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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Operating efficiently and effectively
Operational Efficiencies
of EPA's Human Resources
Shared Service Centers
Not Measured
Report No. 18-P-0207
May 31, 2018
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Report Contributors:
Michael D Davis
Cara Lindsey
Heather Layne
Debra Coffel
Gabriel Porras-Sanchez
Abbreviations
CFR
Code of Federal Regulations
EPA
U.S. Environmental Protection Agency
FTE
Full-Time Equivalent
FY
Fiscal Year
GPRA
Government Performance and Results Act
HC
Human Capital
HR
Human Resources
HRACTS
Human Resources Activity and Communication Tracking System
IBC
Interior Business Center
LOB
Line of Business
OARM
Office of Administration and Resources Management
OHR
Office of Human Resources
OIG
Office of Inspector General
OMB
Office of Management and Budget
OPM
U.S. Office of Personnel Management
RTP
Research Triangle Park
ssc
Shared Service Center
VERA
Voluntary Early Retirement Authority
VSIP
Voluntary Separation Incentive Payments
Cover Image: Image on the EPA's Office of Research and Development Human Resources
intranet page. (EPA photo)
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May 31, 2018
* • U.S. Environmental Protection Agency 18-P-0207
\ Office of Inspector General
At a Glance
Why We Did This Project
The U.S. Environmental
Protection Agency (EPA),
Office of Inspector General
(OIG), performed this audit to
determine whether the EPA
has achieved efficiencies,
savings and improved
customer service in agency
human resources (HR)
operations by establishing
three HR Shared Service
Centers (SSCs) in Cincinnati,
Ohio; Las Vegas, Nevada; and
Research Triangle Park, North
Carolina.
In 2004, the U.S. Office of
Personnel Management
launched the HR Line of
Business (LOB) initiative,
envisioning "government-wide,
modern, cost-effective,
standardized, and
interoperable" HR services to
address "duplicative HR
systems and processes across
the federal government." Per
the EPA's HR SSC intranet
site, the agency launched its
HR SSCs in 2008 "to provide
consistent and efficient human
resources services to all EPA
employees regardless of their
physical location."
This report addresses the
following:
• Operating efficiently and
effectively.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
Listing of OIG reports.
Operational Efficiencies of EPA's Human
Resources Shared Service Centers Not Measured
What We Found
We could not determine whether the EPA achieved
operational efficiencies, savings and improved
customer service with the 2008 implementation of
its HR SSCs. Also, as of January 2017, there was
a disparity in the number of HR staff in each region
and SSC, with no direct correlation between the number of EPA employees
serviced by each location and the number of HR staff employed at each location.
Without a baseline for HR
operations and HR staff,
the EPA is unable to
determine efficiencies in
HR operations.
Federal law and the HR LOB initiative require agencies to focus on reducing
costs, improving quality and achieving cost efficiencies. However, the EPA did
not establish baseline metrics for HR SSC performance and did not collect data
to assess HR SSC performance and efficiencies from 2014 to 2016. In addition,
the Office of Administration and Resources Management did not determine the
appropriate HR staffing levels needed for each region and did not provide
guidance on core staffing needs for regional HR functions. Without a baseline
and a plan on how to use performance measurement data, we cannot determine
whether the EPA is achieving efficiencies in operations, cost savings and
improved customer service.
Our audit also noted that some of the EPA's key HR policies were outdated, with
one policy dating back to the 1970s. Although Office of Management Budget
directives require agencies to streamline policy creation and monitor internal
controls, the EPA's Office of Human Resources did not adhere to its HR policy
update agenda and did not regularly update its HR policies and procedures. As a
result, SSC managers often self-interpret federal guidance and policies, thus
creating inefficiencies.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Administration and
Resources Management (1) develop a plan that establishes a baseline to
measure the future program operational efficiency of HR operations; (2) establish
a workgroup comprising regional and program representatives to develop a
baseline level of HR support necessary for each program and regional office; and
(3) review HR policies, prioritize the policies requiring updates, and update the
policies with stakeholder input.
The Office of Administration and Resources Management concurred with all of
our recommendations and provided acceptable corrective actions with milestone
dates. The proposed corrective actions for Recommendations 1 through 3, when
completed, will meet the intent of the recommendations.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
May 31, 2018
MEMORANDUM
SUBJECT: Operational Efficiencies of EPA's Human Resources
Shared Service Centers Not Measured
Report No. 18-P-0207
FROM: Arthur A. Elkins Jr.
TO:
Donna J. Vizian, Principal Deputy Assistant Administrator
Office of Administration and Resources Management
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this audit was OA-FY17-0126.
This report contains findings that describe the problems the OIG has identified and corrective actions the
OIG recommends. This report represents the opinion of the OIG and does not necessarily represent the
final EPA position. Final determinations on matters in this report will be made by EPA managers in
accordance with established audit resolution procedures.
The EPA's Office of Administration and Resources Management (OARM) and the Office of Human
Resources within OARM are responsible for implementing the recommendations.
In accordance with EPA Manual 2750, your office provided acceptable corrective actions and milestone
dates in response to OIG recommendations. All recommendations are resolved, and no final response to
this report is required. However, if you submit a response, it will be posted on the OIG's website, along
with our memorandum commenting on your response. Your response should be provided as an Adobe
PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. The final response should not contain data that you do not want to be released to the
public; if your response contains such data, you should identify the data for redaction or removal along
with corresponding justification.
We will post this report to our website at www.epa.gov/oig.
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Operational Efficiencies of EPA's
Human Resources Shared
Service Centers Not Measured
18-P-0207
Table of C
Chapters
1 Introduction 1
Purpose 1
Background 1
Responsible Offices 4
Scope and Methodology 4
Prior Reports 5
2 Baselines for Assessing Efficiency Not Developed for EPA's
HR SSCs and HR Staff 7
Federal Law, HR LOB Initiative and Memorandums Require
Efficient Operations 7
Baseline Not Established and Customer Service Not Always Measured.... 8
HR Assessments Performed by EPA and OPM 10
EPA Has Disparate HR Staffing at the Regional and SSC Offices 12
Strategic Plan to Assess HR Efficiencies Not Developed 14
Efficiencies, Savings and Improved Customer Service Not Determined 15
Recommendations 15
Agency Comments and OIG Evaluation 15
3 Outdated HR Policies and Procedures Create HR SSC Inefficiencies 17
OMB Requires Agencies to Review Policies 17
Some EPA HR Policies Are Outdated 17
EPA Did Not Follow Its Policy Update Agenda 18
Outdated Policies and Procedures Created Inefficiencies 18
Ongoing Agency Actions 19
Recommendation 20
Agency Comments and OIG Evaluation 20
Status of Recommendations and Potential Monetary Benefits 21
Appendices
A OARM Response to Draft Report 22
B OARM Revised Response to Recommendation 3 26
C Distribution 28
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Chapter 1
Introduction
Purpose
The U.S. Environmental Protection Agency's (EPA's) Office of Inspector General
(OIG) conducted an audit of the agency's Human Resources (HR) Shared Service
Centers (SSCs). The objective of this audit was to determine whether the EPA has
achieved efficiencies, savings and improved customer service in agency HR
operations by establishing three HR SSCs.
