Performance Management
DOD Is Terminating the National Security Personnel System, but Needs a Strategic Plan to Guide Its Design of a New System Gao ID: GAO-11-524R April 28, 2011The Department of Defense (DOD) is one of the largest and most complex organizations in the world and faces challenges in managing its human capital--particularly its diverse civilian workforce. Our prior work has noted that over time federal positions, including those within DOD, have become increasingly specialized and more highly skilled, resulting in a need for managers to have greater flexibility in hiring and compensating employees. As a result, the department took steps--pursuant to the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2004--to provide managers with greater flexibility in hiring and implemented a performance management system that sought to reward civilian employees' performance and contributions to the agencies' missions rather than to reward longevity in a position. Specifically, in 2004, DOD established the National Security Personnel System (NSPS)--a human capital system that significantly redesigned the rules, regulations, and processes that governed the way civilian employees were hired, compensated, and promoted at DOD. In 2006, the department began converting its civilian employees to NSPS. From its inception, NSPS was criticized and faced challenges from unions and employees regarding several issues, including inconsistent application of the system, pay inequities, and a lack of stakeholder involvement. Since 2003, we have reported on NSPS, covering issues such as DOD's initial regulations for the system and the pace at which it was implemented. We noted in these reports that how human capital reform is done, when it is done, and the basis upon which it is done can make a difference in whether such efforts are successful. In light of the concerns and challenges facing NSPS, the NDAA for FY 2010 contained provisions to terminate the system. Specifically, the act repealed the statutory authority for NSPS and directed the Secretary of Defense to begin, no later than 6 months from the enactment of the law, to take all actions necessary to provide for the orderly termination of NSPS and the conversion of all NSPS employees and positions from NSPS. The act also provided direction regarding DOD's pay and personnel system and a new performance management system. More specifically, regarding the pay and personnel systems, the act directed the Secretary to (1) convert employees, no later than January 1, 2012, to the statutory pay system and all other aspects of the personnel system that last applied or would have applied if NSPS had not been established and (2) ensure that no employee shall suffer any loss of or decrease in pay as a result of the conversion. Regarding the new performance management system, the act directed the Secretary to promulgate, in coordination with the Director of the Office of Personnel Management, regulations providing for, among other things, (1) a fair, credible, and transparent performance appraisal system for employees that links bonuses and other performance-based actions to performance appraisals; (2) a process for ensuring ongoing feedback and dialogue; and (3) development of a plan designed to give employees training, counseling, mentoring, and other assistance. The act did not specify a date for completion of DOD's new performance management system. At the time that DOD's authority for NSPS was repealed, approximately 226,000 DOD civilian employees throughout the department were under the system
During fiscal year 2010, DOD achieved its initial goal of transitioning approximately 75 percent of NSPS employees to their successor pay and personnel system--that is, the General Schedule system--despite having to overcome some challenges. DOD plans to transition the remaining NSPS employees by the January 1, 2012, mandated deadline. Specifically, according to DOD's October 2010 report, the department transitioned, as planned, approximately 172,000 of the 226,000 NSPS employees to the General Schedule system. Regarding challenges, component officials told us that they completed the reclassifications of employees back to the General Schedule system even though in some cases it was difficult to meet deadlines--occasionally requiring the use of contractors or overtime. For the remaining NSPS employees--approximately 53,000--the department plans to complete those transitions in five groups. More specifically, employees in 30 health care provider occupations will return to the General Schedule system from July to December 2011, and employees in other miscellaneous categories (e.g., deployed civilians and those affected by base realignment and closure activities) will transition to the appropriate pay and personnel system no later than December 2011. The remaining three groups of NSPS employees will transition to the following alternative pay and personnel systems during the time frames noted: Science and Technology Reinvention Laboratories from February to April 2011, Acquisition Demonstration Project from March to June 2011, and Physicians and Dentists Pay Plan in June 2011. The Transition Office issued guidance to the components for tracking the costs of the NSPS termination; however, the office did not sufficiently document and support termination costs, and we found inconsistencies in some reported costs. The guidance instructed the components to, among other things, (1) report only the costs that were directly attributable to NSPS termination and (2) include five categories of costs in the cost tracking reports--one category being Within-Grade Increase Buy-Ins, Performance Awards, and Quality Step Increases. Regarding insufficient documentation, we found, for example, that the Transition Office reported $238.6 million (as projected by the Transition Office and Comptroller's Office) to Congress as the estimated fiscal year 2011 departmentwide costs for increased compensation resulting from the termination. However, despite our repeated requests during the course of our review, DOD did not provide documentation to support this estimate or the methodology used to develop this estimate. Transition Office officials told us that the department had experienced turnover in both the Comptroller's Office and the Transition Office since those estimates had been developed. Internal control standards state that all transactions and other significant events need to be clearly documented and that documentation should be readily available for examination. To promote an efficient use of resources and to better plan for the design of a new performance management system, we recommend that the Secretary of Defense direct the Deputy Assistant Secretary of Defense for Civilian Personnel Policy to take the following two actions: (1) in conjunction with the DOD Comptroller, help ensure that information identifying and supporting the costs of the NSPS termination and new performance management system is documented, reliable, traceable to a source document, and readily available for examination, and (2) develop a plan with documented near-term design and implementation goals and a timeline for meeting these goals to build momentum and show progress for the development of an enterprisewide performance management system and to facilitate an assessment of what is being achieved as a result of the resources being spent.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Brenda S. Farrell Team: Government Accountability Office: Defense Capabilities and Management Phone: (202) 512-3604GAO-11-524R, Performance Management: DOD Is Terminating the National Security Personnel System, but Needs a Strategic Plan to Guide Its Design of a New System
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GAO-11-524R:
United States Government Accountability Office:
Washington, DC 20548:
April 28, 2011:
The Honorable J. Randy Forbes:
Chairman:
The Honorable Madeleine Z. Bordallo:
Ranking Member:
Subcommittee on Readiness:
Committee on Armed Services:
House of Representatives:
Subject: Performance Management: DOD Is Terminating the National
Security Personnel System, but Needs a Strategic Plan to Guide Its
Design of a New System:
The Department of Defense (DOD) is one of the largest and most complex
organizations in the world and faces challenges in managing its human
capital--particularly its diverse civilian workforce.[Footnote 1] Our
prior work has noted that over time federal positions, including those
within DOD, have become increasingly specialized and more highly
skilled, resulting in a need for managers to have greater flexibility
in hiring and compensating employees.[Footnote 2] As a result, the
department took steps--pursuant to the National Defense Authorization
Act (NDAA) for Fiscal Year (FY) 2004[Footnote 3]--to provide managers
with greater flexibility in hiring and implemented a performance
management system that sought to reward civilian employees'
performance and contributions to the agencies' missions rather than to
reward longevity in a position. Specifically, in 2004, DOD established
the National Security Personnel System (NSPS)--a human capital system
that significantly redesigned the rules, regulations, and processes
that governed the way civilian employees were hired, compensated, and
promoted at DOD.[Footnote 4] In 2006, the department began converting
its civilian employees to NSPS.
From its inception, NSPS was criticized and faced challenges from
unions and employees regarding several issues, including inconsistent
application of the system, pay inequities, and a lack of stakeholder
involvement. Since 2003, we have reported on NSPS, covering issues
such as DOD's initial regulations for the system and the pace at which
it was implemented.[Footnote 5] We noted in these reports that how
human capital reform is done, when it is done, and the basis upon
which it is done can make a difference in whether such efforts are
successful.
In light of the concerns and challenges facing NSPS, the NDAA for FY
2010 contained provisions to terminate the system.[Footnote 6]
Specifically, the act repealed the statutory authority for NSPS and
directed the Secretary of Defense to begin, no later than 6 months
from the enactment of the law, to take all actions necessary to
provide for the orderly termination of NSPS and the conversion of all
NSPS employees and positions from NSPS.[Footnote 7] The act also
provided direction regarding DOD's pay and personnel system and a new
performance management system.[Footnote 8] More specifically,
regarding the pay and personnel systems, the act directed the
Secretary to (1) convert employees, no later than January 1, 2012, to
the statutory pay system and all other aspects of the personnel system
that last applied or would have applied if NSPS had not been
established and (2) ensure that no employee shall suffer any loss of
or decrease in pay as a result of the conversion. Regarding the new
performance management system, the act directed the Secretary to
promulgate, in coordination with the Director of the Office of
Personnel Management, regulations providing for, among other things,
(1) a fair, credible, and transparent performance appraisal system
[Footnote 9] for employees that links bonuses and other performance-
based actions to performance appraisals; (2) a process for ensuring
ongoing feedback and dialogue; and (3) development of a plan designed
to give employees training, counseling, mentoring, and other
assistance.[Footnote 10] The act did not specify a date for completion
of DOD's new performance management system. At the time that DOD's
authority for NSPS was repealed, approximately 226,000 DOD civilian
employees throughout the department were under the system.
Following the passage of the NDAA for FY 2010 and the repeal of NSPS,
a January 22, 2010, memo[Footnote 11] from the Deputy Secretary of
Defense canceled the charter of the NSPS, Program Executive Office;
redesignated the NSPS Program Executive Office as the NSPS Transition
Office (hereafter referred to as the Transition Office); and appointed
a Director who reports to the Deputy Assistant Secretary of Defense
for Civilian Personnel Policy. Specifically, the memo stated that the
Director of the Transition Office was expected to (1) manage the
development of the plan to transition employees from NSPS and (2)
oversee the design and implementation of an enterprisewide performance
management system, hiring flexibilities, and the DOD Civilian
Workforce Incentive Fund under authorities granted to the Secretary of
Defense in the NDAA for FY 2010. In addition, each component
established an office to oversee the transition. Toward the end of our
review, the Secretary of Defense issued a memo on certain efficiency
initiatives decisions,[Footnote 12] one of which eliminates 176
Civilian Senior Executive positions--including the Director of the
Transition Office. The memo stated that the Office of the Under
Secretary of Defense for Personnel and Readiness shall execute an
implementation strategy to place affected personnel over the next 24
months.
Subsequent to the NDAA for FY 2010's requirement to terminate NSPS,
you asked that we evaluate (1) the status of DOD's transition of
employees from NSPS to their successor pay and personnel system, (2)
the extent to which DOD documented and supported the costs of the NSPS
termination,[Footnote 13] and (3) DOD's approach for designing and
implementing a new enterprisewide performance management system. This
report documents and updates information that we provided to you and
other congressional committees during an interim status briefing in
December 2010.[Footnote 14] For our updated briefing slides, see
enclosure I.
For our review, we focused on DOD civilians that transitioned from
NSPS to the General Schedule system in the Army, the Navy, the Air
Force, and the DOD Fourth Estate because these were the civilians DOD
transitioned in fiscal year 2010.[Footnote 15] To address our first
objective, we reviewed and analyzed relevant legislation, DOD
transition policies and guidance,[Footnote 16] congressional
testimony, and reports on personnel systems prepared by the Office of
Personnel Management and other federal agencies.[Footnote 17] We
interviewed knowledgeable officials within the Transition Office and
the transition offices of the Army, the Navy, the Air Force, and the
DOD Fourth Estate.
