# April 12, 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 MIT Action Item Number 84 (ED/OIG I13E0001)

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. The EIMS group is 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
(improve the strategic management of the Department's human capital). In
this report, we examined item number 84 (completed on July 30, 2002),
concerning the expansion of innovative recruitment strategies.

## 

## Background:

The action required by Action Item Number 84 was to:

Expand innovative strategies to recruit employees, including
notification in trade publications and state agencies

Human Resource Services (HRS) created a plan in June 2002 to address
this action item. The plan had four components: 1) increase and expand
the use of EdHIRES, the Department's web-based, automated hiring system;
2) use paid advertising in newspapers and trade publications; 3)
establish a pilot program that requires hiring at least one career
intern employee in the Office of Management (OM) and in three program
offices; and 4) survey State Employment and Labor offices to determine
feasibility of a working group to assist in recruitment. The OM Director
approved HRS's plan to expand recruitment of Department employees on
July 30, 2002. This action was the basis for the completion date
identified by the Department.

**Objective 1: Did OM complete the actions needed to complete this
item?**

While the Department did develop a plan that would have completed this
item, it has not fully implemented that plan.

The Department introduced EdHIRES on December 7, 2001 to decrease the
amount of time and resources needed to fill positions. While EdHIRES
original implementation only allowed Department employees to apply for
jobs, in March 2003 this capability was expanded to all recruiting
sources; *an initial intent of the design*. As designed the system can
also be tailored to send recruitment announcements to an identified list
of "professional/occupational websites." This feature has not been
brought on line.

HRS budgeted in 2003 for a subscription to WashingtonJobs.com, an online
area job database run through the Washington Post. However, HRS never
obtained a subscription to or used this online service, even though this
service was noted in its approved plan. The team determined they "did
not need to spend the funds" because both EdHIRES and USAJobs, the
Office of Personnel Management's online recruitment source, are
available nationwide. After the draft of this report was issued, HRS
presented extra information showing that while WashingtonJobs.com was
never used, some Principal Offices within the Department have placed job
announcements in trade publications and online.

On July 10, 2000, the White House enacted Executive Order 13162, which
created the Federal Career Intern Program (CIP). This program was
designed to "help agencies recruit and attract exceptional individuals."
While HRS's plan to expand recruitment included establishing a pilot
program to hire at least one Career Intern in OM and three in other
areas of the Department, according to HRS, the CIP "has never been a
pilot" at the Department. Currently under this program, the Office of
the Chief Financial Officer (OCFO) is employing three interns, hired in
the Fall of 2002, and the Office of the Inspector General (OIG) recently
hired three others.

HRS planned to survey State Employment and Labor Offices located in the
same vicinity of Department Offices to determine the feasibility of
forming a working group to help in the Department's recruiting efforts.
To date, HRS has never surveyed any of these offices about forming a
consortium.

After being questioned on the frequency of usage of innovative
recruitment tools, HRS disclosed that it processed three recruitment
bonuses and two continuation of retention allowances in 2003. Managers
use some recruitment and retention tools more frequently, with superior
qualification appointments being the most widely used. Two of the
innovative initiatives, CIP and Student Loan Repayment, have been used
rarely. In 2002, the Department hired *three* employees under the CIP
and used the Student Loan Repayment option *twice*. OM has not looked
into the reasons behind this lack of use.

The plan put forward by HRS and cited as the basis for listing this
action item as "completed" has itself never been implemented. The
Department has not fully utilized all EdHIRES capabilities, encouraged
the use of the CIP and Student Loan Repayment strategies or surveyed
State Employment and Labor Offices.

**Objective 2: As completed, do the actions taken help the Department
towards its stated Blueprint Objective?**

The Blueprint objective's intent was to expand the Department's
innovative strategies for recruitment and thereby help to improve the
strategic management of the Department's human capital. The action taken
does not help the Department towards this objective.

The plan, as outlined by HRS, has not been completed and there has been
no follow up to determine why the strategies offered are so rarely being
used. Absent implementation and an assessment of the plan's
effectiveness, there is no basis for concluding that the actions
identified as "completing" the action item will help move the Department
toward its underlying Blueprint objective.

# Departmental Response

We provided the MIT with a draft report that contained recommendations
that would, if implemented, support the MIT's decision to list the
action item as "completed." The MIT generally did not concur with these
recommendations and decided to "close" the item instead. "Closed"
indicates that the item is either no longer a priority for the
Department or has overtaken by events. Therefore, we have removed our
recommendations from the report. We have included the MIT' comments in
their entirety as an attachment.

# Administrative Matters

We appreciate the cooperation given to us during the inspection. If you
have any questions or wish to discuss the contents of this report,
please call me at 202‑205-8639 or Deb Schweikert, Director, Evaluations
and Inspections Division at 202‑205‑5569. Please refer to the control
number in all correspondence relating to this report.