Background
Federal HR Line of Business Initiative
In 2004, the U.S. Office of Personnel Management (OPM) launched its
governmentwide HR Line of Business (LOB) initiative to accomplish the
following goals: improved management, operational efficiencies, cost
savings/avoidance and improved customer service. In an August 2006
memorandum,1 the Office of Management and Budget (OMB) stated that the "key
goals" of the HR LOB initiative were "to improve services to citizens, to increase
the efficiency and effectiveness of the government, and to provide savings to the
taxpayer."
On May 21, 2007, the OMB and OPM issued a memorandum, Competition
Framework for Human Resource Management Line of Business Migrations, that
provides guidance for agencies planning to upgrade or replace their HR
management systems. This memorandum emphasizes that the intent of the HR
LOB is to "avoid costly and redundant investments in 'in-house' solutions for
common support services." However, the memorandum specifies that agencies
may upgrade their HR systems if they demonstrate that "investment in a system
limited to the agency's own use ... represents a better value and lower risk
alternative than migration to [a federal intergovernmental] SSC."
Per the OPM, the goal of the HR LOB is to deliver HR services through federal
intergovernmental SSCs. However, the EPA states that the "EPA isn't a shared
service provider in the sense of providing HR services to other federal agencies."
The EPA's transition to SSCs is considered an internal agency consolidation that
provides HR services only to its regions and program offices.
1 OMB, Memorandum M-06-22, Cost Savings Achieved Through E-Government and Line of Business Initiatives,
August 2006.
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Executive Order and Memorandums Require Efficient Operations
Subsequent memorandums and an executive order support the federal
government's drive toward efficiency. OMB Memorandum M-16-11, Improving
Administrative Functions Through Shared Services, issued on May 4, 2016, states
that efforts to implement SSCs "will reduce duplication and redundancy and
enable the government to redeploy funds to agency core mission activities." More
generally, Executive Order 13781, Comprehensive Plan for Reorganizing the
Executive Branch, issued on March 13, 2017, directs the OMB to "improve the
efficiency, effectiveness, and accountability of the executive branch." To facilitate
compliance with this executive order, OMB Memorandum M-17-22,
Comprehensive Plan for Reforming the Federal Government and Reducing the
Federal Civilian Workforce, issued April 12, 2017, requires agencies to develop
and submit an Agency Reform Plan that identifies how the head of each agency
proposes "to improve the efficiency, effectiveness, and accountability" of agency
operations. This memorandum provides a framework outlining the factors
agencies should consider when conducting an analysis of existing business
processes. Some of these factors are shown in Table 1.
Table 1: Framework to align activities with an agency's mission, role and performance
Factor
If...
Then explore options to ...
Cost-Benefit
The costs of continuing to operate an agency, a
component or a program are not justified by the
unique public benefits it provides.
Eliminate, merge, restructure, or
improve efficiency and effectiveness.
The long-term savings from shutting down or
merging agencies, components or programs—
including the costs of addressing the equities of
affected agency staff—are greater than the
expected costs.
Eliminate, merge, or improve
efficiency and effectiveness.
Efficiency and
Effectiveness
The agency, component or program—based on
the available body of evidence and historical
performance data—is ineffective or inefficient
(e.g., struggles to make decisions and execute).
Eliminate, restructure, improve
efficiency and effectiveness, improve
workforce performance/accountabiIity,
or enhance evidence-building.
Customer
Service
The agency, component or program can be
redesigned to better meet the needs of the public
and partners in service delivery in a more
accessible and effective manner.
Restructure or improve efficiency and
effectiveness
Source: OMB Memorandum M-17-22.
EPA's HR SSCs
The EPA HR SSCs were developed to align the EPA with the governmentwide
HR LOB initiative. EPA staff stated that prior to the formation of the three HR
SSCs, there were 15 separate and wholly autonomous HR operating offices that
used dissimilar HR processes. On May 8, 2007, the agency issued a case study,
EPA, Business Case Study, Shared Service Centers for Human Resources, which
states that "the ongoing need to reduce fixed costs and operate more efficiently"
motivated the EPA to launch "a number of budget initiatives to evaluate proposed
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disinvestments, innovations, efficiencies and consolidations." The study details
the goals of the agency's planned HR SCCs:
[Consolidating transactional-type human resources functions in
two or three shared service centers provides a strong foundation for
cost effectiveness, operational efficiencies, potential long-term cost
savings and reinvestment opportunities. The proposed
consolidation is designed to assure timely, high quality customer
service, mitigate impacts on affected human resources employees,
and position the Agency for government-wide competition via the
Human Resources Line of Business
The EPA has continued to emphasize these goals. For example, a press release
distributed in January 2008 states that the move to SSCs "would improve the
effectiveness, efficiency, and customer service of agency human resource
operations." In addition, the EPA intranet states that "HR SSCs strive to provide
consistent and efficient human resources services to all EPA employees regardless
of their physical location."
In June 2008, the EPA established HR SSCs in three locations—Cincinnati, Ohio;
Las Vegas, Nevada; and Research Triangle Park (RTP), North Carolina—to
process personnel and benefits actions for the agency's employees. The HR SSCs
provide support to regional, headquarters and program offices (Table 2). In fiscal
year (FY) 2016, the operating cost for the SSCs nationwide was approximately
$9.5 million. In addition, the Director of the Office of Administration and
Resources Management (OARM) in RTP (OARM-RTP) stated that the SSCs
processed 56,993 transactions in FY 2016.
Table 2: Regional, program and headquarters offices assigned to each HR SSC
Cincinnati
Las Vegas
RTP
Office of:
Office of:
Office of:
• Administration and
• Air and Radiation
• The Administrator
Resources
• International and
• The Chief Financial Officer
Management
Tribal Affairs
• General Counsel
• Enforcement and
• Inspector General
• Environmental Information
Compliance Assurance
• Water
• Chemical Safety and Pollution
• Land and Emergency
Regions:
Prevention
Management
• 9-10
• Research and Development
Regions:
Other locations:
Regions:
• 5-8
• Ann Arbor3
• 1-4
Source: EPA's HR SSC intranet site.
a EPA has a National Vehicle and Fuel Emissions Laboratory in Ann Arbor, Michigan.