To address our second objective, we compared DOD guidance on NSPS
termination cost reporting and DOD-and component-level cost reports
for the NSPS termination with GAO standards on internal controls and
Statement of Federal Financial Accounting Standards No. 4, Managerial
Cost Accounting Standards and Concepts. We reviewed termination cost
estimates developed by the DOD Comptroller's Office. We also
interviewed knowledgeable officials in the Transition Office and the
component-level transition offices about their interpretation of DOD's
guidance on capturing the costs of the NSPS termination. In assessing
the reliability of these cost data, we found that DOD had limited
documentation on its termination costs and estimates. We therefore
discussed these issues as findings and recommendations in our report.
To address our third objective, we obtained, reviewed, and analyzed
DOD briefings on the design and implementation of the enterprisewide
performance management system, as well as DOD's report on its New
Beginnings conference conducted in September 2010. We also interviewed
senior officials from DOD's Transition Office and the component
transition offices, as well as representatives from the United DOD
Workers Coalition.[Footnote 18] Because 75 percent of DOD's civilian
employees transitioned from NSPS to the General Schedule in fiscal
year 2010, we obtained, reviewed, and analyzed current flexibilities
in the General Schedule system for recognizing and rewarding employee
performance. See enclosure II for a discussion of these flexibilities,
along with other components of performance management systems. To
identify key practices for designing large-scale programs and
organizational transformations, we reviewed prior GAO work on
organizational change and on the importance of strategic planning and
the establishment of goals and milestones.[Footnote 19]
We conducted this performance audit from August 2010 through April
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. Further
details of our scope and methodology can be found in enclosure III.
Results in Brief:
During fiscal year 2010, DOD achieved its initial goal of
transitioning approximately 75 percent of NSPS employees to their
successor pay and personnel system--that is, the General Schedule
system--despite having to overcome some challenges. DOD plans to
transition the remaining NSPS employees by the January 1, 2012,
mandated deadline. Specifically, according to DOD's October 2010
report,[Footnote 20] the department transitioned, as planned,
approximately 172,000 of the 226,000 NSPS employees to the General
Schedule system.[Footnote 21] Regarding challenges, component
officials told us that they completed the reclassifications of
employees back to the General Schedule system even though in some
cases it was difficult to meet deadlines--occasionally requiring the
use of contractors or overtime. For the remaining NSPS employees--
approximately 53,000[Footnote 22]--the department plans to complete
those transitions in five groups. More specifically, employees in 30
health care provider occupations will return to the General Schedule
system from July to December 2011, and employees in other
miscellaneous categories (e.g., deployed civilians and those affected
by base realignment and closure activities) will transition to the
appropriate pay and personnel system no later than December 2011. The
remaining three groups of NSPS employees will transition to the
following alternative pay and personnel systems during the time frames
noted: Science and Technology Reinvention Laboratories from February
to April 2011, Acquisition Demonstration Project from March to June
2011, and Physicians and Dentists Pay Plan in June 2011.
The Transition Office issued guidance[Footnote 23] to the components
for tracking the costs of the NSPS termination; however, the office
did not sufficiently document and support termination costs, and we
found inconsistencies in some reported costs. The guidance instructed
the components to, among other things, (1) report only the costs that
were directly attributable to NSPS termination[Footnote 24] and (2)
include five categories of costs in the cost tracking reports--one
category being Within-Grade Increase Buy-Ins, Performance Awards, and
Quality Step Increases.[Footnote 25] Regarding insufficient
documentation, we found, for example, that the Transition Office
reported $238.6 million (as projected by the Transition Office and
Comptroller's Office) to Congress[Footnote 26] as the estimated fiscal
year 2011 departmentwide costs for increased compensation resulting
from the termination. However, despite our repeated requests during
the course of our review, DOD did not provide documentation to support
this estimate or the methodology used to develop this estimate.
Transition Office officials told us that the department had
experienced turnover in both the Comptroller's Office and the
Transition Office since those estimates had been developed. Internal
control standards state that all transactions and other significant
events need to be clearly documented and that documentation should be
readily available for examination.[Footnote 27] Further, federal
financial accounting standards state that all cost accounting
processes and procedures should be documented, and regardless of the
type of report in which it is presented, cost information should
ultimately be traceable to the original common data source.[Footnote
28] We found that one component reported $15.5 million for its fiscal
year 2010 termination cost, but the Transition Office reported $10
million for the same cost. Unlike the Transition Office, the
component's reported cost accounted for Within-Grade Increase Buy-Ins,
Performance Awards, and Quality Step Increases. According to
Transition Office and component officials, they did not verify or
validate costs obtained from lower-level organizations. Transition
Office officials told us that a charter was not developed for their
office and expressed uncertainty as to whether they had the
responsibility for verifying the cost data provided by the components
or the authority to require cost documentation. While a charter was
not developed, the Deputy Secretary of Defense memo that established
the Transition Office also made available to it the authorities,
functions, and resources of the redesignated NSPS Program Executive
Office[Footnote 29]. Specifically, the NSPS Program Executive Office's
charter (1) included responsibility for preparing budgets (including
submissions and justifications) and (2) required visibility over
component funds. Moreover, our internal control standards state that
entities should ensure the reliability of financial reporting. By not
clearly documenting NSPS termination costs and helping to ensure the
reliability of cost data, DOD is not providing Congress and other
stakeholders clear insight and visibility into the cost of the NSPS
termination.
DOD has recently taken some steps to begin designing a new
enterprisewide performance management system, including involving key
stakeholders in that process; however, the department does not have a
plan with documented goals and a timeline that are tied to funding to
guide the design of the new system in the near term. Most notably, DOD
has taken steps in accordance with Executive Order 13522 to
collaborate with union representatives and other stakeholders on the
design of the system prior to management approval.[Footnote 30]
Specifically, the department (1) hosted a September 2010 conference
comprising 200 participants[Footnote 31]--approximately 100
representatives each from DOD and the unions--to generate ideas for
the system and establish a relationship with the DOD unions, (2)
convened a December 2010 joint labor-management planning work group to
identify requirements for the start-up of the design teams responsible
for developing the new personnel authorities, (3) identified funds for
the design of the system, (4) held a second conference in February
2011 to foster support for the collaborative relationship and process,
and (5) convened design teams in February 2011 comprising DOD and
labor participants to develop recommendations in response to the NDAA
for FY 2010 authorities. According to the United DOD Workers
Coalition, union representatives have been satisfied with DOD's
efforts to involve labor in the design of the new system. As an
example, these representatives noted--and DOD officials acknowledged--
that the September 2010 conference was initially scheduled for April
2010 but was delayed 5 months to ensure greater union involvement in
the planning process. We have reported that involving employees and
stakeholders helps gain a sense of ownership of a new performance
management system.[Footnote 32] Additionally, the Transition Office
provided us with a funding plan for fiscal year 2011 outlining the
estimated costs of designing an enterprisewide performance management
system. However, the office did not provide us with supporting
documentation for these estimates, and according to officials in the
Transition Office, they have not developed a plan with goals and
timelines tied to funding. These officials stated that building
relationships with union stakeholders became their top priority
because without union buy-in, designing a new system would be nearly
impossible. These officials further stated that it was too early to
know what the final system will look like and that they could not
provide goals and timelines for the system. We agree that it may be
too early to define what DOD's final goals are for a new performance
management system; however, by not having interim goals and a timeline
that are linked to funding, DOD is not positioned to determine whether
it is making progress or if resources are appropriate for the near-
term efforts. Prior GAO work has demonstrated the importance of
setting goals and a timeline to show progress from day one[Footnote
33]. We have furthermore reported that key elements of a sound
management approach contain plans that include establishing goals and
time frames and aligning activities with resources. [Footnote 34]
Conclusions:
DOD focused initially on transitions of employees from NSPS to their
successor pay and personnel system--as mandated by law. Moving
forward, the department is now turning to the design of an
enterprisewide performance management system--which includes
performance-based appraisals, ongoing feedback, and open dialogue--and
took steps to work with key stakeholders, including employees and
union representatives. These are positive steps, and our prior work
has noted that stakeholder involvement in the design of a performance
management system is an essential safeguard to ensuring a fair,
credible, and transparent performance management system. In its
transition efforts, however, the department has not provided
supporting documentation for key costs, assessed the reliability of
such costs, or resolved certain inconsistencies in cost data, nor has
it established a plan with documented goals and a timeline to guide
DOD's near-term efforts to design a new performance management system.
Given the nation's fiscal constraints, it is important that agencies
accurately account for funds and their use. Now that the department
has begun to involve stakeholders, having a strategic plan outlining
goals, resources, and milestones would facilitate assessments of the
department's progress going forward.
Recommendations for Executive Action:
To promote an efficient use of resources and to better plan for the
design of a new performance management system, we recommend that the
Secretary of Defense direct the Deputy Assistant Secretary of Defense
for Civilian Personnel Policy to take the following two actions:
* in conjunction with the DOD Comptroller, help ensure that
information identifying and supporting the costs of the NSPS
termination and new performance management system is documented,
reliable, traceable to a source document, and readily available for
examination, and:
* develop a plan with documented near-term design and implementation
goals and a timeline for meeting these goals to build momentum and
show progress for the development of an enterprisewide performance
management system and to facilitate an assessment of what is being
achieved as a result of the resources being spent.
Agency Comments and Our Evaluation:
In commenting on a draft of our report, the Department of Defense
(DOD) partially concurred with our two recommendations. DOD's comments
are reprinted in enclosure IV. The enclosure also includes our
comments on specific points made in DOD's letter. The department also
provided technical comments on our draft report, which we incorporated
as appropriate.
In written comments, DOD partially concurred with our first
recommendation to, in conjunction with the Comptroller, help ensure
that information identifying and supporting the costs of the NSPS
termination and new performance management system is documented,
reliable, traceable to a source document, and readily available for
examination. Regarding documentation, the department stated that it
was not able to provide worksheets used to develop the estimate for
NSPS transition compensation costs because the preparer of the
estimate had departed more than a year ago and the office had not
maintained his working files. DOD stated that it had maintained only
the estimates and an explanation of the methodology that it had
provided to GAO. However, we asked repeatedly over an 8-month period
for documentation showing DOD's approach for its estimates and
obtained only a limited explanation of the methodology. For the
reasons mentioned previously, the department stated that it was
difficult to provide the requested information. As noted in our
report, internal control standards state that all transactions and
other significant events need to be clearly documented and that
documentation should be readily available for examination.
