# March 22, 2004

# INSPECTION MEMORANDUM

To: Phil Maestri

Director, Management Improvement Team

Office of Deputy Secretary

From: Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection and Management Services

Subject: Review of Blueprint for Management Excellence item number 172
(ED/OIG I13E0008)

This memorandum provides the results of our inspection of one Action
Plan item from the Department of Education's (Department's) Blueprint
for Management Excellence. We are examining several Action Plan items
related to Human Capital. Our objective is two-fold: 1) was the item
completed as described; and, 2) as completed, does the action taken help
the Department towards its stated Blueprint objective. In this report,
we examined Action Item Number 172 concerning the annual review of
position descriptions by rating officials.

Background:

Each Department employee is assigned to a position description (PD).
Given the Department's revised performance evaluation system and its
emphasis on accountability, it is important that position descriptions
provide an accurate statement of the employee's job, including all
current responsibilities.

With this in mind, the MIT developed an Action Item to require a yearly
review of position descriptions. Specifically, Action Item Number 172
requires each Assistant Secretary to:

"**Establish a process to ensure that rating officials annually review
PDs of their staff to ensure the PD accurately covers all of the
employees duties and responsibilities."**

The comments field on this item states, "Completed 6/18/02. This item
was addressed through the One-ED report."

**Objective 1: Was the action item completed as described?**

The One-ED Report does not establish a process, or direct Assistant
Secretaries to establish a process, to monitor position descriptions on
an annual basis.

The annual position description review is a line management
responsibility, to be carried out by the rating officials in each
principal office. The designated action owner is each Assistant
Secretary. According to the MIT, this Blueprint item was addressed
through the One-ED Report. The One-ED report makes no mention of this
requirement. Although this is not reflected in the MIT report on this
action item, it has been suggested that the item was closed because the
One-ED Strategic Investment Process (SIP) includes a review of position
descriptions. We found no evidence that such a review was done as part
of Phase I of the One-ED process to ensure that employee's duties and
responsibilities were accurately reflected in their PD. The MIT
acknowledged that position descriptions were not reviewed as a part of
the Strategic Investment Process, and updates that may result from
future implementation of One-ED reengineer solutions will not result in
annual updates of every employee's position description. Furthermore,
HRS stated that there is no policy that directly requires supervisors to
update position descriptions.

As part of our inspection activities, we surveyed the Department's
executive officers to determine if they were aware of this requirement.
None of the executive officers were aware of any current initiative to
ensure that an annual review of employee position descriptions took
place.

**Objective 2: Did the actions completed meet the objective "To improve
the strategic management of the Department's human capital?"**

This action item was not completed.

**Recommendations:**

The EMT should either designate this item as "closed" if it feels it is
not required any longer or, if the EMT believes this item is still
necessary, the Action Item Number 172 should be re-designated as "open"
and a process identified to ensure the action is initiated and completed
on an annual basis.

**Department Response:**

The MIT concurs that this action item was not completed as intended. As
a result, the MIT will record Action Item Number 172 as "closed" rather
than "completed" and will note the change in the comments section of the
*Blueprint* action item.

We have not modified our recommendation based on the Department's
response.

We appreciate the cooperation given to us during the inspection.

March 10, 2004

To: Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection and Management Services

From: Phillip Maestri, Director

Management Improvement Team

Subject: Draft Inspection Memorandum (1/6/04)

Review of MIT Action Item Number 172 (ED/OIG I13E0007)

"Process for rating officials (to) annually review position
descriptions"

Thank you for the opportunity to review and comment on a draft version
of this inspection memorandum.

### Comments on Background and Findings

In response to your draft memo, the Management Improvement Team (MIT)
reviewed the activities associated with the review of position
descriptions. As OIG found, the MIT recorded blueprint action item #172
as "completed" based on the completion of the One-ED report. The report
contained a plan for a Strategic Investment Process that, through
re-engineering business processes, would change the work individuals
perform. With the implementation of re-engineered work processes, any
changes in duties will need to be reflected in updated position
descriptions. However, the MIT acknowledges that the implementation of
One-ED has not always been accomplished as originally envisioned and
position descriptions were not reviewed during the Strategic Investment
Process. Furthermore, updates to position descriptions that may result
from future implementation of One-ED reengineered solutions will not
result in ***annual*** updates of ***every*** employee's position
description because One-ED reviews occur periodically and affect only a
fraction of employees.

In response to the OIG findings, the MIT asked the Human Resource
Service (HRS) to advise us on the current situation. HRS advises that
there is no policy that directly requires supervisors to update position
descriptions. However, managers are responsible for ensuring the
accuracy of position descriptions. This requirement is referenced in
Personnel Manual Instruction 511-1 (Employee Position Classification
Appeals), which provides:

-   Assignment of duties and responsibilities as documented in official
    position descriptions is a management responsibility. (Paragraph IV)

-   Ultimately, the supervisor has the final authority to determine the
    duties and responsibilities to be reflected in the position
    description, and to explain the basis for the classification of the
    position to the employee. (Paragraph V-B)

5 CFR 511.607(a)(1) states:

-   When the accuracy of the official position description is questioned
    by the employee, the employee will be directed to review this matter
    with his or her supervisor.

Furthermore, HRS advises that, in the staff's judgment, a yearly review
of position descriptions is not necessary for three reasons. First,
Principal Offices reorganize frequently. In the year 2003, there were 25
reorganizations. A key step in the reorganization process requires
management to review position descriptions of employees affected by the
reorganization. If employees' position descriptions do not accurately
describe the duties and responsibilities to be performed in the new
organization, management *must* submit new position descriptions.
Second, supervisors assign the vast majority of employees to standard,
generic position descriptions. These descriptions are written in broad
terms and cover the major, grade-controlling aspects of positions in the
occupational series. Third, the EDPAS performance appraisal system
requires managers to develop standards with employees. If the position
description is inaccurate, that fact should be apparent when the manager
and employee develop the standards for assessing the employee's
performance.

### 

### Response to recommendations

The MIT concurs that this action item was not completed as intended. As
a result, the MIT will record action item #172 as "closed" rather than
"completed" and will note the change in the comments section of the
*Blueprint* action item.