Decision to Consolidate Las Vegas SSC During Our Audit
In response to Executive Order 13781, Comprehensive Plan for Reorganizing the
Executive Branch, the EPA provided the OPM with its Agency Reform Plan in
February 2018, which "represents a series of projects that EPA will complete to
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implement the goals of Executive Order 13781." In the plan, the EPA states its
intention to "examine our HR service model to determine if efficiency can be
obtained through realigning organizations, streamlining management layers and
examining the facility footprint." In addition, in a February 9, 2018, weekly report,
the Special Assistant to the acting Deputy Administrator summarized the Las Vegas
HR SSC consolidation plans:
Beginning in June 2018, work performed at EPA's human resources
shared service center in Las Vegas, Nevada leased space will transition
to EPA's owned locations in Research Triangle Park, NC and
Cincinnati, OH. This consolidation will improve the utilization of
EPA's real property portfolio and will positively impact staff
coordination and service delivery. ... The space will be released by
September 30, 2018.
Responsible Offices
The EPA's OARM is responsible for the issues in this report. Per the EPA's
website, OARM in Cincinnati (OARM-Cincinnati) and OARM-RTP provide
"human resources services to various EPA customers." In addition, the agency's
website states that OARM's Office of Human Resources (OHR) "is responsible
for management of human resource functions for headquarters employees, as well
as agency-wide policy development, strategic planning, and direction for the
EPA's human resource programs."
Scope and Methodology
We conducted this audit from March 2, 2017, to March 12, 2018, in accordance
with generally accepted government auditing standards issued by the Comptroller
General of the United States. 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 objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objective.
To determine whether the EPA has achieved efficiencies, savings and improved
customer service in agency HR operations by establishing three HR SSCs, we
reviewed the following relevant laws, procedures and policy orders:
• OPM, Human Resources Line of Business Initiative, 2004.
• OMB Memorandum M-06-22, Cost Savings Achieved Through
E-Government and Line of Business Initiatives, August 8, 2006.
• EPA, Business Case Study, Shared Service Centers for Human Resources,
May 8, 2007.
• OPM and OMB, Competition Framework for Human Resource
Management Line of Business Migrations, May 21, 2007.
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• [Government Performance and Results Act] GPRA Modernization Act of
2010, Public Law 111-352, January 4, 2011.
• OMB Memorandum M-11-31, Delivering an Efficient, Effective, and
Accountable Government, August 17, 2011.
• OMB Memorandum M-16-11, Improving Administrative Functions
Through Shared Services, May 4, 2016.
• OMB Circular No. A-123, Management's Responsibility for Enterprise
Risk Management and Internal Control, July 15, 2016.
• Executive Order 13781, Comprehensive Plan for Reorganizing the
Executive Branch, March 13, 2017.
• OMB Memorandum M-l 7-22, Comprehensive Plan for Reforming the
Federal Government and Reducing the Federal Civilian Workforce,
April 12, 2017.
• 5 CFR § 250.203, "Agency Responsibilities."
We also performed the following interviews and actions:
• Interviewed OARM management, SSC HR directors and staff to obtain an
understanding of the oversight practices in place to gauge the efficiencies
of the SSCs.
• Judgmentally selected and interviewed regional HR staff to determine
areas of responsibility in the HR function and the adequacy of HR
resources.
• Obtained and analyzed staff rosters for regional offices and SSCs in
calendar years 2006, 2007 and 2017.
• Obtained and analyzed internal assessments of EPA HR operations in the
regions and the SSCs. Reviewed OHR assessments of the regions issued
from calendar years 2007 through 2009 and 2013 through 2016. Reviewed
OPM assessments of the OHR issued in calendar years 2014 and 2015.
• From the EPA's intranet, determined current and outdated HR policies.
From SSC HR directors, determined the effect of outdated policies on HR
operations. Discussed with OHR management the reason for outdated
policies.
Prior Reports
EPA OIG Report No. 09-P-0206. EPA's Human Resources Management System
Did Not Deliver Anticipated Efficiencies to the Shared Service Centers, issued
August 11, 2009, found that the EPA's reliance on PeoplePlus to achieve HR SSC
efficiency and effectiveness involved "increased risks to its security and stability
because the software vendor no longer supported the current version." The report
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makes four recommendations; all corrective actions were completed by
October 20, 2010.
EPA OIG Report No. 10-P-0177. EPA 's Revised Hiring Process Needs Additional
Improvements, issued August 9, 2010, noted that the agency's HR SSCs "did not
consistently provide program managers with the best candidates, and data quality
and recruitment action processes need improvement." Specifically, the report
found that the agency "had not implemented critical technology upgrades or
obtained other resources necessary for the service center concept to succeed" and
that there was "a lack of management attention to policies and inconsistencies"
within the HR SSCs. The report makes eight recommendations; per the EPA, all
corrective actions were completed by June 1, 2014. However, based on the
subsequent changes in HR transactional processing discussed in Chapter 2 of this
current report, some of the corrective actions are no longer in place.
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Chapter 2
Baselines for Assessing Efficiency Not Developed
for EPA's HR SSCs and HR Staff
We could not determine whether the EPA achieved operational efficiencies,
savings and improved customer service with the 2008 implementation of its HR
SSCs. In addition, as of January 2017, there was a disparity in the number of HR
staff in each region and SSC, with no direct correlation between the number of
EPA employees serviced by each location and the number of HR staff employed
at each location. Federal law, the OPM HR LOB initiative and OMB
memorandums require agencies to focus on reducing costs, improving quality and
achieving cost efficiencies. However, the agency did not establish a baseline for
HR SSC performance, nor did it gather measures from 2014 to 2016 to assess HR
SSC performance and efficiencies. Without these measures, we cannot determine
the extent to which the EPA is achieving efficiencies in operations, savings and
improved customer service.
Federal Law, HR LOB Initiative and Memorandums Require Efficient
Operations
The GPRA Modernization Act of 2010 focuses on performance and improving
efficiencies in federal agencies, while OMB Memorandum M-ll-31, Delivering
an Efficient, Effective, and Accountable Government, provides additional
guidance on the act and assists agencies in refining performance management
guidance. In addition, the goals (outlined in Table 3) and vision (quoted below) of
the OPM's HR LOB initiative emphasize efficiency:
Governmentwide, modern, cost-effective, standardized and
interoperable human resource solutions providing common core
functionality to support the Strategic Management of Human
Capital [HC] and addressing duplicative and redundant HR
systems and processes across the Federal Government.
Table 3: Goals of OPM's HR LOB
Activity
Goal
Improved
Management
Improve governmentwide strategic management of HC: faster decision-
making, more informed policy-making, more effective workforce
management, and improved resource alignment with agency missions.
Operational
Efficiencies
Achieve or increase operational efficiencies in the acquisition,
development, implementation and operation of HR management and
supporting systems: improved servicing ratio/response times, reduced
cycle times and improved automated reporting.
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Activity
Goal
Cost Savings/
Avoidance
Achieve or increase cost savings/avoidance from HR solution activities:
reduced duplicative software/hardware/operations/labor resources and
increased competitive environment.
Improved
Customer Service
Improve customer service: increased accessibility to client and value;
improved communication and responsiveness; and enhanced quality,
timeliness, accuracy and consistency.
Source: OPM's "HRLOB Establishment Documents" webpage.