With respect to the inconsistencies in cost data we identified in the
report, the department acknowledged that in some cases the components
and the Transition Office provided inconsistent FY 2010 cost data to
us and as we note in our report both the Transition Office and the
components told us during this review that they did not verify or
validate these data. In its comments DOD stated that the Transition
Office, like its predecessor Program Executive Office NSPS, is not a
program office in the classic sense of an acquisition program. It
stated that the Transition Office is not a budget submission office,
other than for its own operations, and the employing components have
oversight of their civilian personnel dollars and budget authority to
execute those dollars. However, as noted in our report, the Deputy
Secretary of Defense memo that established the Transition Office made
available to this office the authorities, functions, and resources of
the redesignated NSPS Program Executive Office. Specifically, the NSPS
Program Executive Office's charter (1) included responsibility for
preparing budgets, including submissions and justifications, and (2)
required visibility over components' funds. In commenting on our
recommendation, the department noted that the Transition Office will,
among other things, (1) work with the DOD Comptroller to ensure that
cost information is appropriately addressed and (2) continue to
assemble data for the military departments/DOD agencies and
activities--the latter of which will remain accountable for their own
budgets and expenditures. It is unclear whether or how these actions
will fully ensure that information identifying and supporting the
department's costs is documented, reliable, traceable to a source
document, and readily available for examination. We therefore believe
our recommendation remains valid in its entirety.
DOD also partially concurred with our second recommendation to develop
a plan with documented near-term design and implementation goals and a
timeline for meeting these goals to build momentum and show progress
for the development of an enterprisewide performance management system
and to facilitate an assessment of what is being achieved as a result
of the resources being spent. With respect to designing a new
performance management system, the department stated that it agreed
that successful projects require project plans, milestones, resources,
review, and decision processes. According to the department, it is
engaged in a unique collaborative effort with its labor partners,
consistent with Congress's requirements, and the design of the new
system is currently following an interim plan that is not the
traditional top-driven project. The department further stated that (1)
until recommendations are developed jointly for the new authorities,
it would be premature to document design and implementation goals and
a timeline for meeting them and (2) it will develop a detailed post-
fiscal year 2011 project plan that includes goals, steps, and
timelines, once it can determine the scope based on the
recommendations being developed during the current, planned design
team activities associated with the basic design. The department
stated that it is following an interim plan; however, such things as
goals and timelines, linked to funding, were not discussed with us
during the course of our review. We continue to believe that it is
important to set goals and a timeline to show progress from the
beginning of this process and that key elements of a sound management
approach contain plans that include establishing goals and time frames
and aligning activities with resources. The existence of such a plan
does not mean that from day one a final determination has been made
about the system's design, but that interim steps are in place for the
department to build momentum and show progress for the development of
its new system. Such a plan need not wait until after fiscal year
2011, but the department would benefit from such interim steps at
present, as we recommended.
We are sending copies of this report to the appropriate congressional
committees. We are also sending copies to the Secretary of Defense and
the Director of the NSPS Transition Office. This report also is
available at no charge on the GAO Web site at [hyperlink,
http://www.gao.gov].
Should you or your staff have questions concerning this report, please
contact me at (202) 512-3604 or farrellb@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. Key contributors to this report are
listed in enclosure V.
Signed by:
Brenda S. Farrell:
Director, Defense Capabilities and Management Issues:
Enclosures - 5:
[End of section]
Enclosure I: Status of DOD's Transition from the National Security
Personnel System:
Briefing for the Offices of the Senate Committee on Armed Services,
House Committee on Armed Services, and House Committee on Oversight
and Government Reform:
December 2010:
(Updated April 2011):
Background:
The National Defense Authorization Act (NDAA) for Fiscal Year (FY)
2010 directed the Secretary of Defense to begin, no later than 6
months from the date of enactment, to take all actions necessary to
provide for the orderly termination of the National Security Personnel
System (NSPS) and to complete the conversion of all employees from
NSPS by not later than January 1, 2012.[Footnote 35] The act also
directed the Secretary to, among other things,
* convert employees to the statutory pay system and all other aspects
of the personnel system that last applied, and if none applied, to the
system that would have applied had NSPS never been established;
* ensure that no employee shall suffer any loss of or decrease in pay
as a result of the conversion; and;
* promulgate, in coordination with the Director of the Office of
Personnel Management, regulations providing for a fair, credible, and
transparent performance appraisal system for employees.[Footnote 36]
As of March 2011, officials from the NSPS Transition Office
(Transition Office) have acknowledged that regulations have not been
promulgated to establish its enterprisewide performance management
system; however, the Department of Defense (DOD) has recently begun
the initial planning stages for this new system.
Key Questions:
As the DOD transitions from NSPS and begins to plan for an
enterprisewide performance management system, our work addressed the
following questions:
1. What is the status of DOD's transition of employees from NSPS to
their successor pay and personnel system?
2. To what extent has DOD documented and supported costs for the NSPS
termination?[Footnote 37]
3. What is DOD's approach for designing and implementing a new
enterprisewide performance management system?
Scope:
We focused our review on DOD civilians who transitioned from NSPS to
the General Schedule system in fiscal year 2010 and who were employed
by either:
* the Army,
* the Navy,[Footnote 38]
* the Air Force, or,
* the DOD Fourth Estate.[Footnote 39]
Key Question 1: Methodology:
To assess the status of DOD's transition of employees from NSPS to
their successor pay and personnel system, we:
* reviewed relevant legislation;
* obtained, reviewed, and analyzed DOD and component-level plans and
guidance for the transition of employees from NSPS to the General
Schedule system, as well as plans and guidance for the transition of
employees to alternative pay and personnel systems;[Footnote 40]
* interviewed senior officials within the Transition Office
responsible for managing the transition across all of the components;
* interviewed transition officials within each of the components at
the headquarters level and local level at select installations and
organizations; and;
* reviewed congressional testimony and reports prepared by the Office
of Personnel Management and other federal agencies.[Footnote 41]
Key Question 2: Methodology:
To assess the extent to which DOD has documented and supported the
costs of DOD's NSPS termination, we:
* analyzed termination cost reporting guidance[Footnote 42] issued by
the Transition Office;
* interviewed officials from DOD's Transition Office and the component
transition offices on how they had interpreted the guidance directing
them to estimate NSPS termination costs;
* obtained and reviewed quarterly cost tracking reports from the
Transition Office and the component transition offices, as well as
termination cost estimates developed by the DOD Comptroller's Office;
* reviewed GAO's internal control standards, as well as the Statement
of Federal Financial Accounting Standards No. 4, Managerial Cost
Accounting Standards and Concepts; and;
* assessed the reliability of cost data and found that DOD had limited
documentation on termination costs and estimates. We, therefore,
discussed this issue as a finding in our report and made related
recommendations.
Key Question 3: Methodology:
To assess DOD's efforts to design and implement a new enterprisewide
performance management system, we:
* interviewed senior officials within DOD's NSPS Transition Office
responsible for managing the design and implementation of DOD's new
enterprisewide performance management system;
* obtained, reviewed, and analyzed Transition Office briefings, as
well as its report resulting from its recent conference, documenting
initial steps taken before establishing a design team for the new
system;
* reviewed prior GAO work on organizational change, strategic
planning, goals, and milestones;
* interviewed union officials about DOD's efforts to include union
representation in the design and implementation of the new system;
[Footnote 43] and;
* obtained, reviewed, and analyzed current flexibilities in the
General Schedule system for recognizing and rewarding employee
performance. (See enclosure II of the report for a discussion of these
flexibilities, along with other components of performance management
systems.)
Key Question 1: Status of DOD's Transition from NSPS:
During fiscal year 2010, DOD achieved its initial goal of
transitioning approximately 75 percent of the 226,000 NSPS employees
(about 172,000 employees) to their successor pay and personnel system-”
that is, the General Schedule system”despite having to overcome some
challenges. DOD plans to transition the remaining approximately 53,000
NSPS employees by the January 1, 2012, mandated deadline.[Footnote 44]
During fiscal year 2011 through the end of February 2011, the
department completed an additional 8,336 transitions from NSPS to the
General Schedule system, which totals more than 180,000.
The timeline on the next slide shows DOD's efforts to transition NSPS
employees.
Figure 1: Timeline of DOD's Transition from NSPS:
[Refer to PDF for image: timeline]
From February 28, 2010 through September 30, 2010: DOD transitioned
approximately 172,000 employees of its NSPS workforce totaling
approximately 226,000. There are five remaining groups scheduled to
begin transitioning to alternative pay and personnel systems beginning
in early 2011.
September 2010: DOD organized a conference as an initial step in the
planning stages for the department's enterprisewide performance
management system.
Beginning in Spring 2011: Transition Office officials indicated that
DOD plans to continue with the transition of the remaining five NSPS
groups, which represents approximately 53,000 employees. These groups
include the following:
* 30 Health Care Provider Occupations;
* Science and Technology Reinvention Laboratories;
* Acquisition Demonstration Project;
* Physicians and Dentists Pay Plan;
* Miscellaneous categories (i.e. deployed civilians).
January 1, 2012: This is the NDAA for FY 2010 required deadline for
DOD to complete the transition of all employees from NSPS.
Source: GAO analysis of DOD data.
[End of figure]
Key Question 1: Status of the Army's Transition from NSPS:
According to Army officials, the Army:
* had transitioned approximately 67,000 NSPS employees to the General
Schedule system in fiscal year 2010, with approximately 15,000 Army
employees scheduled to transition to the General Schedule or
alternative pay and personnel systems in 2011;[Footnote 45]
* had maintained the General Schedule classifications alongside the
NSPS position descriptions of its employees while NSPS was
operational, facilitating efforts to reclassify employees as part of
the transition from NSPS to the General Schedule system; and;
* developed a conversion tool, called the NSPS2GS, which allowed for
the electronic conversion of employees and tracking of classification
decisions.
Successor system: Army officials told us that employees transitioning
from NSPS to the General Schedule system will have their performance
appraised under the Army's five-level legacy performance management
system-”the Total Army Performance Evaluation System, known as TAPES.
[Footnote 46]
Challenges: Army officials also stated that some challenges of the
transition included managing employee perceptions about pay retention
and identifying employees with "special circumstances," such as
deployed civilians.
Key Question 1: Status of the Navy's Transition from NSPS:
The Navy transitioned approximately 42,700 NSPS employees to the
General Schedule system, achieving its stated goal for fiscal year
2010. Approximately 27,600 employees are scheduled to transition to
alternative pay and personnel systems in 2011.[Footnote 47]
Successor system: Navy officials told us that the Navy had
transitioned its former NSPS employees to a two-tiered system referred
to as the Interim Performance Management System. According to Navy and
Marine Corps officials:
* the first tier satisfies the NDAA for FY 2010 requirement that all
NSPS employees convert to the component's legacy pay and personnel
system, and under this tier an employee's performance is determined to
be acceptable or unacceptable by a rating official and senior rating
official;
* the second tier is an optional framework that commands may adopt to
make employee awards determinations, and under this tier, a
Performance Awards Review Board determines employee awards but does
not make any determinations about ratings;[Footnote 48] and;
* employees under the Interim Performance Management System are
required to document their performance using a 20-page assessment
form, similar to the automated self-assessment included as part of the
Performance Appraisal Application under NSPS.
Challenges: With approximately 25 percent of the Navy's NSPS workforce
having no prior exposure to the General Schedule system, the Navy
faced a training and communication challenge given the relatively
short transition time period.
Key Question 1: Status of the Air Force's Transition from NSPS:
The Air Force transitioned approximately 37,000 NSPS employees to the
General Schedule system in fiscal year 2010.[Footnote 49]
Approximately 4,000 employees are scheduled to transition to
alternative pay and personnel systems in 2011.
