserve serious consideration.
They are, however, unprecedented in their size, scope, and
significance. As a result, they should be considered carefully--and not
just from a DOD perspective. The DOD proposal has significant
precedent-setting implications for the human capital area in government
in general, and for OPM in particular.
The DOD civilian human capital proposal raises several critical
questions both for DOD as well as for governmentwide policies and
approaches. Should DOD and/or other federal agencies be granted broad-
based exemptions from existing law, and if so, on what basis? Does DOD
have the institutional infrastructure in place to make effective use of
the new authorities? Our work has shown that while progress is being
made, additional efforts are needed by DOD to integrate its human
capital planning process with the department's program goals and
mission. The practices that have been shown to be critical to the
effective use of flexibilities provide a validated roadmap for DOD and
Congress to consider.[Footnote 4] We believe it would be more prudent
and appropriate to approve the broad banding and pay for performance
issues on a governmentwide basis. Nevertheless, if additional
authorities are granted to DOD, Congress should consider establishing
additional safeguards to ensure the fair, merit-based, transparent, and
accountable implementation of NSPS. This includes addressing the issues
I have raised in this statement.
As I have suggested, Congress should consider providing governmentwide
broad banding and pay for performance authorities that DOD and other
federal agencies can use provided they can demonstrate that they have a
performance management system in place that meets certain statutory
standards and can be certified to by a qualified and independent party,
such as OPM. Congress should also consider establishing a
governmentwide fund whereby agencies, based on a sound business case,
could apply for funds to modernize their performance management systems
and ensure that those systems have adequate safeguards to prevent
abuse. This would serve as a positive step to promote high-performing
organizations throughout the federal government while avoiding further
fragmentation within the executive branch in critical human capital
policies and approaches.
We look forward to continuing to support Congress and work with DOD in
addressing the vital transformation challenges it faces.
Chairman Hunter, Mr. Skelton, and Members of the Committee, this
concludes my prepared statement. I would be pleased to respond to any
questions that you may have.
Contacts and Acknowledgments:
For further information on human capital issues at DOD, please contact
Derek Stewart, Director, Defense Capabilities and Management on (202)
512-5559 or at stewartd@gao.gov. For further information on
governmentwide human capital issues, please contact J. Christopher
Mihm, Director, Strategic Issues, on (202) 512-6806 or at
mihmj@gao.gov. Individuals making key contributions to this testimony
included William Doherty, Clifton G. Douglas, Jr., Christine Fossett,
Bruce Goddard, Judith Kordahl, Janice Lichty, Bob Lilly, Lisa Shames,
Ellen Rubin, Edward H. Stephenson, Jr., Tiffany Tanner, Marti Tracy,
and Michael Volpe.
FOOTNOTES
[1] U.S. General Accounting Office, Defense Transformation: Preliminary
Observations on DOD's Proposed Civilian Personnel Reforms, GAO-03-717T
(Washington, D.C.: Apr. 29, 2003).
[2] 68 Fed. Reg. 16,119-16,142 (2003).
[3] U.S. General Accounting Office, Results-Oriented Cultures: Creating
a Clear Linkage between Individual Performance and Organizational
Success, GAO-03-488 (Washington, D.C.: Mar. 14, 2003).
[4] U.S. General Accounting Office, Defense Transformation: Preliminary
Observations on DOD's Proposed Civilian Personnel Reforms, GAO-03-717T
(Washington, D.C.: Apr. 29, 2003).
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