Per the OPM's HRLOB Migration Planning Guidance, agencies are required "to
prepare for, and manage, a migration of their human resource management
operations to a shared services environment." In the assessment phase, agencies
are required to envision how they can best deliver HR services to support their
missions and to develop business cases for change. The OPM identifies the
following activities as part of the "assess phase":
• Identify applicable HR benchmarks and best practices.
• Baseline current HR services delivery measures and metrics.
• Devise and validate an HR information technology strategy.
• Develop a business case.
In addition, OMB Memorandum M-17-22, Comprehensive Plan for Reforming
the Federal Government and Reducing the Federal Civilian Workforce, requires
agencies to operate more efficiently and to identify ways to reduce the cost of the
federal workforce. In Section III(D)(ii) of this memorandum, the OMB directs
agencies to examine the total cost of their personnel; to determine a baseline for
the appropriate number of full-time equivalents (FTEs); to evaluate and alter
organization and position structures to ensure they effectively and efficiently
support agency missions; and to "[k]eep positions current," which includes
assessing whether technology has "changed or eliminated the need for some
positions." In particular, the OMB notes that Management Analysts may duplicate
HR functions and that HR transactional services are among those fields
undergoing rapid transformation due to technology.
Baseline Not Established and Customer Service Not Always Measured
When the EPA established its HR SSCs in 2008, the agency did not establish a
baseline to measure performance, nor did it gather data from 2014 to 2016 to
assess HR SSC performance and efficiencies. In addition, although the agency
began collecting customer satisfaction and other HR SSC data in 2016, OARM
has not developed a plan regarding how to use this information. Without a
baseline and a plan to use performance measurement data, we cannot determine
whether the EPA is achieving efficiencies in operations, cost savings and
improved customer service.
On its "Program Evaluation and Performance Measurement at the EPA" webpage,
the EPA defines "performance measurement" as "a way to continuously monitor
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and report a program's progress and accomplishments, using pre-selected
performance measures." Program measures help offices determine "whether the
program is meeting its goals or objectives" and whether outcome activities
examine program processes and activities to "better understand how outcomes are
achieved and how quality and productivity could be improved." In addition, the
webpage defines "cost-effectiveness evaluation" as a way to "identify program
benefits, outputs or outcomes and compare them with the internal and external
costs of the program."
However, the EPA did not develop a performance measurement system to
determine the extent to which HR improvements and efficiencies were achieved
by its SSCs. Although the EPA did develop a business case as required by the
OPM, the agency did not develop a baseline of HR services delivery measures
and metrics. A baseline would have enabled comparison of data before and after
the HR SSCs were established, which would allow the agency to determine the
success of HR operations and whether the EPA is achieving its goals. Such
measurements are essential to making cost-effective decisions.
In December 2017, in response to the OIG's discussion document presenting our
findings to the agency, OARM proposed to implement the HR performance
measures/metrics being used and tracked under the new EPA Lean Management
System to establish the baseline for measures. The EPA is making this proposal
more than 9 years after the HR SSCs were established. Nevertheless, we agree
with the EPA's proposed plan, which will enable the EPA to measure and track
progress in meeting specific performance metrics.
SSC Customer Service Standards
One of the goals of the EPA HR SSCs is to provide excellent, efficient and
consistent customer service. The 2007 EPA HR business case study states that
service standards and performance metrics are "one of the most important factors
contributing to the success of shared service centers." In July 2008, the EPA
developed a Human Resources (HR) Shared Service Center (SSC) Customer
Service Standards document, which includes quantitative standards for customer
service (Table 4).
Table 4: General customer service support quantitative standards
Action requested
Timeframe for completion
Review, evaluate, and communicate the
completeness and appropriateness of a
requested action, and notify the customer if
additional information is needed, etc.
Within 3 workdays of receipt of action
Return noncomplex telephone calls, email
messages and general inquiries
Within 1 workday
Respond to complex inquiries requiring
problem resolution
Within 3 workdays; unresolved issues referred
for triage/resolution by appropriate source
within 5 workdays
Source: EPA's HR SSC Customer Service Standards.
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Despite the establishment of these standards, agency officials stated that there was
no system in place to assess the extent to which the HR SSCs have met these
standards. For example, no process was in place to track when telephone calls
were returned and when issues were resolved. In addition, an HR SSC Director
indicated that when the HR SSC standards were created, they represented more of
a goal than an actual plan.
HR Recruitment and Customer Satisfaction Tracking
From the time the HR SSCs were established in 2008 until 2014, the agency used
customer surveys generated by the HR Activity and Communication Tracking
System (HRACTS) to gauge SSC customer satisfaction. HRACTS also tracked
the status of recruitment actions, so that the agency could, according to OARM
staff, "fully understand the time to hire effort and opportunities to improve."
However, the agency stopped using HRACTS in 2014 when the EPA migrated to
the U.S. Department of Interior's Interior Business Center (IBC) to process
personnel and payroll services. The OARM Deputy Assistant Administrator cited
"survey fatigue" as another reason why customer satisfaction surveys were halted.
Furthermore, the Director of OARM-Cincinnati stated that the agency moved
away from Lotus Notes, thereby ending the agency's use of HRACTS.
Even though the IBC offers reporting capabilities for its personnel and payroll
customers, the EPA did not initially use these reports because they were not
agency-specific. In December 2016, 2 years after the EPA transitioned to the IBC,
the SSCs began utilizing the IBC reporting tools to analyze areas such as
customer service, the recruitment process timeline, temporary detail2 actions, and
others based upon ad hoc customer requests and needs. When the agency fully
implements the IBC reporting capability, the EPA should be able to obtain the
data needed to establish a baseline, which will allow the agency to determine
whether customer service and recruitment actions are improving from that point
forward. As of September 2017, the SSCs were in the process of demonstrating
IBC reporting capabilities to their customers. In the meantime, the agency should
develop a plan to use the information from these reports to help develop a
baseline and to evaluate the efficiency and effectiveness of agency HR operations.
HR Assessments Performed by EPA and OPM
The Director of OARM-RTP indicated that one way to gauge SSC efficiencies
would be to review the OHR's annual HR assessments of the regional offices
before and after the establishment of the SSCs. Since the SSCs were formed,
these assessments mainly address SSC operations. In addition, the OPM conducts
assessments of the EPA's agency-level HR business practices and HR
headquarters. According to the Director:
2 A detail is a temporary assignment of an employee to a different position or set of duties for a specified period. The
employee is expected to return to his or her regular duties at the end of the assignment.
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One of the most important metrics for an HR operations office is
the level of compliance with OPM regulations, Merit Systems
Principles and HR Policy and requirements. This is assessed and
documented through the OPM/OHR Accountability process. Each
SSC is assessed each year and strengths and weaknesses are
identified and reported - the SSC Leadership then develops an
action plan to address any identified issues or shares best practices
that are identified to ensure continuous improvement in meeting
our compliance and operational objectives.