According to Air Force transition office officials:
* the Air Force selected later transition dates (a July to September
time frame)[Footnote 50] in fiscal year 2010 so that employees would
receive a rating of record for the 2010 performance cycle and;
* the Air Force's transition strategy included communicating often
with employees during the transition process and using the transition
plan developed for the NSPS implementation as a road map for
transitioning from NSPS.
Successor system: Former NSPS employees have returned to the Air
Force's legacy pass/fail performance management system.
Challenges: According to Air Force transition office officials,
challenges of the transition included managing the reclassification
process, which resulted in, for example, a need for additional staff;
developing a transition policy in a short time period; and training
employees on the difference between NSPS and the General Schedule
system.
Key Question 1: Status of the DOD Fourth Estate's Transition from NSPS:
According to Washington Headquarters Services agency officials,
[Footnote 51] the DOD Fourth Estate transitioned approximately 25,000
NSPS employees to the General Schedule system in fiscal year 2010, and
approximately 2,400 employees are scheduled to transition in 2011 to
alternative pay and personnel systems.[Footnote 52]
Successor system: The various DOD Fourth Estate entities transitioned
their employees back to at least 14 different legacy performance
management systems, all of which had existed previously under the
General Schedule system, including pass/fail, three-level, and five-
level rating systems.
Challenges: Officials identified a number of challenges during the
transition period, such as those related to reclassifying positions,
providing guidance to employees in a timely manner, and managing
employee perceptions on certain topics, such as pay retention.
As mentioned previously, DOD expects to transition the remaining
approximately 53,000 NSPS employees[Footnote 53] according to the
schedule below and anticipates completing the transition of all
employees by the NDAA for FY 2010 deadline of January 1, 2012.
Table:
Population category: Physicians and dentists;
Transition to: Physicians and Dentists Pay Plan;
Projected transition date: June 2011.
Population category: Other health care professionals in designated
occupations;
Transition to: General Schedule system;
Projected transition date: July to December 2011.
Population category: Acquisition Workforce Personnel Demonstration
Project;
Transition to: Acquisition Workforce Personnel Demonstration Project;
Projected transition date: March to June 2011.
Population category: Science and Technology Reinvention Laboratories;
Transition to: Science and Technology Reinvention Laboratories;
Projected transition date: February to April 2011.
Population category: Miscellaneous (e.g., deployed civilians,
alternative personnel systems);
Transition to: Previous personnel system;
Projected transition date: No later than December 31, 2011.
Source: DOD.
[End of table]
[End of Key Question 1]
Key Question 2: The Extent to Which DOD Has Documented and Supported
Costs for the NSPS Termination:
The Transition Office issued guidance[Footnote 54] to the components
for tracking costs of the NSPS termination; however, the office did
not provide sufficient documentation to support termination costs, and
we found inconsistencies in some reported costs.
* More specifically, the guidance, which was provided in the
Transition Office's April 2010 plan, states that the components are
to, among other things:
(1) report only the costs that were directly attributable to NSPS
termination;[Footnote 55]
(2) include five categories in their cost tracking reports”-one
category being Within-Grade Increase Buy-Ins, Performance Awards, and
Quality Step Increases;[Footnote 56]
(3) begin cost reporting for the NSPS termination in the second
quarter of fiscal 2010; and;
(4) continue such reporting until all NSPS employees had transitioned
to the appropriate pay and personnel systems.
* With respect to insufficient supporting documentation, we found, for
example, that the Transition Office reported $238.6 million (as
projected by the Transition Office and Comptroller's Office) to
Congress[Footnote 57] as the estimated fiscal year 2011 departmentwide
costs for increased compensation resulting from the termination.
* However, despite our repeated requests during the course of our
review, DOD did not provide documentation to support this estimate.
- Transition Office officials told us that they were unable to provide
such documentation because of turnover in both the Transition Office
and the Comptroller's Office.
- Our internal control standards state that all transactions and other
significant events need to be clearly documented, and the
documentation should be readily available for examination.[Footnote 58]
- Further, federal financial accounting standards[Footnote 59] state
that all cost accounting processes and procedures should be
documented, and regardless of the type of report in which it is
presented, cost information should ultimately be traceable back to the
original common data source.
* Additionally, termination costs were not always reported accurately
and consistently by the components and the Transition Office. For
example:
- The Transition Office initially told us that fiscal year 2010 costs
for increased compensation were $180 million, but during the course of
our review, the office corrected this estimate-”stating that the $180
million was the annualized cost of salary adjustments beginning in
fiscal year 2011 and not a fiscal year 2010 cost. The Transition
Office later provided an estimate of $56 million for increased
compensation costs for the fiscal year 2010 transitions.
- One component's transition office reported that the fiscal year 2010
cost of the NSPS termination was $15.5 million, while the Transition
Office reported that the same cost was $10 million-”a difference of
over $5 million. This component's cost tracking report included one
category-”Within-Grade Increase Buy-Ins, Performance Awards, and
Quality Step Increases”that was not included in the Transition
Office's cost tracking report.
- Another component's transition office reported that the fiscal year
2010 cost of the NSPS termination was approximately $3.4 million,
whereas the Transition office reported that the same cost was $3.1
million”-a difference of approximately $300,000. We found that the
Transition Office's and component's cost tracking sheets were
consistent with on another for each reporting cost category; however,
the totals were inconsistent.
* According to Transition Office and component officials, they did not
verify or validate costs obtained from lower-level organizations.
* Additionally, officials from the Transition Office told us that a
charter was not developed for their office and expressed uncertainty
as to whether they had the responsibility for verifying the cost data
provided by the components.
* While a charter was not developed for the Transition Office, the
Deputy Secretary of Defense memo that established the Transition
Office also made available the authorities, functions, and resources
of the redesignated NSPS Program Executive Office.[Footnote 60] The
NSPS Program Executive Office charter (1) included responsibility for
preparing budgets (including submissions and justifications) and (2)
required visibility over component funds.
* Our internal control standards state that entities should ensure the
reliability of financial reporting.
* By not clearly documenting NSPS termination costs and helping to
ensure the reliability of cost data, DOD is not providing Congress and
other stakeholders clear insight and visibility into the cost of the
NSPS termination.
[End of Key Question 2]
Key Question 3: DOD's Approach to Designing and Implementing an
Enterprisewide Performance Management System:
DOD has recently taken some steps to begin designing a new
enterprisewide performance management system, which include involving
key stakeholders in that process. However, the department does not
have a plan with documented goals and a timeline that are tied to
funding to guide the design of the new system in the near term.
Most notably, in accordance with Executive Order 13522,[Footnote 61]
the Transition Office has collaborated with union representatives and
other stakeholders on the design of the system prior to management
approval. Specifically the department:
* hosted a September 2010 conference to generate ideas for the system
and establish a relationship with the unions;
* convened a December 2010 joint labor-management planning work group
to identify requirements for the start-up of the design teams
responsible for developing the new personnel authorities;
* identified funds for the design of the system;
* held a second conference in February 2011 to foster support for the
collaborative relationship and process; and;
* convened design teams comprising DOD and labor participants to draft
proposed regulations for NDAA for FY 2010 authorities.
According to the United DOD Workers Coalition, union representatives
have been satisfied with DOD's efforts to involve labor in the design
of the new system.
* For example, DOD officials noted that the September 2010 conference
was initially scheduled for April 2010 but was delayed 5 months to
ensure greater union involvement in the planning process.
The Transition Office provided us with a funding plan for fiscal year
2011 outlining the estimated cost of designing an enterprisewide
performance management system.
However, according to officials, the Transition Office has not
developed a plan with goals and timelines-”tied to funding-”that
identifies next steps for the design of a new system. These officials
stated that building relationships with union stakeholders became the
top priority because without union buy-in, designing a new system
would be nearly impossible. Officials further stated that previously
it was too early to develop documented goals for the system but that
the design teams had convened on February 23, 2011, and the department
will spend the remainder of fiscal year 2011 developing and vetting
recommendations for the three NDAA for FY 2010 mandates before sending
their recommendation to the regulation writers.
We agree that it may be too early to define what DOD's final plans are
for a new performance management system; however, by not having
interim goals linked to funding and a timeline for the near term, DOD
is not positioned to determine whether it is making adequate progress
or if resources are appropriate for the near-term efforts.
Prior GAO work:
* demonstrated the importance of setting goals and a timeline to show
progress from day one[Footnote 62] and;
* reported that key elements of a sound management approach contain
plans that include establishing goals
and time frames and aligning activities with resources.[Footnote 63]
[End of Enclosure I]
Enclosure II: Flexibilities in the General Schedule System and Other
Elements of Performance Management:
According to the Office of Personnel Management, federal agencies are
required to develop an approved performance appraisal system that
establishes employee performance standards and includes appraisals
that serve as a basis for training, rewarding, reassigning, promoting,
reducing in grade, retaining, and removing employees.
Within the General Schedule system, as an example, federal managers
have three primary means to recognize and reward employee performance.
First, an employee who is paid on an annual basis, who occupies a
permanent position within the scope of the General Schedule, and who
has not reached the maximum rate of pay for the grade in which his or
her position is placed is eligible for a within-grade increase at set
intervals based upon time of service within each grade--provided his
or her work is performed at an acceptable level as determined by the
head of the agency and the employee did not receive an equivalent
increase in pay from any cause during that period. Specifically, (1)
for each 52 weeks of service, an employee may advance in steps 1, 2,
and 3; (2) for each 104 calendar weeks of service an employee may
advance in steps 4, 5, and 6; and (3) for each 156 calendar weeks of
service an employee may advance in steps 7, 8, and 9. However, a
within-grade increase can be withheld for performance below an
acceptable level. Second, the head of each agency may grant additional
quality step increases provided resources are available, in
recognition of high-quality performance above that ordinarily found in
the type of position concerned. However, an employee is eligible under
this section for only one additional step increase within any 52-week
period. Third, agencies may grant cash awards, honorary or informal
recognition awards, or time-off awards to an employee on the basis of
performance as reflected in the employee's most recent rating of
record.
In addition, a sound performance management system will include many
elements. Figure 2 shows some examples of these elements,[Footnote 64]
which include, among others, (1) clearly communicate performance
expectations to employees that align with organization missions and
goals; (2) provide employees meaningful, constructive, and candid
feedback relative to performance expectations, including at least one
documented interim review; and (3) provide employees with a
recommended rating of record.
Figure 2: Elements of a Performance Management System:
[Refer to PDF for image: illustration]
Elements of a Performance Management System:
* Expectation setting;
* Ongoing and midpoint feedback;
* Self-assessment;
* Appraisal preparation;
* Appraisal review;
* Appraisal feedback;
* Development plans/independent development plan;
* Performance-based compensation.
Source: GAO.
[End of figure]
[End of Enclosure II]
Enclosure III: Objectives, Scope, and Methodology:
In our review of civilian employees' transition from the National
Security Personnel System (NSPS) at the Department of Defense (DOD),
we focused primarily on the approximately 172,000 employees
transitioning to the General Schedule system in fiscal year 2010 (the
first year of the transition) from the Army, the Navy, the Air Force,
the Marine Corps, and the DOD Fourth Estate.[Footnote 65] The
transitions of the remaining 53,000 employees from NSPS to alternative
pay and personnel systems are not due for completion until January 1,
2012. During the course of our review, we met with officials from the
NSPS Transition Office (Transition Office) as well as the component-
level offices responsible for managing the transition at each of the
components.
