FEDERAL PAY

Opportunities Exist to 

Enhance Strategic 

Use of Special 

Payments

Report to the Committee on Oversight 

and Government Reform, House of 

Representatives

December 2017

GAO-18-91

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-91, a report to the 

Committee on Oversight and Government 

Reform, House of Representatives

December 2017

FEDERAL PAY

Opportunities Exist to Enhance Strategic Use of

Special Payments

What GAO Found

Generally, federal agencies have seven broadly available government-wide 

special payment authorities to help address recruitment and retention 

challenges. Chief Human Capital Officer (CHCO) Council agencies reported 

using these authorities to varying degrees but overall for few employees in fiscal 

years 2014-2016. For example, in fiscal year 2016, less than 6 percent of the 

over 2 million CHCO agencies’ employees received compensation from at least 

one of the authorities (see figure). The two most frequently used—special rates 

and retention incentives—were used for over 74,000 employees and over 13,000

employees, respectively, each year. The least-used—critical position pay—was 

used for as few as seven employees a year. CHCO agencies also reported using 

the range of authorities to help address skills gaps, particularly for science, 

technology, engineering, and mathematics occupations. 

CHCO Agency Employees Receiving Special Payments, Fiscal Year 2016 

CHCO agencies reported that these authorities had positive impacts—such as 

on-staff retention and applicant quality—but had few documented effectiveness 

assessments. Nine of 10 agencies that reported having documented 

assessments provided them, but GAO found that only 3 had information on

effectiveness, such as its impact on meeting staffing needs.

The Office of Personnel Management (OPM) collects agency data on use but 

has not tracked data to analyze how much authorities help agencies improve 

recruitment and retention government-wide. OPM may be missing opportunities

to promote strategic use by providing guidance and tools on assessing 

effectiveness. For example, OPM has not explored reasons for trends in use of 

critical position pay or consistently shared best practices and innovative ways to 

use authorities. Without tracking data and providing guidance to help agencies 

assess effectiveness, OPM will be unable to determine whether use of special 

payment authorities helps agencies to improve recruitment and retention.

View GAO-18-91. For more information, 

contact Yvonne D. Jones at (202) 512-2717 or 

jonesy@gao.gov.

Why GAO Did This Study

Federal agencies can provide 

additional compensation by using 

seven broadly available special

payment authorities to recruit and 

retain employees to address needed 

skills. Though special payments can 

help fill mission-critical skills gaps, 

agencies also face constrained 

budgets, which underscores the 

importance of cost-effective use of 

authorities. OPM and the CHCO 

Council play important roles in 

assuring effective federal human 

capital management.

GAO was asked to examine agency 

use, challenges, and improvements 

needed, if any. This report 1) describes 

CHCO agencies’ use of special 

payment authorities in fiscal years 

2014-2016; 2) assesses to what extent 

CHCO agencies examined

effectiveness; and 3) evaluates how

OPM has helped agencies address 

recruitment and retention needs. GAO 

obtained information from CHCO 

agencies on use of authorities through 

a questionnaire. GAO also analyzed 

OPM personnel data and agency 

documents, and interviewed agency 

officials. 