**February 13, 2004**

**To:** Cathy H. Lewis

Assistant Inspector General

Evaluation, Inspection and Management Services

**From:** Phillip Maestri, Director

Management Improvement Team

**Subject:** Draft Inspection Memorandum (January 6, 2004)

Review of MIT Action Item Number 84 (ED/OIG I12E0001)

"Expand innovative strategies to recruit employees"

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 MIT reviewed Department activities
targeted to "expand innovative strategies to recruit employees,
including notification in trade publications and state agencies." As OIG
reports, the action was designated "completed" in July 2002 when the
Office of Management (OM) Director approved an HRS plan to address
recruitment issues.

Consistent with your findings, the MIT found that some components of
that plan were not implemented. The implementation of the plan was not
tracked by the MIT, first because the item was "completed" based on the
plan rather than the implementation, and second, because the MIT did not
track the implementation of offices' milestones or the component
activities identified at their discretion that comprise the plan. As a
result, the *Blueprint* was not updated to reflect deviations OM made
from its plan as it moved forward with implementation. Specifically:

-   One potential feature of ED Hires---to send recruitment
    announcements to identified websites---has not been used.

-   One potential avenue of paid advertising -- a subscription to
    WashingtonJobs.com -- was not used.

-   CIP was directly implemented, instead of begun by a pilot project in
    targeted offices.

-   Recruitment partnerships with State Employment and Labor offices
    were not pursued.

Other components of the plan were completed, including:

-   EDHires was expanded to serve all recruiting sources.

-   Offices used paid advertising for recruitment. OM has examples of
    this advertising and reports that, in the last year, Principal
    Offices placed paid advertisements with Attorneyjobs.com,
    Hotjobs.com, Law.com, Monster.com, Global Media Group, New York Law
    Journal, New York Times, San Francisco Chronicle, San Francisco
    Examiner, San Francisco Recorder, and Washington Post. The principal
    offices have more information on where they advertise.

-   CIP was implemented at ED and interns hired (6 since the inception;
    HRS reports that 5 other selections have been made and the
    candidates are awaiting security clearances). The Personnel Manual
    Instruction (PMI) on CIP was posted in March 2003 and is available
    to managers at <http://wdcrobiis08/doc_img/pmi_302-2p1.doc>

-   Information on all recruitment and retention tools, including the
    innovative ones, is advertised on ConnectED at
    [connected.ed.gov/index.cfm?articleobjectid=369AA60A-0D99-4360-BADC354F80568A8B](../connected.ed.gov/index.cfm%3Farticleobjectid=369AA60A-0D99-4360-BADC354F80568A8B)\
    and full descriptions are available at
    <http://wdcrobiis08/doc_img/recruit.doc>

The MIT concludes that these activities, in all probability, "helped the
Department towards" the *Blueprint* objective. We therefore think the
OIG conclusion that "the action taken does not help" is an
overgeneralization of the results. The MIT recognizes that there has not
been a formal assessment of the plan's effectiveness (that is, an
evaluation of the impact of the activities). OM has some data that
suggests each vacancy announcement draws a number of candidates that are
qualified (between 3 and 8 depending on the occupational category).
However, we cannot ascertain from that data whether this is a sufficient
number of applicants to meet the need nor if the certified candidates
were as qualified as the managers would like. Absent more information,
it is not possible to make a statement on the degree to which the
objective has been achieved. Such rigorous assessment of the impact of
human resource activities was not built into the *Blueprint*.

It is important to note that responsibility for recruitment and other
personnel processes are shared. The *Blueprint* recognized this shared
responsibility. Action #84 was assigned to all senior officers as well
as OM (Action Owners), and to executive officers as well as the HR
Director (Responsible Individuals). Upon investigation, the MIT did not
find systematic information regarding the actions taken by these other
parties. Informal feedback suggests that front-line managers and
executive officers are often unaware of or do not understand the
recruitment options available. A full understanding of the issue and
well-informed plan of action needs to address the scope of
responsibility of HRS and strategies for engaging senior officers,
executive officers, and front-line managers in improving human resource
management.

A technical correction to OIG's description of the use of recruitment
strategies will make it more accurate. Superior qualification
appointments are not literally in the category "recruitment bonuses and
retention allowances." Therefore the 50-100 requests a year for
"recruitment bonuses and retention allowances" is not accurate because
most of these are requests for superior qualification appointments. OM's
most recent data on this are, in 2003, three recruitment bonuses were
paid, two continuation of retention allowances were paid, and 36
superior qualifications appointments were made.

The memo will be clearer if it only discusses the strategy investigated,
i.e., the CIP. Other recruitment tools were not components of the OM/HRS
plan that the OIG investigated. The MIT will need to do further research
if OIG needs information on other strategies.