EPA staff stated that before the SSCs were established, the annual HR
assessments revealed a variety of issues such as illegal hiring practices, lack of
position descriptions and improper delegation of authority. Per EPA staff, illegal
hiring occurs when the EPA hires an individual but does not have the right to do
so (e.g., if the new hire does not have the required educational qualifications). For
example, we found a 2007 Cincinnati HR assessment conducted just before the
SSCs were established that noted one issue regarding illegal hiring. In contrast,
our review of the EPA's HR assessments conducted on the regional offices after
the SSCs were established through 2009 noted no issues related to illegal hiring,
and our review of the SSC assessments from 2014 through 2016 noted just one
instance of illegal hiring in 2015, which occurred at the Cincinnati SSC.
In December 2017, in response to the OIG's discussion document, OHR staff
provided the following statements emphasizing other issues identified by
assessments conducted before the SSCs were established but not identified by
assessments conducted after the SSCs were established:
• "Region 10 had improperly delegated class authority to their managers and
had no valid position descriptions."
• "Region 5 had improperly accreted 43 employees on the same date,
resulting in backdating issues."3
• "Ann Arbor had no PDs whatsoever for 15% of its population (300)."
The HR assessments we reviewed after the establishment of the SSCs reported
issues related to merit promotion and delegated examining,4 where the proper
documentation was not available or uploaded to the electronic Official Personnel
Folder database, as required by federal regulations and EPA standard operating
procedures.
3 The OIG notes that the assessment we received states that the region "reclassified and noncompetitively upgraded"
47 employees—not 43 employees— "through accretion-of-duty promotions."
4 Delegated examining authority is an authority that the OPM grants to agencies to fill competitive civil service jobs
with applicants applying from outside the federal workforce, federal employees who do not have competitive service
status, or federal employees with competitive service status.
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EPA Has Disparate HR Staffing at the Regional and SSC Offices
As of January 2017, there was a disparity in the number of HR staff in each
region and SSC. In addition, there was no direct correlation between the number
of EPA employees serviced by each location and the regional and SSC HR staff
employed at each location.
Regional HR Staff
The Director of OARM-RTP stated that when the EPA established the SSCs,
OARM funded three HR staff positions—one for employee relations, one for
training and one for HC/strategic planning—in each region. Since HR
requirements in the regions may vary, regions used their own resources to fund
any additional HR staffing needs. However, OARM did not determine the
appropriate staffing levels needed for each region. OARM also did not provide
guidance on the core staff needed for regional HR functions or on the number of
regional staff needed to provide required HR services.
The regions are responsible for funding any locally based HR staff that they deem
necessary to augment the three OARM-funded HR positions. As shown in Table 5,
Region 5 had 15 HR FTEs in January 2017, while Region 8 staffed three FTEs.
Table 5: Comparison of regional HR staff and regional employee count
Region
Regional
HR staff count
Percentage of
total regional
HR staff
Regional
employee count
Percentage of
total regional
employees
11/06 a
1/17
1/17
11/06a
1/17
1/17
1
b 12.75
7
9%
673
574
8%
2
13
7
9
870
786
11
3
11
13
16
893
826
11
4
16
11
14
1,024
925
13
5
21
15
19
1,217
1,088
15
6
14
7
9
845
755
10
7
13
6
8
541
526
7
8
b 12.3
3
4
572
521
7
9
b 14.82
5
6
848
751
10
10
14
5
6
604
548
8
Total
141.87
79
100%
8,087
7,300
100%
Source: OIG analysis of OARM data.
aThis date was chosen to illustrate HR staffing levels before the SSCs were established.
b Decimals account for regional employees who did not work full-time on HR functions.
As of January 2017, the number of regional HR staff was not proportional to the
number of regional employees. As detailed in Table 5, Region 3 was the only
region with an increase in HR staff since the SSCs were established, with the
addition of two employees from November 2006 to January 2017 (an 18.2 percent
increase). However, the number of employees in Region 3 decreased from 893 to
826 (a 7.5 percent decrease). In addition, Region 3 had 16 percent of the total
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regional HR staff in January 2017, while it serviced only 11 percent of the total
regional employees.
In December 2017, in response to the OIG's discussion document, OARM staff
indicated that some staffing in the regional offices "have nothing to do with the
migration of transactional work." For example, Region 3 has two Labor and
Employee Relations staff, and Region 5 has five Labor and Employee Relations
staff. These positions are necessary, per OARM, because Labor and Employee
Relations work was not transitioned to the HR SSCs. In addition, OARM staff
stated that because the regions have assumed more HC work than when they were
operational HR offices, they need additional staff to do that work.
According to the EPA's 2007 business case study, the regional HR Officers
estimated that each region would need to locally maintain a minimum of six to
eight HR FTEs (for larger regions) to augment the SSCs. In our discussions,
Region 5 told us that it was sufficiently staffed. Region 8 told us that it was
understaffed and was not able to provide sufficient oversight of its internal review
processes for HR functions. Region 3 said that it was overstaffed with 13 HR
FTEs.
One regional HR Officer stated that, if the regions do not have adequate local HR
support, then regional HR staff are at risk of being unable to provide sufficient
oversight of HR functions, such as hiring processes or Voluntary Early
Retirement Authority (VERA)/Voluntary Separation Incentive Payments (VSIP)
offers.5 HR staff may also not be able to provide timely advice to managers.
Without adequate staff, the regions may not be able to provide quality, efficient
and effective support to their customers.
An OARM official stated that the magnitude of regional staff performing HR
functions is unknown. Instead, because regional staffing is based on the volume of
work and needs within each individual region, the regions determine where staff
are assigned at any particular time.
SSC and Nationwide HR Staff
The number of SSC FTEs has decreased since the centers were established in
2008 (Table 6). When the SSC FTEs are combined with the regional HR FTEs
from the same timeframes, the total number of HR FTEs agencywide has also
decreased, which indicates potential cost savings and efficiencies.
5 VERA and VSIP are programs designed to increase voluntary attrition in support of an agency's downsizing or
restructuring goals. If authorized by the OPM, agencies can offer certain employees VERA, which temporarily
lowers the age and service requirements for retirement, and/or VSIP, a buyout of up to $25,000 to separate from
federal service.
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Table 6: SSC and regional FTEs
HR FTEs
2008ab
2017 b
RTP
25
48.8
Cincinnati
11.25
27.75
Las Vegas
12.3
17
SSC Subtotal
48.55
93.55
Regional
142.8
79
Total
191.35
172.55
Source: EPA's 2007 business case staffing plan
and OARM data.
a FY 2008 President's Budget per EPA's 2007
business case study.
b Decimals account for employees who did not
work full-time on HR functions.
In December 2017, in response to the OIG's discussion document, OARM
indicated that prior to the migration to SSCs, program office staff had "non-HR
transactional personnel who performed internal coordination work" because
"[program offices were not delegated the authority to conduct true HR
transactional work." As a result, there were few "actual HR FTE in program
offices." The work that was performed by these non-HR staff was migrated to the
HR SSCs and is now being performed by HR staff.