To determine the status of the NSPS transition of employees from NSPS
to their successor pay and personnel systems, we reviewed the
legislative requirements for the transition identified in the National
Defense Authorization Act for Fiscal Year 2010. We also reviewed Title
5 of the United States Code, which governs government organization and
employees. Specifically, we focused on Section 9902, which governs DOD
personnel authorities; Chapter 53, Subchapter III, which governs
General Schedule pay rates; and Section 5363, which governs the use
and applicability of pay retention. We also obtained, reviewed, and
analyzed relevant DOD transition guidance, such as the NSPS to GS
Transition Guide: Chapters 1-6, as well as component-specific
transition guidance. We also obtained, reviewed, and analyzed
congressional testimony regarding the NSPS transition given by DOD's
Transition Office and the Office of Personnel Management. Using a
semistructured interview technique, we interviewed knowledgeable
officials from the Transition Office and each component's responsible
transition office to understand how DOD and each component were
managing the orderly transition of NSPS employees to the General
Schedule system, and the extent to which each of those offices is
prepared for future transitions. Further, we analyzed documents on the
General Schedule system and performance management that were issued by
the Office of Personnel Management and interviewed appropriate
officials. We also analyzed reports on NSPS transition, lessons
learned, and organizational transformation published by the
Congressional Research Service and GAO.
To determine the extent to which DOD documented and supported costs
for the NSPS termination, we compared DOD guidance on NSPS termination
cost reporting provided to the components and lower-level
organizations--included as part of DOD's April 2010 report to
Congress[Footnote 66]--and DOD-and component-level cost reports for
the NSPS termination with GAO standards on internal controls and
Statement of Federal Financial Accounting Standards No. 4, Managerial
Cost Accounting Standards and Concepts. We reviewed termination cost
estimates developed by the DOD Comptroller's Office. We also
interviewed knowledgeable officials in the Transition Office and the
component-level transition offices about their interpretation of DOD
guidance on capturing the costs of the NSPS termination. We assessed
the reliability of these cost data by reviewing available
documentation, including the Transition Office's funding plan, and
interviewing knowledgeable agency officials about these costs. We
reviewed the data and documents for completeness and consistency, and
in discussions with component and Transition Office officials, they
told us that they neither verified nor validated the information
obtained from lower-level organizations. Based on these facts and
identified errors and inconsistencies, we concluded that the data were
not reliable and therefore discussed these issues as findings and
recommendations in our report.
To determine DOD's approach for designing and implementing a new
enterprisewide performance management system, we obtained, reviewed,
and analyzed DOD briefings on the development of its new
enterprisewide performance management system. We also obtained,
reviewed, and analyzed DOD's conference report resulting from its New
Beginnings Conference, which documents initial ideas that will be used
to design the enterprisewide performance management system, in
addition to DOD's hiring flexibilities, and the Workforce Incentive
Fund. Using a semistructured interview technique, we interviewed
senior officials within DOD's Transition Office and the component
transition offices responsible for managing the design and
implementation of DOD's new enterprisewide performance management
system about the current status of DOD's efforts and future plans for
the enterprisewide performance management system.
To better understand options available to federal managers for
recognizing and rewarding employee performance, we obtained, reviewed,
and analyzed flexibilities in the General Schedule system. To
determine best practices for designing large-scale programs and
transformation, we reviewed prior GAO work on organizational change
and on the importance of strategic planning and the establishment of
goals and milestones.[Footnote 67] To determine the extent to which
DOD has involved union representatives in the design and
implementation of its new performance management system, we
interviewed senior representatives of the United DOD Workers Coalition
about DOD's efforts to include union representation in the design and
implementation of the new system.
We conducted this performance audit from August 2010 through April
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient and appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of Enclosure III]
Enclosure IV: Comments from the Department of Defense:
Note: DOD's letter was sent on April 14, 2011. GAO comments
supplementing those in the report text appear at the end of this
enclosure.
Department Of Defense:
NSPS Transition Office
1400 Key Boulevard Suite 8200
Arlington, VA 22209-3144:
Ms. Brenda S. Farrell:
Director, Defense Capabilities and Management:
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, D.C. 20548:
Dear Ms. Farrell:
This is the Department of Defense (DoD) response to your draft report,
"Performance Management: DoD Is Terminating the National Security
Personnel System, but Needs a Strategic Plan to Guide Its Design of a
New System,“ dated March 29, 2011 (GAO Code 351519/GA0-11-524R). Thank
you for the opportunity to review and comment on the draft. [See
comment 1]
The National Defense Authorization Act for Fiscal Year 2010 (NDAA
2010) amends section 9902 of title 5, U.S. Code. It requires GAO to
assess employee satisfaction with the regulations, processes, and the
fairness, transparency, and credibility of the new performance
management system, redesigned appointment procedures, and the DoD
Civilian Workforce Incentive Fund as authorized in NDAA. 2010. As will
be discussed more fully below, the design process is ongoing and the
statutorily mandated assessment would be premature at this time. While
the statute did not require an evaluation of the termination of the
National Security Personnel System (NSPS), the Department is pleased
that GAO reviewed the transitions from NSPS that DoD effected during
Fiscal Year 2010 (FY2010)[Footnote 1].
The Department's response to GAO's evaluation follows. Our response to
the two recommendations for executive action is enclosed.
The repeal of the statutory authority for NSPS precipitated an
unprecedented effort ” one of the largest scale transitions from one
Federal personnel system to another. The NSPS population at its
largest (226,000 employees when transitions began the end of February
2010) was larger than the number of employees in any Executive agency,
with the exception of the Department of Veterans' Affairs. DoD planned
for the orderly termination of NSPS and the Department of Veterans'
Affairs. DoD planned for the orderly termination of NSPS and the
transition of employees and positions with the least possible
disruption to the mission and hardship to employees. The Department's
senior leadership opted to transition the workforce to the applicable
prior pay and personnel system, in conformance with the NDAA 2010
requirement, as quickly as possible.
As noted in the draft report, roughly 75 percent of the NSPS
population in February 2010 occupied positions rooted in the
government-wide General Schedule (GS) system. Therefore, the
Department decided to transition most NSPS employees in positions with
a legacy to the GS pay and classification system ” without undue
interruption ” during FY2010. The degree of planning for and execution
of this initiative was much greater, more intense, far-reaching, time-
and resource-consuming than it might appear ” and was accomplished
while maintaining readiness and carrying out other imperatives. The
Department's success in overcoming challenges and transitioning
172,000 employees (representing 76 percent of the NSPS population)
from the NSPS broad bands to the discrete grades of the GS system in
FY2010 is a tribute to the hard work of the DoD supervisory,
managerial, and human resources communities to plan and carry out the
job classifications, training, communications, data processing, and
performance system migration.
The Department acknowledges that we were not able to provide the
worksheets used to develop the estimate for NSPS transition
compensation costs, and that in some cases there were inconsistencies
between the FY2010 cost figures provided by the Military
Departments/Defense Agencies and Activities and the way the NSPS
Transition Office characterized them. It is useful to consider the
nature of the costs discussed in your evaluation, recap for the record
the methodology for estimating the compensation costs associated with
the transitions, and address the inconsistencies in reporting those
costs that are noted in your draft report.
Congress required employees to transition from NSPS to the statutory
pay and personnel system that last applied or that would have applied
if NSPS had never been established. The GS rules of classification and
pay setting governed the FY2010 transitions. The great majority of
termination costs entailed grade and step placements documented in
official personnel transactions, recorded in the Defense Civilian
Personnel Data System (DCPDS). DCPDS was the source of raw data for
analyst estimates in May 2009, and for summary reports regarding
actual changes in compensation. Although not normally involved in
budget matters for the employing Military Departments and Defense
Agencies and Activities, the NSPS Transition Office estimated the
aggregate salary increase for the DoD Comptroller. [See comment 3] GAO
did not comment on the accuracy of the Department's estimate of the
change in employee compensation when compared to the actual cost, but
rather commented that the Department did not have working files from
May 2009 available so their analysts could inspect DoD's methodology.
We provided GAO the methodology for developing the estimate, but not
the source data files. As we explained, the analyst who prepared the
transition cost estimate departed more than a year ago, and the office
did not maintain his working files, only the estimates and explanation
of the methodology which the NSPS Transition Office provided to GAO.
At the pre-closeout meeting on March 8, 2011, GAO analysts informed us
that the documentation the Department had provided was not sufficient
to give them a full understanding of whether the estimate of NSPS to
GS transition costs was valid. [See comment 4]
In developing the compensation cost estimate, the Department could not
know an individual employee's GS transition grade before it was
determined. In 2009, when we estimated compensation increases due to
NSPS termination, we therefore could not predict whether his or her
NSPS salary would be within the range for their GS grade, over, or
under. The analyst's start point was DCPDS data for the NSPS workforce
as it stood in spring 2009 when Congress set forth its initial NDAA
2010 provisions for terminating NSPS ” 209,700 employees, with an
average adjusted salary (base plus locality) of $82,800. The DoD NSPS
Transition Office analyst assumed that all employees would be placed
on a step, not to exceed step 10, with a pay increase if their NSPS
pay fell between steps of the GS grade of their transition position ”
in conformance with government-wide GS pay setting rules. [See comment
4] NSPS physicians and dentists whose base salary exceeded the YA-3
pay band maximum were not included. Also excluded were 8,500 employees
at the maximum of their NSPS pay band and 1,300 employees within $50
of their maximum rate. For employees who came to NSPS from a DoD GS
position, the analyst modeled the grade they likely would hold if NSPS
transactions similar to within band promotions had been to a GS
position. That is, the analyst reviewed three years of personnel
actions during the time that NSPS had been in effect. He credited NSPS
accelerated compensation for developmental positions and other
individual increases that rounded up to five percent as a GS
promotion. He then calculated their step placement increases, averaged
them, and applied the resulting average increase of 1.03 percent as a
standard factor across the NSPS workforce. The total salary estimate
for one year was $178.5M, including nearly $153M in base pay increases
and nearly $27M for locality pay. Using the rounded $180M as the
adjusted pay increase, the DoD Comptroller adjusted the amount to
include benefits and the expected civilian pay raise. Estimated
increased civilian pay costs of $238.6M (rounded to $239M) are
provided in the DoD budget for FY2011 and inflated through the Future
Years' Defense Program.
An alternative method suggested by the Office of Personnel Management
was to apply a 1.5 percentage (representing a half step increase)
across the workforce, resulting in an estimated cost nearly 50 percent
higher than the more granular estimate used by the Department. Such an
approach was likely to overestimate costs, because it was not adjusted
for employees at or above the maximum rate for the highest GS grade
encompassed by the employee's NSPS pay band or for some employees at
or above the maximum rate for their likely GS transition grade. Those
employees would not receive pay increases upon transition.