What GAO Recommends

GAO is making three 

recommendations, including that OPM 

should work with the CHCO Council on 

tracking data and providing guidance 

and tools to assess effectiveness of 

authorities, among others. OPM 

concurred or partially concurred with all 

recommendations, and described 

planned steps to implement them.
Page i GAO-18-91 Federal Pay

Letter 1

Background 4

Agencies Reported Using Special Payment Authorities to Varying 

Degrees but for Few Employees in Fiscal Years 2014-2016 8

Agencies Generally Reported Positive Impacts but Few 

Documented Their Assessments of Special Payment 

Authorities 18

OPM Has Provided Some Guidance and Collects Some Data, but 

Has Not Assessed Effectiveness or Documented Approval 

Processes 26

Conclusions 38

Recommendations for Executive Action 39

Agency Comments and Our Evaluation 40

Appendix I Objectives, Scope, and Methodology 43

Appendix II Special Payment Authorities Questionnaire 

Sent to Chief Human Capital Officer Agencies 50

Appendix III CHCO Agencies Reported Use of Special Payment 

Authorities Affecting Selected Areas of Operation 55

Appendix IV Office of Personnel Management Data on Use 

of Special Payment Authorities by Occupational Family 58

Appendix V Comments from the Office of Personnel Management 60

Appendix VI GAO Contact and Staff Acknowledgements 63

Contents
Page ii GAO-18-91 Federal Pay

Tables

Table 1: Title 5 Special Payment Authorities Generally Available to 

Agencies 4

Table 2: Federal Employees at CHCO Agencies Who Received 

Compensation from Special Payment Authorities, Fiscal 

Years 2014-2016 11

Table 3: CHCO Agency Use of Special Payment Authorities by 

Skills Gap Area, Fiscal Years 2014-2016 16

Table 4: CHCO Agencies Reported Impacts of Special Rates 

Authority on Selected Areas, Fiscal Years 2014-2016 19

Table 5: CHCO Agencies Reported Assessing Special Payment 

Authorities, Fiscal Years 2014-2016 21

Table 6: Agencies Utilization of Available Critical Position Pay 

Authority Slots in Calendar Years (CY) 2012-2015 31

Table 7: Tools and Guidance on OPM’s Website for Title 5 Special 

Payment Authorities 35

Table 8: CHCO Agencies Reported Impacts of Superior 

Qualifications on Selected Areas, Fiscal Years 2014-2016 55

Table 9: CHCO Agencies Reported Impacts of Critical Position 

Pay on Selected Areas, Fiscal Years 2014-2016 55

Table 10: CHCO Agencies Reported Impacts of Recruitment 

Incentives on Selected Areas, Fiscal Years 2014-2016 56

Table 11: CHCO Agencies Reported Impacts of Retention 

Incentives on Selected Areas, Fiscal Years 2014-2016 56

Table 12: CHCO Agencies Reported Impacts of Relocation 

Incentives on Selected Areas, Fiscal Years 2014-2016 57

Table 13: CHCO Agencies Reported Impacts of Student Loan 

Repayment Authority on Selected Areas, Fiscal Years 

2014-2016 57

Table 14: Top Five Occupational Families with Most Frequent 

Government-wide Use for Selected Special Payment 

Authorities, Fiscal Year 2014 59

Figures

Figure 1: CHCO Agencies Used a Variety of Special Payment 

Authorities for Recruitment and Retention, Fiscal Years 

2014-2016 9

Figure 2: CHCO Agencies Used Special Payment Authorities for a 

Small Number of Their Employees, Fiscal Year 2016 10

Figure 3: CHCO Agency Reported Spending on Selected 

Payment Authorities, Fiscal Years 2014-2016 13
Page iii GAO-18-91 Federal Pay

Figure 4: Agencies Most Frequently Used the Student Loan 

Repayment Program for Attorneys, Engineers, and 

Contract Specialists, Calendar Year 2015 17

Figure 5: CHCO Agencies Reported Challenges with Using 

Special Payment Authorities, Fiscal Years 2014-2016 23

Figure 6: CHCO Agencies Reported Likelihoods of Changes That 

Would Improve Their Use of Special Payment Authorities 25
Page iv GAO-18-91 Federal Pay

Abbreviations

3R Recruitment, Relocation, and Retention

CDC Centers for Disease Control and Prevention

CHCO Chief Human Capital Officer

CY Calendar Year

DHS Department of Homeland Security

DOD Department of Defense

DOJ Department of Justice

DOT Department of Transportation

EHRI Enterprise Human Resources Integration

FASTs Federal Agencies Skills Teams

GS General Schedule

HHS Department of Health and Human Services

HR Human Resources

HRU Human Resources University

Interior Department of the Interior 

IRS Internal Revenue Service

IT Information Technology

MCO Mission-Critical Occupation

OMB Office of Management and Budget

OPM Office of Personnel Management

SEC Securities and Exchange Commission

State Department of State

STEM Science, Technology, Engineering, and Mathematics

TIGTA Treasury Inspector General for Tax Administration

Title 5 Title 5 of the United States Code

Treasury Department of the Treasury

USDA United States Department of Agriculture

VA Department of Veterans Affairs

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Page 1 GAO-18-91 Federal Pay

441 G St. N.W.

Washington, DC 20548

December 7, 2017 

The Honorable Trey Gowdy

Chairman

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

Federal agencies can provide additional payments to current employees 

and offer additional compensation to prospective employees in certain 

circumstances to support their recruitment and retention efforts, and 

address human capital challenges. These special payments can be 

strategic tools to help recruit and retain highly qualified personnel. 