Strategic Plan to Assess HR Efficiencies Not Developed
OARM management told us that it has not developed a "strategic plan" for the
HR SSCs. However, OARM staff stated that "strategic objectives for the SSCs
have been part of larger OARM-wide plans and initiatives." For example,
according to OARM management, in 2014 OARM began developing and sharing
key priorities in the acting Assistant Administrator's Priorities document, which
usually includes components that relate to HR and/or the SSCs. While not part of
a standalone plan, the HR mission is captured in that document as a part of the
office's overarching priorities.
However, the OPM noted the need for a Strategic HC Plan in its 2014 HC
management evaluation of EPA headquarters:
EPA has not updated its Strategic Human Capital Plan since 2006
to fully align its goals to that of the EPA SP [strategic plan]. This
makes it difficult to develop current Human Capital (HC)
strategies. EPA's HC documentation did not include strategies for
evaluating the efficiency and effectiveness of HR operations.
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Efficiencies, Savings and Improved Customer Service Not Determined
The EPA's goal is to improve operational efficiencies and customer service by
way of the HR SSCs. However, it is difficult to determine the extent to which the
EPA is achieving efficiencies in operations, costs and customer service because
the agency has not established a baseline or gathered performance measures from
2014 to 2016. In furtherance of OMB Memorandum M-17-22, which directs
agencies "to improve [their] efficiency, effectiveness, and accountability," the
EPA should develop a strategic plan that includes a baseline by which the
effectiveness of the SSCs can be measured. Without a plan that outlines
benchmarks and performance standards, we cannot determine whether the SSCs
improved efficiencies, savings and customer service.
In light of the government's efforts to reduce federal operating costs, the budget
situation and employee departures due to VERA/VSIP, the EPA should review its
HR staffing nationwide. In addition, the EPA should determine the baseline level
of staff needed for the required HR activities in the regions, program offices and
the SSCs and should plan accordingly to provide consistent service nationwide.
Recommendations
We recommend that the Assistant Administrator for Administration and
Resources Management:
1. Develop a plan that establishes a baseline to measure the future program
operational efficiency of human resources operations.
2. Establish a workgroup comprising regional and program representatives to
develop a baseline level of human resources support necessary for each
program and regional office.
Agency Comments and OIG Evaluation
OARM concurred with Recommendations 1 and 2. OARM provided acceptable
corrective actions and planned milestone dates. Recommendations 1 and 2 are
resolved.
For Recommendation 1, OARM agreed to establish and track HR performance
measures and metrics as part of the agency's new Lean Management system.
OARM stated that the SSCs are currently identifying additional metrics for areas
of service, such as nonrecruitment actions, benefits services and retirement
services. OARM said that it will finish identifying those additional service
metrics, establish baselines and begin tracking performance levels by
December 31, 2018. OARM also stated that by February 28, 2019, it will engage
the HR SSC Customer Advisory Group and the Project Management
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Officers/Regional HR Officers community to review and evaluate the HR SSC
Customer Service Standards document. Based on this review, the existing
standards may be restructured, replaced or eliminated.
In addition, OARM stated that it concurs with Recommendation 2, with the
understanding that it can only facilitate a discussion with program and regional
offices. By June 2019, OARM said it will engage the Project Management
Officers/Regional HR Officers community and other stakeholders to understand
the type of work and support being provided by those individuals; analyze best
practices; ensure that there are defined roles and responsibilities for the SSCs,
programs and regions; and develop guidelines on the core functions and necessary
support staffing levels that program and regional offices can use to evaluate their
organizations.
The OIG concurs with OARM's actions, which satisfy the intent of
Recommendations 1 and 2. Appendix A contains the complete OARM response.
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Chapter 3
Outdated HR Policies and Procedures Create
HR SSC Inefficiencies
Our review of the EPA's HR policies showed that some key policies are outdated.
We noted one policy that was dated as far back as the 1970s. OMB
memorandums require agencies to streamline policy creation and monitor internal
controls. However, the OHR did not adhere to its HR policy update agenda and
did not regularly update its HR policies and procedures. As a result, SSC
managers often self-interpret guidance and policies, thus creating inefficiencies.
OMB Requires Agencies to Review Policies
OMB Memorandum M-l 7-22, Comprehensive Plan for Reforming the Federal
Government and Reducing the Federal Civilian Workforce, issued April 12, 2017,
directs agencies to streamline policies "by eliminating the common tendency to
recraft/restate policy for a component or regional office."
Per OMB Circular A-123, Management's Responsibility for Enterprise Risk
Management and Internal Controls, management is required to design, implement
and operate an entity's internal control system. In addition, management
"develops and maintains documentation of its internal control system," documents
the agency's internal control responsibilities in policies, and "evaluates and
documents the results of ongoing monitoring and separate evaluations to identify
internal control issues."
Some EPA HR Polices Are Outdated
Our review of the EPA's HR policies showed that some key policies are outdated.
Our discussions with HR SSC senior leadership also revealed why the policies
should be updated (Table 7).
Table 7: Sample of outdated EPA policies and manuals
EPA policy/manual
Issue date
Reason policy should be updated
Merit Promotion Manual
3/91
The manual contains outdated references.
Reduction in Force
9/96
"Competitive Area" and "Competitive Level" definitions must
be updated for the policy to be properly applied.
Position Classification
8/75
The following portions need to be updated to align with OPM
guidance: titles; references; roles and responsibilities;
standard position descriptions; and position questionnaire,
initiating and appeals processes.
Employment of
Non-Citizens
9/96
This policy needs to include the appropriations act changes
from allowing appointments of citizens of countries with mutual
security agreements to requiring that any permanent residents
hired be seeking citizenship.
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EPA policy/manual
Issue date
Reason policy should be updated
Intergovernmental
Personnel Act Policy
and Procedures Manual
6/97
Outdated roles and responsibilities.
Term Appointments
6/87
Policy contains outdated references.
Source: OARM data and information from HR SSC staff.
The OPM's FY 2014 assessment of the EPA's HR functions also noted the
following concerns regarding the EPA's outdated policies:
EPA HQ had several outdated HR policies which were not aligned
with current regulations and HCAAF [Human Capital
Accountability and Assessment Framework] expected outcomes,
while others were in draft form. Discussions with the
Accountability Program manager (APM) revealed the EPA Office
of General Counsel was limited to a staff of two attorneys who
review and approve EPA HC policies. While we understand the
limitations EPA has faced, the agency must ensure its HC policies
are updated to prevent the application of erroneous information
which may adversely impact employees.
As part of its assessment, the OPM issued a "Required Action" for the EPA to
update its HC strategies to "include clearly defined measures and milestones to
align with the goals and objectives of the current strategic plan." In response to
the OPM assessment, the EPA noted that an HC action plan and an HR policy
update plan were submitted to the OPM on June 12, 2015. Our review of the HC
action plan noted that the agency issued guidance in some areas. However, the
agency should continue to review its policies and develop a plan to update needed
HR policies.
