Is it All or Nothing on General Schedule Reform?

Last week the Government Accountability Office (GAO) issued a report on the General Schedule. The report, “OPM Needs to Improve the Design, Management, and Oversight of the Federal Classification System” outlines eight key attributes of a modern classification system and assesses the degree to which the General Schedule aligns with those attributes. The eight are:

  • Internal equity. All employees with comparable qualifications and responsibilities for their respective occupations are assigned the same grade level.
  • External equity. All employees with comparable qualifications and responsibilities are assigned grade levels and corresponding pay ranges comparable to the nonfederal sector.
  • Transparency. A comprehensible and predictable system that employees, management, and taxpayers can understand.
  • Flexibility. The ease and ability to modify the system to meet agency-specific needs and mission requirements, including modifying rates of pay for certain occupations to attract a qualified workforce, within the framework of a uniform government-wide system.
  • Adaptability. The ease and ability to conduct a periodic, fundamental review of the entire classification system that enables the system to evolve as the workforce and workplace changes.
  • Simplicity. A system that enables interagency mobility and comparisons with a rational number of occupations and clear career ladders with meaningful differences in skills and performance, as well as a system that can be cost-effectively maintained and managed.
  • Rank-in-position. A classification of positions based on mission needs and then hiring individuals with those qualifications.
  • Rank-in-person. A classification of employees based on their unique skills and abilities.

GAO recognized that some of these attributes appear to be in conflict with one another. For example, classifying positions based upon rank-in-position and based upon rank-in-person appear to be polar opposites. GAO also criticizes the Office of Personnel Management for not having adequate oversight of GS classification, not updating standards frequently enough, and not adequately resourcing the program. OPM partially concurred with most of GAO’s recommendations, but did not concur on the issue of developing a strategy to systematically track and prioritize updates to occupational standards.

Both GAO and OPM positions have merit. GAO is correct that the GS system is outdated and overly complex. They are right that OPM has not adequately resourced the program. They are right that OPM should address the shortcomings of the GS system sooner rather than later. OPM is correct in saying it does not need a new process to get classification standards written and updated more regularly. OPM also said it has only 6 full time classification policy staff. GAO says OPM has to make tradeoffs the same as any other agency.

That last point is one that I think is important. Yes, OPM has to make tradeoffs. I have not hesitated to criticize OPM when it is off track. In this case, I think they are in a no-win situation. The agency’s recent budget requests show OPM’s appropriated dollars are significantly less than they have been in the past. The agency operates more on revolving funds than appropriations. They also have trust fund money that covers management of retirement and insurance programs. Those color-of-money distinctions are important, because they limit the number of people OPM can devote to policy and oversight work. While the agency has over 5,000 employees, less than 20% of them can be assigned policy, oversight and agency management tasks. That puts OPM in the position of playing management whack-a-mole with priorities. If they decide to devote far more resources to classification, they will have to come from other programs, leading to those programs being under resourced.

GAO’s Recommendations

GAO’s report established a good set of criteria for an effective classification system. It also made three recommendations for executive branch action:

  • Working through the CHCO Council, and in conjunction with key stakeholders such as the Office of Management and Budget, unions, and others, should use prior studies and lessons learned from demonstration projects and alternative systems to examine ways to make the GS system’s design and implementation more consistent with the attributes of a modern, effective classification system. To the extent warranted, develop a legislative proposal for congressional consideration.
  • Develop cost-effective mechanisms to oversee agency implementation of the classification system as required by law.
    • Develop a strategy to systematically track and prioritize updates to occupational standards.
    • Develop a strategy that will enable OPM to more effectively and routinely monitor agencies’ implementation of classification standards.

The first recommendation is the most critical, because it could negate the need for at least one of the other two recommendations. In recent years the CHCO Council has become an effective means of driving government human capital policy. A CHCO Council working group, partnering with OMB and with unions (at the national level), could develop a set of policy recommendations that would make the current classification process far less complex, without changing the underlying laws. That last point is critical – the likelihood of significant Civil Service reform that is enacted by the Congress is remote, due to the combination of Congressional dysfunction and a lack of appetite for Civil Service reform.

Reform Does Not Require Congress to Act

How would we dramatically change GS classification without rewriting the law? Most people think the highly complex GS system is entirely a creation of the Classification Act of 1949 (as amended). It is true that the Classification Act created the General Schedule and defines each of the 15 GS grade levels. Much of the complexity (23 occupational families and 420 job series) comes from policy decisions made by OPM and others in the 65 years since the Classification Act passed. There is no legal requirement to have 420 job series. OPM creates new series when it determines they are necessary, is asked by the White House to do so, gets statutory direction, or they are requested by agencies. A great example is Cyber Security. There is a lot of pressure (including in the intro of the GAO report) to create a Cyber Security job series. OPM has not done so, and with good reason. At the Department of Homeland Security we had a need for more Cyber Security professionals. They were not in a single job series and could not be. Cyber Security is a complex field that includes Computer Scientists, Network and Systems Engineers, Security Specialists, Digital Forensics Specialists, Program Managers, Intelligence Specialists, and about 10 more categories. A single job family cannot address so many different positions that have radically different duties and qualifications requirements. In fact, GAO points out that the use of 420 job series adds unnecessary complexity to the GS system.