### Developments since the completion 

In the 18 months since the OM plan was first approved, the system of
on-line job applications and job announcements has matured and grown.
EDHires allows both internal and external candidates to find and apply
for ED jobs on line. All ED vacancy announcements appear on "USAJobs"
(OPM's site). State employment agencies create seamless access to
national job postings through America's Job Bank (AJB). A MIT cursory
investigation suggests that the state job web sites link directly to
USAJobs or, at least, link directly to AJB, which links to USAJobs.
College and university job web sites also link to AJB and USAJobs.

HRS reports that senior HRS staff met with WashingtonJobs.com and
determined it was not cost effective to purchase the subscription, based
both on cost and duplication between this and other advertising sources.
The OIG memo does not make it clear that HRS followed up on this and
made a specific determination.

Subsequent to its initial planning, HRS determined that the state
employment working groups were not an effective strategy. First, the
need was limited. Regional office recruitment is low relative to ED-wide
need. As of January 2004, there were 11 recruitment actions in the
regions (underway at various stages of the process), compared to 172
headquarters recruitment actions underway. Second, it is not clear that
state employment offices are a good source of applicants. Third,
electronic distribution of information to state employment web sites
through the AJB/USAJobs links meets much of the need. Finally, HRS
reports that Regional HRS offices participate on the Federal Personnel
Council and the Federal Executive Board, which serve some of their
networking needs.

Finally, OM developed a survey to help identify barriers to using
special hiring and compensation flexibilities. The survey was
distributed January 29, 2004 to executive officers and selected senior
executives who OM identified as "key informants" with specific
experience with or insight into the use special hiring and compensation
tools. Responses were due to OM by February 6, 2004. OM will report its
findings to the EMT.

### Response to recommendations

The MIT concludes that the fundamental criteria in developing future
HR-relative activities must be the extent to which further activities
are needed and whether the benefits justify the costs. HRS dropped some
of the components of the original plan because, in the staff's judgment,
they were not cost-effective. The MIT suggests that new recommendations
address current needs and consider cost effectiveness.

Given experience with this and other hiring, recruitment, retention, and
performance appraisal related activities, much greater attention must be
paid to the limited role that HRS plays and how to engage those on the
front lines. Supervisors, senior executives, and executive officers are
not cohesive groups accountable to one individual. But they clearly must
take on responsibility to forward this agenda.

**[Recommendation 1]{.underline}: *"Fully implement EDHires by
populating and using its notification lists."*** It might be
cost-effective to implement the automatic notification feature of
EDHires, if targeted institutions can be identified and logically linked
to the specific types of job announcements. This will require further
investigation.

**[Recommendation 2]{.underline}: *"Publish job announcements in trade
publications and newspapers." ***It appears offices already publish
announcements in trade publications and web sites. If there is evidence
that this resource is underutilized, the response should take into
account that executive offices and front-line supervisors, rather than
OM, may be the ones to address this.

**[Recommendation 3]{.underline}*: "Create a well-publicized CIP that
follows the initial requirements and effectively recruits
individuals."*** The CIP program was established. The information is
available on ConnectED. Note that supervisors are responsible for
identifying vacancies to fill using CIP and for ensuring it is a good
developmental experience for the interns. (See PMI 302-2) Determining
whether the program is underutilized and whether it is effective
requires further investigation. The MIT suggests that this
recommendation focus on evaluating CIP. Further program implementation
should be guided by those findings. The HRS director is responsible for
evaluating the overall effectiveness of the CIP (PMI 302-2). The HRS
survey of executive officers and managers asks why they do not used CIP
and other recruitment authorities. Using the survey results, OM/HRS will
report to the EMT on recruitment and hiring strategies.

**[Recommendation 4]{.underline}: *"Survey local State Employment and
Labor Offices about the feasibility of forming a working group."***
Given the limited recruitment at regional office and the posting of ED
vacancies announcements at state labor department web sites, this
activity has probably been rendered obsolete.

**[Recommendation 5]{.underline}: *"Work with Executive Officers to
identify why recruitment/ retention tools are not being used. Develop a
plan for encouraging greater use and share that plan with the EMT."***
The MIT suggests that this recommendation focus on assessing whether
further use is needed, rather than increasing the use of the
flexibilities. Given the scope of HRS' responsibility and authority,
executive officers and senior officers must take an active role in
recruitment and retention. HRS' January survey of executive officers and
selected managers addresses recruitment and retention tools. OM/HRS will
report to the EMT on the results of that survey.

**[Recommendation 6]{.underline}: *"Within one year, survey executive
offices to assess the effectiveness of that plan."*** OM has existing
forums to communicate with executive offices. The MIT request that this
recommendation be sufficiently flexible to allow OM to find the best
method to do such follow up, which might not be a formal survey. As with
recommendation #5, the MIT also suggests consideration be given to the
responsibility of the executive officers for carrying this out.

**[Recommendation 7]{.underline}: *"Designate Action Item Number 84 as
'open.'"*** The MIT concurs that this action item was not completed as
originally planned. As a result, the MIT will record action item #84 as
"closed" rather than "completed" and will provide more details regarding
the specific activities associated with this item in the comments
section of the *Blueprint*.