EPA Did Not Follow Its Policy Update Agenda
OHR staff explained to us that policy writing can be very detailed and complex,
even more so if the policy affects employees in a bargaining unit. These staff
indicated that a policy agenda is created every fiscal year to determine which
policies will be updated; quite often, they said, updates to the agenda's more
pertinent policies are delayed because of the influence of senior management and
the EPA HR community or because of the need to update other policies in
response to OIG reports and recommendations.
Policies and Procedures Created Inefficiencies
SSC staff indicated that outdated EPA policies and manuals cause them to over-rely
on standard operating procedures. As a result, some HR SSC standard operating
procedures have supplanted agency policy. In addition, because EPA policies are
not always updated after OPM guidance is issued or updated, SSC managers spend
time interpreting the OPM's guidance and policies themselves. Regional HR staff
18
Outdated
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stated that the EPA's HR policies should be updated to avoid misinterpretation of
federal law. The staff also said that wording of the policy is not always definitive
and leaves room for confusion. As noted by the OPM, the EPA "must ensure its HC
policies are updated to prevent the application of erroneous information which may
adversely impact employees." Federal and OPM guidance and updates should be
reflected in the EPA's policies and procedures to satisfy federal and OPM
requirements.
Ongoing Agency Actions
In response to the draft report, the EPA stated that two significant HR policies are
slated to be reviewed in FY 2018: one on "classification" and one on
"recruitment, relocation and retention." OARM explained its policy review
process:
OHR develops an annual agenda which may be modified at any
time. OHR notified OIG during the review that it had a policy
agenda for the next couple of years (i.e., FY18-FY19) to address
some of the foundational policies mentioned by the SSCs as being
out of date. While our goal is to complete those policies in the
identified fiscal year [see Table 8], we did not commit that all
those policies would be completed by the end of FY19. Some of
these policies (e.g., merit promotion) are negotiable and will
require union involvement. As noted, OHR prioritizes which
policies to work on at any given time given resources and specific
needs of the agency at that time. In addition, the policy agenda is
often modified during a FY to address other priorities (e.g., last
year the agency had to modify the plan to accommodate the
development of an emergency leave transfer program due to the
hurricanes that struck the U.S.). When the plan is modified, the due
dates of other policies in the queue may be pushed back. Thus, the
agenda provided to OIG should be considered a plan [see Table 8],
that is subject to change and not viewed as absolute due dates.
The agency also provided its proposed policy review for FY 2018 and calendar
year 2019 (Table 8).
Table 8: EPA's planned policy reviews
FY 2018
Calendar year 2019
Merit promotion
Leave
Classification
Pay setting
Recruitment, relocation and retention
Premium pay
Source: OARM staff.
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Recommendation
We recommend that the Assistant Administrator for Administration and
Resources Management:
3. Review human resources policies, prioritize the policies requiring updates,
and update the policies with stakeholder input.
Agency Comments and OIG Evaluation
OARM concurred with Recommendation 3 and provided acceptable corrective
actions and planned milestone dates. Recommendation 3 is resolved.
OARM also provided additional information regarding its policy review process.
We revised this report accordingly and included the information provided.
OARM did not initially provide a milestone date for the completion of its planned
policy reviews. OARM provided a revised response to Recommendation 3 and
stated that by December 31, 2019, it "will have a subject matter expert reviewed
draft ready for Directive Clearance Review and/or union negotiation for the
policies listed in Table 8 of the report." OARM further stated the following:
We recognize the importance of keeping our policies current and
will continue to engage the SSCs and program/regional offices to
identify areas of focus and to establish a tentative schedule for
reviewing and updating those policies. This is a current annual
practice of OARM OHR. OARM engages with stakeholders
through workgroups to review and draft any policies, updates. All
policies receive subject matter expert, senior management, and
legal review before implementation. Most are vetted through a
standard policy review process that involves many stakeholder
groups, including the five unions.
The OIG concurs with OARM's actions, which satisfy the intent of
Recommendation 3. Appendices A and B contain OARM's responses to
Recommendation 3.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Potential
Planned
Monetary
Rec.
Page
Completion
Benefits
No.
No.
Subject
Status1
Action Official
Date
(in $000s)
15 Develop a plan that establishes a baseline to measure the future
program operational efficiency of human resources operations.
15 Establish a workgroup comprising regional and program
representatives to develop a baseline level of human resources
support necessary for each program and regional office.
20 Review human resources policies, prioritize the policies requiring
updates, and update the policies with stakeholder input.
Assistant Administrator for 2/28/19
Administration and
Resources Management
Assistant Administrator for 6/30/19
Administration and
Resources Management
Assistant Administrator for 12/31/19
Administration and
Resources Management
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
OARM Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
April 16.2018
OfFICEOf
ADMINISTRATION
AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Response to Dra" " '1 ' ncies of EPA's Human Resources Shared
Service Centers 0A-FY17-0126
FROM: Donna J. Vizian it jh/fyfj
Principal Deputy Assistant A
TO:
Michael Davis
Director, Efficiency Audits
Office of the Inspector General
The Office of Administration and Resources Management appreciates the oppo ltunity to review
and provide feedback to the draft report "Operational Efficiencies of EPA's Human Resources
Shared Service Centers Not Measured'", Project No. OA-FY17-0126 dated March 12, 2018. In
addition to our response to the three recommendations, OARM has one item of feedback
regarding the "factual information" provided in the report.
Report Feedback
Page 18 states: In December 201 7, in response to the OJG's discussion document, OHR
proposed a policy review agenda/or fiscal years 2018 and 2019 (Fable 8). OHR staff indicted
that it "has to prioritize which policies to work on at any given time given limited resources and
the agency's time intensive directives clearance review process. " The proposed actions when
completed, will meet the intent of Recommendation 3. However, since the proposed actions are
scheduled to be competed in fiscal year 2019, we will continue to keep this recommendation in
the report.
Table 8: EPA 's proposed policy review Fiscal year 2018 Fiscal year 2019
Merit Promotion Leave
Classification Pay setting
Recruitment\ Relocation and Retention Other Incentive Payments
Premium Pay
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Response: OHR's policy agenda was developed prior to December 2017 and is partly based on
recommendations from the SSC Directors. OHR did not propose an agenda specifically to
address OIG's preliminary findings. OHR develops an annual agenda which may be modified at
any time. OHR notified OIG during the review that it had a policy agenda for the next couple of
years (i.e., FYI 8-FYI9) to address some of the foundational policies mentioned by the SSCs as
being out of date. While our goal is to complete those policies in the identified fiscal year, we did
not commit that all those policies would be completed by the end of FYI 9. Some of these
policies (e.g., merit promotion) are negotiable and will require union involvement. As noted,
OHR prioritizes which policies to work on at any given time given resources and specific needs
of the agency at that time. In addition, the policy agenda is often modified during a FY to address
other priorities (e.g., last year the agency had to modify the plan to accommodate the
development of an emergency leave transfer program due to the hurricanes that struck the U.S.).