Where we need to go is in the opposite direction. The number of job series should be reduced by at least half, and more likely by three quarters. One reason OPM cannot maintain current standards for all of the jobs is that there are too many of them. GAO also points out that the stove piping of jobs into narrow series may hamper career growth. So – we have too many series, we cannot maintain the classification standards because of that, and the number limits agency flexibility on reassigning staff. It also makes for an arduous and overly complex hiring process for applicants from outside government.

If the number of job series is reduced to a more manageable number (I suggest no more than 100), we could achieve most of the objectives of GAO’s eight attributes of a modern classification system. Even some of the apparently conflicting attributes can be addressed. For example, on the surface it appears we cannot have a system that includes both rank-in-person and rank-in-position attributes. But we can. Take a look at the Research Grade Evaluation Guide (RGEG) published by OPM. The RGEG includes 4 classification factors:

  1. Research Assignment
  2. Supervisory Controls
  3. Guidelines and Originality, and
  4. Contributions, Impact, and Stature

The RGEG recognizes that “Work commonly expands commensurate with the researcher’s motivation, capability, and creativity.” Evaluation of factor 4 is based upon the researcher’s accomplishments rather than a rigid standard based upon the job itself. The RGEG recognizes that it is difficult to separate the person from the work the person does. OPM could use a similar approach to incorporate both rank-in-person and rank-in-position into new classification standards. The RGEG also covers research in many fields – there is not an RGEG for Physics, one for Chemistry, one for medicine, etc. OPM could use a similar approach with multi-series standards to dramatically reduce the number of classification standards it has to write and maintain. For example, a STEM Grade Evaluation Guide could cover many STEM positions. An Administrative Grade Evaluation Guide could cover financial management, human resources, procurement and other administrative positions.

Benefits of Administrative Reform

Administrative reform is faster, more achievable, and less likely to veer off into Fed bashing than a statutory solution might be. It maintains stability in the legal framework of the Civil Service, yet addresses the Adaptability feature in GAO’s 8 attributes. It achieves Simplicity, adopts both Rank-in-Person and Rank-in-Position attributes, and should also improve Internal Equity. It certainly demonstrates Flexibility as well. While we may not be able to get to a completely modern classification system without Congressional action, we can certainly improve on what we have today. By pursuing an administrative rather than statutory solution, OPM can begin to rapidly address many of the shortcomings of the existing system. The points of view of key stakeholders, such as unions and the Senior Executives Association, can be taken into account, as can those of good government advocates such as the Partnership for Public Service and the National Academy of Public Administration. The CHCO Council can drive the process, ensuring the resulting changes are implementable and consistent with accomplishing agency missions. Rather than waiting for the day when Civil Service reform might be achievable in Congress, we can act now. Why wait??

 

Fear Not: The Case for Shared Services in Government

The Federal government, much like any other organization, either provides for itself or buys a wide range of overhead services to support its operations. Overhead is not a derogatory term – it is just the term that is applied to services that are necessary to support the mission of an agency. Missions do not get accomplished without overhead services. While overhead services such as Human Resources, Financial Management, or Contracting support follow laws and regulations that are remarkably consistent across agencies, most agencies have dedicated internal service providers. The result is a level of redundancy and cost that diverts scarce resources to overhead functions rather than agency missions. Faced with decreasing budgets and shocks such as sequestration, agencies can no longer afford to carry out business-as-usual with respect to common support services. Secretary of Defense Chuck Hagel challenged his Department and its stakeholders to “…challenge all past assumptions…” and “put everything on the table.”

“We need to challenge all past assumptions, and we need to put everything on the table.  For example, it is already clear to me that any serious effort to reform and reshape our defense enterprise must confront the principal drivers of growth in the department’s base budget – namely acquisitions, personnel costs, and overhead.”

Secretary of Defense Chuck Hagel – April 3, 2013

One good example of overhead services that whould be “on the table” is Human Resources/EEO. Looking only at the number of Federal employees in those occupations, we see 2% of the Federal workforce in the HR/EEO (41,929 employees) job series. Because both HR and EEO offices also employ people in other job series, such as IT, budget, and administration, my experience is that as many as a quarter of the people in HR offices are not in HR series. That means another half percent of the Federal workforce are HR in non-HR job series. The number may be higher. Assuming that conservative number, 2.5% of the Federal workforce exists to provide HR services to the government.