DoD received no extra funding to cover FY2010 compensation costs
resulting from transitions from NSPS as a result of Congress's repeal
of NSPS. Employees transitioned from NSPS between February 28 and the
end of September 2010, as scheduled by the employing Military
Department/Defense Agency or Activity. The employing offices carried
out the transitions, processed the transition actions in DCPDS, and
absorbed resulting compensation cost increases within their FY2010
budgets. The DoD NSPS Transition Office monitored progress and impact
of conversion transactions in aggregate throughout the year.
GAO found that the NSPS transition offices did not validate the
transition costs reported by the employing offices. As discussed at
the exit conference, the NSPS Transition Office, like its predecessor
Program Executive Office NSPS, is not a program office in the classic
sense of an acquisition program. It is not a budget submission office
(other than for its own operations). [See comment 5]
It does not manage employing organizations' payroll budgets and
expenditures (other than for its own staff). It does not monitor
individual personnel changes after transition from NSPS. The
employing Components have oversight of their civilian personnel
dollars and budget authority to execute those dollars. [See comment 5]
From a DoD-wide standpoint, the estimate by the NSPS Transition Office
for one year of compensation increases due to NSPS termination was
applied toward the FY2011 DoD budget. Based on all transition step
placements documented in the personnel data system, the one year value
of pay increases due to actual transitions of 172,000 employees from
NSPS in FY2010 was just over $180M, before any benefit cost additions.
As noted, payroll costs are traceable to the individual personnel
actions via DCPDS by DoD Components that took employees out of NSPS
and placed them into GS. With roughly half the remaining 53,000 NSPS
employees as of September 30, 2010 expected to transition to the GS
system in 2011, the budgeted $238.6M places our estimate within 10
percent of the projected actual cost. We can provide a personnel data
system file of NSPS employees as of the end of April 2009 and one that
captures the FY2010 transitions, if GAO analysts desire to make their
own calculations. [See comment 6]
With respect to the three inconsistent cost figures cited in your
report and draft presentation, the report discusses the resolution of
two of them ” one was resolved during the course of the review, and
the second was the result of a difference in the way figures were
reported. We have determined that the third inconsistency was the
result of a mistake in addition ” the NSPS Transition Office had the
supporting figures but made a mistake in the arithmetic. [See comment
7]
With respect to designing the new performance management system
prescribed in NDAA 2010, we agree that successful projects require
project plans, milestones, resources, review, and decision processes.
The Department's success in drawing down NSPS due to the system's repeal
” acknowledged by GAO ” is indicative that we understand well how to
plan and manage such an undertaking. [See comment 8]
GAO in its draft report asserted that the Department does not have
interim goals and a timeline that are linked to funding for the next
steps in designing the new performance management system and is not
positioned to determine if it is making progress or if resources are
appropriate for near-term efforts. The NSPS Transition Office staff
discussed with the GAO analysts its plan and estimated resource needs
for the near-term design process. Transition Office staff also
discussed two factors associated with the details of Congress's
mandate for a new performance management system and other authorities
that make our task different from traditional top-driven projects.
[See comment 8]
The interim design project plan begins with a series of planning
meetings starting in spring of 2010 that culminated in the September
2010 conference that brought together over 200 participants from
management, employees, and DoD unions to explore, give insights, and
suggest system ideas concerning the NDAA 2010 authorities. The next
steps of the project plan were joint union-management planning to
decide on the design process and general timeframes. Joint design
teams were established, and participants convened in February 2011 to
begin a series of scheduled meetings through September 2011. [See
comment 9] As we explained to the GAO analysts, the teams were
presenting their detailed project plans for the year at the end of
their second session, March 31. The teams have stated project goals to
fully explore options and develop recommendations for consideration by
DoD decision makers by the end of FY2011. At the end of each design
session, there are scheduled progress reviews with the joint steering
group to inform them about progress, key outcomes, and next steps.
[See comment 9]
As discussed with GAO, the first of two factors that makes the design
of the new system different from traditional top-driven projects is
that NDAA 2010 requires DoD to "include a means for ensuring employee
involvement (for bargaining unit employees, through their exclusive
representatives) in the design and implementation of such system."
Congress required the Department to ensure no problems like those
underscored in the Defense Business Board's August 2009 review of NSPS
would occur if DoD proposed an alternative personnel system for
transition of its NSPS employees; the key criticism being insufficient
workforce/union involvement in planning NSPS. As captured in the
Department's fall 2010 reports to Congress and in other information on
DoD's New Beginnings website, the Department has been mindful of its
responsibility to work with exclusive representatives of DoD employees
and involve the workforce in developing the new authorities. DoD is
proceeding with its unions in a deliberate, collaborative partnership
consistent with Congress's requirements, as well as the President's
labor-management Executive Order requiring pre-decisional involvement
of unions in all workplace matters to the fullest extent practicable.
The second factor that makes the development of the new performance
management system and other authorities different from the traditional
top-down approach is that until the collaborative process works
through, the Department remains open to union-management
recommendations for future system/process changes which may be narrow
and along proven lines, or far-reaching innovations with a substantial
implementation tail. As GAO acknowledged in its draft report, the
United DoD Workers' Coalition is complimentary on the Department's
approach to developing the new system. Once the ideas are matured and
the scope of jointly developed recommendations known, we will be in a
position to work out the full timeline and tie it to long-term funding
for completing the basic design and central operations to implement
the system. It is premature to estimate the whole project.
In summary, when NSPS was designed and implemented, there was no
indication that the statutory authority would be repealed after the
system had operated for three years. When Congress repealed the
authority, the Department planned and carried out the transition of
172,000 employees from NSPS in FY2010 promptly and responsibly. The
great majority of transition costs were the actual compensation costs
associated with applying the government-wide GS classification and pay
setting rules to transitioning employees and their positions. The
compensation cost estimate itself and the processed transactions
indicate that the methodology was appropriate and the estimate that
DoD used for the budget was quite close to the actual experience.
Finally, the Department has implemented an interim project plan that
continues to engage with its partners in the joint labor and
management design teams, and that is expected to produce collaborative
design recommendations for a new performance management system that
then will be scoped, addressed for full implementation in a new
project plan, and tied to funding. [See comment 9]
Again, thank you for the opportunity to comment on the draft report.
Our response provides comments on major items we would like to clarify
or correct. If you have any questions regarding this response, please
do not hesitate to contact me.
Sincerely,
Signed by:
John H. James, Jr.
Director:
Enclosure:
Footnote:
[1] When GAO Code 351519 was announced in a June 28, 2010, letter to
Secretary of Defense Gates, the engagement was titled "2010 Review of
the Department of Defense's Transition out of the National Security
PCIS mad System (NSPS)." The letter stated that the source of the work
was "in response to a congressional mandate in the National Defense
Authorization Act for Fiscal Year 2010, which directed GAO to conduct
reviews of the department's transition from NSPS in calendar years,
2010, 2011, and 2012." At a pre-closeout meeting with GAO analysts on
March 2, 2011, GAO advised us that the scope of their evaluation had
been revised and the draft report would be focused on three
objectives: (1) the status of DoD's transition of employees from NSPS
to their legacy pay and classification system; (2) the extent to which
DoD has identified the costs associated with the NSPS termination; and
(3) DoD's approach for designing and implementing a new enterprise-
wide performance system.
[End of letter]
GAO Draft Report Dated March 29, 2011:
GAO Code 3515039/GA0-11-524R:
[See comment 10]
"Performance Management: DoD is Terminating the National Security
Personnel System, but Needs a Strategic Plan to Guide Its Design of a
New System"
Department Of Defense Response To GAO Recommendations For Executive
Action:
To help ensure an efficient use of resources and to better plan for
the design of a new performance management [system], we recommend that
the Secretary of Defense direct the Under Deputy Assistant Secretary
of Defense for Civilian Personnel Policy to take the following two
actions:
Recommendation 1: In conjunction with the Comptroller, help ensure
that information identifying and supporting the costs of the NSPS
termination and new performance management system is documented,
reliable, traceable to a source document, and readily available for
examination.
DoD Response: Partially concur.
With respect to NSPS termination, the vast majority of transition
costs was increased employee compensation as a result of applying the
government-wide GS classification and pay setting rules. These costs
are documented on individual official personnel transactions that
effect the transitions of employees from NSPS to the appropriate
successor pay and personnel system. The Department uses personnel
records that reside in the Defense Civilian Personnel Data System for
source data There was no line item for NSPS in the DoD budget, and
compensation costs are included in DoD Components and Activities'
funding.
With respect to costs of the new performance management system, a copy
of the budget request was provided to the GAO team. As discussed at
the out brief and in the DoD letter response to GAO, it is premature
to predict future costs as the system is being developed jointly by
DoD labor and management and is not top-driven. Costs for program
operations such as for training and program start up can be estimated
by the responsible office, once the design matures and recommendations
emerge.
We will work with the DoD Comptroller to ensure that cost information
is appropriately addressed. The NSPS Transition Office will refine a
budget request for its own operations, and will continue to assemble
data for the Military Departments/DoD Agencies and Activities. They
will continue to be accountable for their budgets and expenditures.
Recommendation 2: Develop a plan with documented near-term design and
implementation goals and a timeline for meeting these goals to build
momentum and show progress for the development of an enterprise-wide
performance management system and to facilitate an assessment of what
is being achieved as a result of the resources being spent.
DoD Response: Partially concur.
The Department is engaged in a unique collaborative effort with its
labor partners, consistent with Congress's requirements. As discussed
in the Department's letter response to GAO and during the out brief,
design of the new system is following an interim plan that is not the
traditional, top-driven project Until recommendations are developed
jointly for the new authorities, it would be premature to document
design and implementation goals and a timeline for meeting them as
contemplated by the GAO recommendation. We will develop a detailed
post-FY2011 project plan that includes goals, steps, and timelines,
once we can determine the scope based on the recommendations being
developed during the current, planned design team activities
associated with the basic design.
The following are GAO's comments on specific points made in the
Department of Defense's (DOD) letter sent on April 14, 2011.
GAO Comments:
1. DOD stated that the National Defense Authorization Act (NDAA) for
Fiscal Year (FY) 2010 requires GAO to assess employee satisfaction
with the regulations, processes, and the fairness, transparency, and
credibility of the of the new performance management system,
redesigned appointment procedures, and the DOD Civilian Workforce
Incentive Fund as authorized in the NDAA. The comments further noted
that the GAO letter announcing the engagement stated that the source
of work was "in response to a congressional mandate," the design
process was ongoing and the statutorily mandated assessment would be
premature at the time, and that at the pre-closeout meeting, GAO
advised the department that the scope of the evaluation had been
revised and the draft report would be focused on the three objectives
included in the report. To clarify, we note in our report that we
initially conducted our review in response to an anticipated mandate
in which DOD was expected to promulgate regulations for its new
performance management system and GAO was to report on, among other
things, the processes established pursuant to those regulations. But
the department did not issue those regulations and thus the mandate
was not triggered. We informed DOD that we briefed the defense
committees in December 2010 and congressional interest was expressed
for us to continue our work on the status of the National Security
Personnel System (NSPS) transition. Subsequently, the Chairman and
Ranking Member of the Subcommittee on Readiness of the House Committee
on Armed Services requested our ongoing work in this area.