When the plan is modified, the due dates of other policies in the queue may be pushed back.
Thus, the agenda provided to OIG should be considered a plan that is subject to change and not
viewed as absolute due dates.
There are two significant policies listed that are slated to be completed in FYI 8: Classification
and Recruitment, Relocation and Retention.
All other policies listed have been/will be started between FY18-FY19 and completed as soon as
possible but not guaranteed by the end of FY19.
Responses to Recommendations
Recommendation 1: Develop a plan that established a baseline to measure the future program
operational efficiency of human resources operations.
Response: OARM concurs. As noted in the draft report, OARM agreed to establish and track
HR performance measures/metrics as part of the agency's new Lean Management system. In
October 2017 OARM's SSCs began tracking five national level metrics for SSC performance.
These metrics track overall time-to-hire including the time-to-hire for standard recruitment
packages and non-standard recruitment packages. The metric also breaks out the process by step
so the agency can evaluate the time for each step in the process and identify potential areas of
concerns and/or opportunities to operate more efficiently. Other national level metrics being
tracked include the quality of packages submitted for SSC processing and reasons why packages
might be returned to the customer for further work (rework) and the percentage of "standard
packages" used by program and regional offices for those established job series.
OARM's SSCs are currently identifying additional metrics for other areas of services such as
processing non-recruitment actions and benefits/retirement services. By December 31, 2018
OARM will identify those additional service metrics, establish baselines, and begin tracking the
performance levels. OARM will also engage the Human Resources Shared Service Centers
Customer Advisory Group (CAG) and the PMO/RHRO community to review the posted
Customer Service Standards to determine if they are effective measurements for customer
service. The SSCs will evaluate the feasibility of measurement for these standards and as
necessary establish standards that are both impactful and measurable. Based on this review the
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existing standards may be restructured, replaced or eliminated. OARM will complete this effort
by February 28, 2019.
Recommendation 2: Establish a workgroup comprising regional and program representatives
to develop a baseline level of human resources support necessary for each program and
regional office.
Response: OARM concurs with this recommendation with the understanding that OARM can
only facilitate a discussion with program and regional offices. Each program and regional office
has the authority and discretion to staff their organization in the manner that best meets their
mission requirements. When the SSCs were established, the agency senior leadership was aware
of the total number of staff located in each human resource office - those staff funded by OARM
as the National Program Manager and those staff supplemented by regional offices using non-
OARM resources. The agency leadership made the decision to focus solely on the OARM
funded FTE. Because the move to shared service centers was focused only on processing HR
transactional services, there was no discussion about the number of staff members providing
HR/Human Capital support to program and regional offices.
OARM recognizes the importance of identifying the level and type of HR support located within
each regional and program office. We will engage the PMO/RHRO community and others to
understand the type of work/support being provided by those individuals, analyze best practices;
ensure there are defined roles and responsibilities of all (SSCs/programs/regions); and develop
guidelines on core functions and necessary support staffing levels that program and regional
offices can use in evaluating their current organizations. Target completion date is June 2019.
Recommendation 3: Review HR policies, prioritize the policies requiring updates, and update
the policies with stakeholder input.
Response: OARM concurs with this recommendation. We recognize the importance of keeping
our policies current and will continue to engage the SSCs and program/regional offices to
identify areas of focus and to establish a tentative schedule for reviewing and updating those
policies. This is a current annual practice of OARM/OHR. OARM engages with stakeholders
through workgroups to review and draft any policies/updates. All policies receive subject matter
expert, senior management, and legal review before implementation. Most are vetted through a
standard policy review process that involves many stakeholder groups, including the five unions.
We have previously shared our current plan for FY2018 and FY2019; however, policy review
and updating is a continuous process so no completion date can be established.
Please let John Showman or myself know if you have any questions or require additional
information.
cc: John Showman, DAA, OARM
Lauren Lemley, OARM AFC
Rick Carter, Director, OARM-CINN
Arron Helm, Director, OARM-RTP
Wesley Carpenter, Director, OHR
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SSC Directors
Debbi Hart, Director, Policy, Planning and Training Division, OARM/OHR
Heather Layne, OIG Project Manager/Senior Audit or
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Appendix B
OARM Revised Response to Recommendation 3
l Ni l MI> S l"Al"i:S KW IRONMKNTAl I'ROTF.C HON AM-1M V
Ol-'WCEOl-
ADMINISTRATION
,«6- AND RESOURCES
4 m§ Apill 2c'\ 2» Not Measured" - Project No.
cvi7J>ns
si i
Revised
ol'LP.
OA-FYI74U2!.
f) h ¦¦ ;
FROM: Do nun J Vizi an n ' ' '
Principal Depot) AUr¥v>hi>tnrior "
S
TO: Michael l)u\ is
Direetoi I flkieiic\ Audit*
Office of the Inspecior Genera'
Based on a meeting held between our offices on April 23, 2018, the Office of Administration and
Resources is revising our response and corrective action for Recommendation 3:
Recommendation 3: Review HR policies, prioritize the policies requiring updates, and update
the policies with stakeholder input.
Response: OARM concurs with this recommendation. We recognize the importance of keeping
our policies current and will continue to engage the SSCs and program/regional offices to
identify areas of focus and to establish a tentative schedule for reviewing and updating those
policies. This is a current annual practice of OARM/OHR. OARM engages with stakeholders
through workgroups to review and draft any policies/updates. All policies receive subject matter
expert, senior management, and legal review before implementation. Most are vetted through a
standard policy review process that involves many stakeholder groups, including the five unions.
By December 31, 2019, OARM will have a subject matter expert reviewed draft ready for
Directive Clearance Review and/or union negotiation for the following policies:
Merit Promotion (target FY2018)
Classification (target FY2018)
Recruitment, Relocation and Retention (target FY2018)
Premium Pay (target FY2018)
Leave (target CY2019)
Pay setting (target CY2019)
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Please let John Showman or myself know if you have any questions or require additional
information.
cc: John Showman, DAA, OARM
Lauren Lemley, OARM AFC
Rick Carter, Director, OARM-CINN
Arron Helm, Director, OARM-RTP
Wesley Carpenter, Director, OHR
SSC Directors
Debbi Hart, Director, Policy, Planning and Training Division, OARM/OHR
Heather Layne, OIG Project Manager/Senior Auditor
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Appendix C
Distribution
The Administrator
Deputy Administrator
Chief of Staff
Chief of Operations
Assistant Administrator for Administration and Resources Management
Regional Administrators, Regions 1-10
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Administration and Resources Management
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Human Resources, Office of Administration and Resources Management
Director, Office of Resources, Operations and Management, Office of Administration and
Resources Management
Director, Office of Administration and Resources Management—Research Triangle Park
Director, Office of Administration and Resources Management—Cincinnati
Director, Office of Regional Operations
Deputy Director, Office of Resources, Operations and Management, Office of Administration
and Resources Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinators, Regions 1-10
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