Federal Employees in HR/EEO Job Series

Job Series

# of Employees

Average Salary

Total Cost

201

27,698

$84,957

$2,353,138,986

203

11,480

$43,199

$495,924,520

260

2,751

$93,971

$258,514,221

$3,107,577,727

+ 30% Fringe

932,273,318

Total Cost

$4,039,851,045

 

If we look only at the costs of the Human Resources/EEO workforce (in salary and fringe benefits cost of employees in the 201 (HR Specialist), 203 (HR Clerk and Assistant) and 260 (Equal Employment Opportunity) job series is more than $4 billion. HR/EEO organizations also employee people in other job series, such as budget, clerical and information technology, and the common “catch-all” 301 job series. Use of the 301 series for HR has increased in recent years as a way of reducing the apparent number of HR professionals, and to support grades that are often not as easily obtained in the more prescriptive 201, 203 and 260 job series. In addition to the non-HR/EEO job series, HR/EEO service organizations also purchase contract support. The number of dollars devoted to such services is difficult to identify, government-wide it is certainly in the hundreds of millions and perhaps more. Because the costs of common services are buried in agency budgets, the number is rarely examined as a single cost. The time has come to begin that examination and find ways to reduce the cost to a more manageable level.

There are many side effects of failure to consolidate overhead services. Chief among them is the lack of money for training staff and modernizing systems and processes. An agency with redundant overhead organizations will cut costs by taking away everything but salary dollars and leaving the overhead functions with few resources to do anything other than pay their employees. It is rare to find an HR office that is adequately resourced, even when the agency is spending more on such services than would seem necessary. The agency wonders why it is not getting great support, the employees in the support organizations wonder why they cannot get training or adequate tools to do their work, and everyone wonders why it does not get better. An agency, its employees and its HR staff are far better off with one or two well-staffed, trained and resourced HR offices than they are with ten marginally staffed and resourced organizations that struggle to provide good service.

I have heard people saying for years that services cannot be consolidated because their agency is unique. While it may make us feel better to say we are unique, the truth is most agencies are not. The plethora of different rules, processes and systems is the result of choice rather than absolute necessity. Although agencies tend to create their own operating policies and directives for HR services, those rules are usually created because they can be, not because of a compelling business argument. Not only that, attempts to consolidate HR/EEO services are typically met with fierce resistance. When the Department of Defense proposed consolidating HR services in the 1980s, one of the services responded with the objection that their civilian HR services were at the heart of their warfighting capabilities. When faced with that type of opposition, the proposal was dropped. Eventually, the DoD elected to “regionalize” its HR services in a way that protected most of the parochial interests that objected to the previous consolidation proposal. The result was a model that few DoD leaders and virtually no one in HR would consider to be effective or efficient.

When the Defense Logistics Agency proposed a real consolidation of HR services, Pentagon officials supported it as a means of seeing if consolidation could actually work. Studies of the DLA HR transformation have shown it was completely successful, reduced costs, and dramatically improved the quality of services. The proposed transformation was not universally accepted in DLA. In fact, many affected managers, field Commanders and Senior Executives were vehemently opposed. One SES referred to it as “the most brutal proposal I’ve ever seen.” Another said he would rather have bad service he controlled than good service someone else controlled. One General said it was doomed to failure and would generate no savings, even if it could be implemented, which he doubted. They were wrong. Not only did the consolidation work, it saved money and provided more resources for the consolidated offices to get their work done. Many of the savings came from elimination of redundant management structures. Rather than having seven HR offices, each with an HR Director, staff directors, and support teams for each, there were two HR offices. Rather than having seven sets of HR tools, we had one. Rather than having seven sets of operating procedures, we had one. DLA is not the only example of effective HR consolidation. Agencies as diverse as the Department of the Treasury, NASA, the Department of Commerce and the Department of the Interior have had similar successes. That kind of consolidation and cost reduction is not radical. It is not risky, and it is not new and different. It is a tried and proven approach to delivering services.

What was driving those objections, and what bold leaders in government will face today, is fear. Fear of loss of control. Fear of loss of influence. Fear of failure. Fear of services that are worse than before. Overcoming those fears is critical if government is going to transform itself today. If those fears drive debates about overhead services, imagine how people will respond when asked to do the same thing for mission services. How will any real consolidation of services, elimination of redundant missions and consolidation of agencies take place? We have proven in multiple agencies that support services can be effectively and efficiently consolidated, yet that knowledge has not been translated into government wide measures to dramatically transform support services. It is time to take that step.