2. DOD stated that it planned for the orderly termination of NSPS and
the Department of Veterans' Affairs. The part about the Department of
Veterans Affairs was not a requirement of the NDAA for FY 2010.
3. DOD stated that although the office is not normally involved in
budget matters for the employing military departments and defense
agencies and activities, the NSPS Transition Office (Transition
Office) estimated the aggregate salary increase for the DOD
Comptroller. The department further noted that we did not comment on
the accuracy of the department's estimate of the change in employee
compensation when compared to the actual cost, but rather we commented
that the department did not have working files from May 2009 available
for inspecting DOD's methodology. As the department stated, we did not
comment on the accuracy of DOD's estimate of the change in employee
compensation when compared to the actual cost because, during the
course of our review, we repeatedly asked DOD for the actual costs
associated with the transition and this information was not provided.
Regarding DOD's comment on working files, we also asked repeatedly
over an 8-month period for supporting documentation of DOD's actual
termination cost, but did not receive documentation of the actual cost
resulting from changes in employee compensation because of the
transition and received only a limited explanation of the approach
used to develop the estimate. For the reasons mentioned previously,
the department stated that it was difficult to provide the requested
information. As we mentioned in our report, internal control
standards[Footnote 68] state that all transactions and other
significant events need to be clearly documented and that
documentation should be readily available for examination. Further,
federal financial accounting standards[Footnote 69] state that all
cost accounting processes and procedures should be documented, and
regardless of the type of report in which it is presented, cost
information should ultimately be traceable to the original common data
source.
4. DOD stated that the department had provided GAO the methodology for
developing the estimate but had not provided the source data files.
DOD explained that one of the analysts who prepared the transition
cost estimate had departed more than a year ago and that the office
did not maintain his working files. As we mentioned in comment 3,
internal control standards and federal financial accounting standards
emphasize the value of documentation. Thus, we continue to believe
that documentation is imperative. Additionally, during the 8 months of
our review, we repeatedly asked the department to provide supporting
documentation of the cost data and methodology used to determine the
cost estimates, but received only a limited explanation of the
department's approach to calculating the estimate. However, the
department, in its comments on a draft of this report, provided some
additional information on its cost estimates for which supporting
documentation was not provided. More specifically, the department did
not previously provide us with such information about (1) the
analyst's starting point being 209,700 employees, with an average
adjusted salary (base plus locality) of $82,800; (2) the assumptions
used for the estimate; and (3) the number of excluded employees.
Maintaining such documentation is important because, among other
things, (1) it helps ensure management's approval of the methodology
over time; (2) it helps ensure consistent application of the
methodology over time; and (3) it provides a basis for independent
evaluators to review and assess the methodology--including all data
sources, costing methods and assumptions used, and the justification
for using them.
5. DOD stated that GAO found that the NSPS transition offices did not
validate the transition costs reported by the employing offices. In
its comments DOD stated that "the NSPS Transition Office, like its
predecessor Program Executive Office NSPS, is not a program office in
the classic sense of an acquisition program. It is not a budget
submission office, other than for its own operation, and the employing
components have oversight of their civilian personnel dollars and
budget authority to execute those dollars." However, as noted in our
report, the Deputy Secretary of Defense memo that established the
Transition Office made available to this office the authorities,
functions, and resources of the redesignated NSPS Program Executive
Office. Specifically, the NSPS Program Executive Office's charter (1)
included responsibility for preparing budgets, including submissions
and justifications and (2) required visibility over components' funds.
6. DOD stated that it can now provide a personnel data system file of
NSPS employees that captures the fiscal year 2010 transitions for GAO
review. However, as previously noted, over an 8-month period we
repeatedly asked for but were not provided the actual costs and
documentation associated with the department's termination-related
costs.
7. With respect to the three inconsistencies in cost data that we
noted in our report, the department stated that (1) one was resolved
during the course of our review, (2) the second was the result of a
difference in the way the cost figures were reported, and (3) the
third was the result of a mistake in addition. In our report, we
identified three inconsistencies, which included (1) $180 million that
was initially reported to us as a fiscal year 2010 cost, (2) a
difference of over $5 million between the reported termination costs
of one component and the amount reported by the Transition Office, and
(3) a difference of approximately $300,000 between the reported
termination costs of a different component and the amount reported by
the Transition Office. We continue to believe that the reliability of
financial reporting is important. As mentioned in our report, internal
control standards state that entities should ensure the reliability of
financial information. Without ensuring the reliability of cost data,
DOD is not providing Congress and other stakeholders clear insight and
visibility into the cost of the NSPS termination.
8. With respect to designing the new performance management system
prescribed in the NDAA for FY 2010, DOD acknowledged that successful
projects require project plans, milestones, resources, review, and
decision processes. We found that the department did not have interim
goals and a timeline that linked to funding for the next steps in
designing the new performance management system and was not positioned
to determine if it was making progress or if resources were
appropriate for near-term efforts. DOD stated that Transition Office
staff had discussed its plan with us and had estimated resource needs
for the near-term design process. We disagree. The department
officials told us that they had an interim plan; however, such things
as goals and timelines, linked to funding, were not discussed with us
during the course of our review.
9. DOD commented that its design teams were presenting their detailed
project plans for the year at the end of their second session--March
31--and have stated project goals to fully explore options and develop
recommendations for consideration by DOD decision makers by the end of
fiscal year 2011. It further noted that the department had implemented
an interim project plan that continues to engage with its partners in
the joint labor and management design teams, and that is expected to
produce collaborative design recommendations for a new performance
management system that then will be scoped, addressed or full
implementation in a new project plan, and tied to funding. Although
the department discussed its interim plan with us, as noted, such
things as goals and timelines, linked to funding, were not discussed.
We continue to believe that it is important to set goals and a
timeline to show progress from day one and that key elements of a
sound management approach contain plans that include establishing
goals and time frames and aligning activities with resources.
10. The GAO job code should be 351519, not 3515039.
[End of Enclosure IV]
Enclosure V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Ron Fecso, Chief Statistician;
Marion A. Gatling, Assistant Director; Margaret G. Braley; Virginia A.
Chanley; Mae F. Jones; Lonnie J. McAllister; Mark R. Needham; Neil A.
Pinney; Amie M. Steele; Spencer J. Tacktill; Martha R. Tracy; John W.
Van Schaik; Jack C. Warner; and Jennifer L. Weber made key
contributions to this report.
[End of Enclosure IV]
Footnotes:
[1] GAO, High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-11-278] (Washington, D.C.: February
2011); DOD's High-Risk Areas: Actions Needed to Reduce Vulnerabilities
and Improve Business Outcomes, [hyperlink,
http://www.gao.gov/products/GAO-09-460T] (Washington, D.C.: Mar. 12,
2009); High-Risk Series: An Update, [hyperlink,
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January
2009); and Defense Business Transformation: Sustaining Progress
Requires Continuity of Leadership and an Integrated Approach,
[hyperlink, http://www.gao.gov/products/GAO-08-462T] (Washington,
D.C.: Feb. 7, 2008).
[2] GAO, Human Capital: Monitoring of Safeguards and Addressing
Employee Perceptions Are Key to Implementing a Civilian Performance
Management System in DOD, [hyperlink, http://www.gao.gov/products/GAO-
10-102 (Washington, D.C.: Oct. 28, 2009).
[3] The NDAA for FY 2004 provided DOD with the authority to establish
a pay-for-performance management system as part of the National
Security Personnel System.
[4] See [hyperlink, http://www.gao.gov/products/GAO-10-102] and GAO,
Human Capital: DOD Needs to Improve Implementation of and Address
Employee Concerns about Its National Security Personnel System,
[hyperlink, http://www.gao.gov/products/GAO-08-773] (Washington, D.C.:
Sept. 10, 2008).
[5] See [hyperlink, http://www.gao.gov/products/GAO-10-102] and
[hyperlink, http://www.gao.gov/products/GAO-08-773]. Also, see GAO,
Human Capital: DOD Needs Better Internal Controls and Visibility over
Costs for Implementing Its National Security Personnel System,
[hyperlink, http://www.gao.gov/products/GAO-07-851] (Washington, D.C.:
July 16, 2007), and Human Capital: Observations on Final Regulations
for DOD's National Security Personnel System, [hyperlink,
http://www.gao.gov/products/GAO-06-227T] (Washington, D.C.: Nov. 17,
2005).
[6] Pub. L. No. 111-84, § 1113 (2009).
[7] While the language of the NDAA for FY 2010 refers to the
"conversion" of employees from NSPS, DOD has referred to the process
of moving employees from NSPS to the General Schedule system and all
other systems as a "transition." For the purposes of this report, we
will refer to the respective conversions of civilian employees in each
of the components as "transitions."
[8] To complete the requirements of the NDAA for FY 2010, DOD first
transitioned employees from NSPS to their successor pay and personnel
system--which included reviewing NSPS position descriptions and
reclassifying each employee's position under the General Schedule
system.
[9] The NDAA for FY 2010 directs DOD, under the subsection entitled
"Performance Management and Workforce Incentives," to include certain
elements as part of the new performance appraisal system. We refer to
the system that DOD is in the process of developing as a "performance
management system."
[10] The NDAA for FY 2010 also provides the Secretary of Defense with
the authority to establish a Department of Defense Civilian Workforce
Incentive Fund and to implement other personnel flexibilities.
However, to date, DOD officials have stated that regulations have not
been promulgated to establish its enterprisewide performance
management system.
[11] The Deputy Secretary of Defense's January 22, 2010, memo was
entitled Establishment of the National Security Personnel System
Transition Office and Selection of John H. James, Jr. as Director.
[12] Department of Defense, Office of the Secretary of Defense,
Memorandum on Track Four Efficiency Initiatives Decisions (Mar. 14,
2011).
[13] DOD officials refer to the costs to transition employees and
terminate NSPS (the program) as "termination costs."
[14] This work was initially conducted in response to an anticipated
mandate in which DOD was expected to promulgate regulations for its
new performance management system and GAO was to report on the
processes established pursuant to those regulations; however, the
department did not issue those regulations. Subsequently, the Chairman
and Ranking Member for the Subcommittee on Readiness of the House
Committee on Armed Services requested a report based on our ongoing
work in this area.
[15] The Department of the Navy's NSPS policies include Marine Corps
civilians. The DOD Fourth Estate refers to all organizational entities
in DOD that are not in the military departments or the combatant
commands. Examples include the Office of the Secretary of Defense, the
Joint Staff, DOD's Office of the Inspector General, the defense
agencies, and DOD field activities.
[16] The guidance we reviewed and analyzed included the NSPS to GS
Transition Guide for the Human Resources Practitioner Chapters 1-6,
and the April 2010 Department of Defense Overarching National Security
Personnel System (NSPS) Transition Plan, which included guidance on
such things as roles and responsibilities, cost tracking, and
timelines for the NSPS termination.
[17] See Office of Personnel Management, Creating a Foundation for the
21ST Century Federal Workforce: The 2008 Assessment of the
Implementation of the Department of Defense National Security
Personnel System (Washington, D.C., December 2008); Alternative
Personnel Systems in Practice and a Guide to the Future (Washington,
D.C., October 2005); and A Fresh Start for Federal Pay: The Case for
Modernization (Washington, D.C., April 2002). Also, see Congressional
Research Service, Conversion from the National Security Personnel
System to Other Pay Schedules: Issues for Congress, R41321
(Washington, D.C., July 15, 2010).
[18] In 2004, 36 of the DOD unions voluntarily formed the United DOD
Workers Coalition to allow the workers to have one voice with regard
to NSPS. Each union elects representatives to speak on its behalf at
collaborative coalition meetings. DOD has 45 unions, which are
affiliated with 1,500 local bargaining units.
[19] GAO, Human Capital: Opportunities Exist to Build on Recent
Progress to Strengthen DOD's Civilian Human Capital Strategic Plan,
[hyperlink, http://www.gao.gov/products/GAO-09-235] (Washington, D.C.:
Feb. 10, 2009), and Results-Oriented Cultures: Implementation Steps to
Assist Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003).
[20] Department of Defense, Semiannual Report to Congress: Termination
of the National Security Personnel System (Washington, D.C., October
2010).
[21] According to the Transition Office, during fiscal year 2011
(through the end of February 2011), the department completed an
additional 8,336 transitions of employees from NSPS to the General
Schedule system. Thus, as of February 27, 2011, a total of 180,000
employees had been transitioned from NSPS. With regard to the numbers
of employees awaiting transition, as well as those who have already
transitioned, department officials noted that those figures change
with each pay period because of turnover and other changes in the
workforce.
[22] As of September 30, 2010, the total number of employees awaiting
transition from NSPS was 53,000.
[23] The guidance was included in the Transition Office's April 2010
report to Congress. The guidance, entitled NSPS Termination Costs and
Tracking, was to guide the component transition offices' cost
reporting efforts.
[24] According to officials in the Transition Office, DOD determined
that it would not be economically feasible to directly trace or assign
indirect costs for NSPS after a review of indirect costs in the
Statement of Federal Financial Accounting Standards No. 4, Managerial
Cost Accounting Standards and Concepts (July 31, 1995).
[25] NSPS termination cost tracking reports provided to us by the
components included the following five categories (as specified by the
Transition Office guidance): (1) Design and Termination; (2) Training,
Development, Support, and Execution; (3) Human Resources (HR)
Automated Systems; (4) Within-Grade Increase Buy-Ins, Performance
Awards, and Quality Step Increases (formerly Program Evaluation); and
(5) Program Office Operations.
[26] Department of Defense, Report to Congress: Termination of the
National Security Personnel System (Washington, D.C., Apr. 23, 2010).
[27] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[28] Statement of Federal Financial Accounting Standards No. 4,
Managerial Cost Accounting Standards and Concepts.
[29] As noted, a January 22, 2010, memo from the Deputy Secretary of
Defense redesignated the NSPS Program Executive Office as the NSPS
Transition Office and appointed a Director who reports to the Deputy
Assistant Secretary of Defense for Civilian Personnel Policy.
[30] Executive Order 13522, entitled Creating Labor-Management Forums
to Improve Delivery of Government Services, allows employees and their
union representatives to have predecisional involvement in workplace
matters to the fullest extent practicable.
[31] Officials from the Transition Office also said that nonunion DOD
employees were also involved in the conference.
[32] [hyperlink, http://www.gao.gov/products/GAO-03-669].
[33] [hyperlink, http://www.gao.gov/products/GAO-03-669].
[34] [hyperlink, http://www.gao.gov/products/GAO-09-235].
[35] While the language of the NDAA for FY 2010 refers to the
"conversion" of employees, the Department of Defense (DOD) has
referred to the process of moving employees from NSPS to the General
Schedule system and to all other alternative pay and personnel systems
as a "transition." For the purposes of this briefing, we will refer to
the process as a "transition."
[36] The NDAA for FY 2010 also provides the Secretary of Defense with
the authority to establish a DOD Civilian Workforce Incentive Fund and
to implement other personnel flexibilities.
[37] DOD officials refer to the costs to transition employees and
terminate NSPS (the program) as "termination costs."
[38] The Department of the Navy's NSPS policies include Marine Corps
civilians.
[39] The DOD Fourth Estate refers to all organizational entities in
DOD that are not in the military departments or the combatant
commands. Examples include the Office of the Secretary of Defense, the
Joint Staff, DOD's Office of the Inspector General, the defense
agencies, and DOD field activities.
[40] The transitions to the other pay and personnel systems did not
take place until spring 2011; therefore, we have not been able to
obtain as much information on these transitions as on the General
Schedule.
[41] Office of Personnel Management, Creating a Foundation for the
21st Century Federal Workforce: The 2008 Assessment of the
Implementation of the Department of Defense National Security
Personnel System (Washington, D.C., December 2008); Alternative
Personnel Systems in Practice and a Guide to the Future (Washington,
D.C., October 2005); and A Fresh Start for Federal Pay: The Case for
Modernization (Washington, D.C., April 2002).
[42] This guidance included NSPS Termination Cost Reporting, the NSPS
to GS Transition Guide for the Human Resources Practitioner Chapters 1-
6, as well as the April 2010 Department of Defense Overarching
National Security Personnel System (NSPS) Transition Plan, which
included guidance on such things as roles and responsibilities, cost
tracking, and timelines for the NSPS termination.
[43] In 2004, 36 of the DOD unions voluntarily formed the United DOD
Workers Coalition to allow the workers to have one voice with regard
to NSPS. Each union elects representatives to speak on its behalf at
collaborative coalition meetings. DOD has 45 unions, which are
affiliated with 1,500 local bargaining units.
[44] With regard to the numbers of employees awaiting transition, as
well as those who have already transitioned, department officials
noted that those figures change with each pay period because of
turnover and other changes in the workforce.
[45] According to the Transition Office, during fiscal year 2011
through the end of February 2011, the Army transitioned an additional
1,544 NSPS employees to the General Schedule system.
[46] Under TAPES, employees are assigned a rating based on five
performance rating definitions: successful level 1, successful level
2, successful level 3, fair, and unsuccessful.
[47] According to the Transition Office, during fiscal year 2011
through the end of February 2011, the Navy transitioned an additional
6,528 NSPS employees to the General Schedule system.
[48] Although Navy transition office officials stated that the second
tier is optional and Navy guidance indicates that the second tier is a
recommended framework, Marine Corps guidance issued on September 16,
2010, makes the second tier's framework mandatory Marine Corps-wide.
[49] According to the Transition Office, during fiscal year 2011
through the end of February 2011, the Air Force transitioned an
additional 234 NSPS employees to the General Schedule system.
[50] According to DOD's Transition from NSPS to GS Guidance, chapter
5, issued July 23, 2010, employees who transitioned from NSPS to the
General Schedule system from July 3, 2010, through January 1, 2011,
are eligible to receive a rating of record, for which a pay pool panel
is required.
[51] The Washington Headquarters Services agency is responsible for
managing the NSPS transition across all the DOD Fourth Estate entities.
[52] According to the Transition Office, during fiscal year 2011
through the end of February 2011, the DOD Fourth Estate transitioned
an additional 30 NSPS employees to the General Schedule system.
[53] As of September 30, 2010, the total number of employees awaiting
transition from NSPS was 53,000.
[54] The guidance was included in the Transition Office's April 2010
report to Congress and was to direct the component transition offices'
cost reporting efforts.
[55] According to a 2007 memo for component NSPS program managers,
entitled Reporting National Security Personnel System (NSPS)
Implementation Costs, DOD's intent, at the time of NSPS
implementation, was to report only direct NSPS implementation costs.
According to the memo, DOD determined that it would not be
economically feasible to directly trace or assign indirect costs for
NSPS after review of indirect costs in Statement of Federal Financial
Accounting Standards No. 4, Managerial Cost Accounting Standards and
Concepts (July 31, 1995).
[56] NSPS termination cost tracking reports provided to us by the
components included the following five categories (as specified by the
Transition Office guidance): (1) Design and Termination; (2) Training,
Development, Support, and Execution; (3) Human Resources (HR)
Automated Systems; (4) Within-Grade Increase Buy-Ins, Performance
Awards, and Quality Step Increases (formerly Program Evaluation); and
(5) Program Office Operations.
[57] Department of Defense, Report to Congress: Termination of the
National Security Personnel System (Washington, D.C., Apr. 23, 2010).
[58] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[59] Statement of Federal Financial Accounting Standards No. 4,
Managerial Cost Accounting Standards and Concepts.
[60] As noted, a January 22, 2010, memo from the Deputy Secretary of
Defense canceled the NSPS Program Executive Office charter,
redesignated the NSPS Program Executive Office as the NSPS Transition
Office, and appointed a Director who reports to the Deputy Assistant
Secretary of Defense for Civilian Personnel Policy.
[61] Executive Order 13522, entitled Creating Labor-Management Forums
to Improve Delivery of Government Services, allows employees and their
union representatives to have predecisional involvement in workplace
matters to the fullest extent practicable.
[62] [hyperlink, http://www.gao.gov/products/GA0-03-669].
[63] GAO, Human Capital: Opportunities Exist to Build on Recent
Progress to Strengthen DOD's Civilian Human Capital Strategic Plan,
[hyperlink, http://www.gao.gov/products/GAO-09-235] (Washington, D.C.:
Feb.10, 2009). See also [hyperlink,
http://www.gao.gov/products/GAO-03-669].
[64] See GAO, Human Capital: Monitoring of Safeguards and Addressing
Employee Perceptions Are Key to Implementing a Civilian Performance
Management System in DOD, [hyperlink,
http://www.gao.gov/products/GAO-10-102] (Washington, D.C.: Oct. 28,
2009); Human Capital: DOD Needs to Improve Implementation of and
Address Employee Concerns about Its National Security Personnel
System, [hyperlink, http://www.gao.gov/products/GAO-08-773]
(Washington, D.C.: Sept. 10, 2008); and DOD Civilian Personnel:
Intelligence Personnel System Incorporates Safeguards, but
Opportunities Exist for Improvement, [hyperlink,
http://www.gao.gov/products/GAO-10-134] (Washington, D.C.: Dec. 17,
2009).
[65] The Department of the Navy's NSPS policies encompass Marine Corps
civilians. The DOD Fourth Estate includes all organizational entities
in DOD that are not in the military departments or the combatant
commands, for example, the Office of the Secretary of Defense, the
Joint Staff, DOD's Office of the Inspector General, the defense
agencies, and DOD field activities.
[66] Department of Defense, Semiannual Report to Congress: Termination
of the National Security Personnel System (Washington, D.C., October
2010).
[67] GAO, Results-Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003), and Military Personnel: Sustained Leadership and Oversight
Needed to Improve DOD's Prevention and Treatment of Domestic Abuse,
[hyperlink, http://www.gao.gov/products/GAO-10-923] (Washington, D.C.:
Sept. 22, 2010).
[68] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]
(Washington, D.C.: November 1999).
[69] Statement of Federal Financial Accounting Standards No. 4,
Managerial Cost Accounting Standards and Concepts.
[End of section]
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