However, balancing constrained budgets with a potential wave of 

employee retirements and the need to fill gaps in mission-critical skills 

within the federal workforce underscores the need for agencies to cost 

effectively use special payment authorities. These include special pay 

rates, incentives, and student loan repayments.1

The Office of Personnel Management (OPM) works with agency chief 

human capital officers (CHCOs) to provide human capital tools and 

guidance to support agency missions.2 Continued collaborative efforts 

between OPM and the CHCO Council assist agencies in using 

compensation flexibilities to address human capital challenges.3 Our prior 

work has shown that increasing agencies’ awareness of available 

flexibilities and evaluating existing tools are key aspects for successfully 

managing the range of human capital flexibilities.4 Moreover, we have 

1

We use the term “special payment authorities” in this report to refer to certain 

compensation flexibilities available government-wide to federal agencies through Title 5 of 

the United States Code to recruit, retain, or both recruit and retain needed employees. 

Table 1 provides descriptions of the seven authorities that are included in this report.

2

For example, GAO, Human Capital: Strategies to Help Agencies Meet Their Missions in 

an Era of Highly Constrained Resources, GAO-14-168 (Washington, D.C.: May 7, 2014); 

and Human Capital: OPM Can Better Assist Agencies in Using Personnel Flexibilities, 

GAO-03-428 (Washington, D.C.: May 9, 2003).

3

The CHCO Council includes the CHCOs of the executive departments and serves to 

coordinate and collaborate on the development and implementation of federal human 

capital policies.

4

GAO, Human Capital: Effective Use of Flexibilities Can Assist Agencies in Managing 

Their Workforces, GAO-03-2 (Washington, D.C.: Dec. 6, 2002). 

Letter
Page 2 GAO-18-91 Federal Pay

reported that building agency capacity in using human capital flexibilities 

increases the likelihood of agencies using these tools appropriately and 

cost effectively to address human capital challenges.5

You asked us to examine how much agencies use various available 

special payment authorities, challenges agencies face, and improvements 

needed to better ensure that agencies use these authorities to more 

effectively recruit and retain employees. This report (1) describes what is 

known about how much CHCO Council agencies used selected special 

payment authorities in fiscal years 2014-2016; (2) assesses the extent to 

which CHCO agencies evaluate the effectiveness of these authorities and 

identifies challenges, if any, the agencies reported facing in using the 

authorities to address mission-critical skills gap areas; and (3) evaluates 

how OPM has helped agencies address federal recruitment and retention 

needs.

To address our first objective, we administered a questionnaire to the 27 

CHCO agencies to collect data on frequency of use, dollars spent, and 

whether agencies used the authorities to help address recruitment and 

retention needs in mission-critical skills gap areas in fiscal years 2014-

2016.6 All 26 CHCO agencies that reported use of the authorities 

responded to our questionnaire.7 We also analyzed OPM’s Enterprise 

Human Resources Integration (EHRI) personnel data for fiscal year 2014 

to describe the use of authorities by occupational family, and for fiscal 

year 2016 to determine the total number of federal employees at the 

CHCO agencies.

In addition, we analyzed OPM reports on the student loan repayment and 

the critical position pay authorities to describe government-wide use by 

occupation in calendar year 2015—the most recent available reports at 

the time of our review. To assess the reliability of the CHCO agency 

reported data and the OPM EHRI data, we compared frequencies in the 

two data sets by agency for fiscal year 2014 (the one year of available 

 5

GAO, Federal Workforce: Sustained Attention to Human Capital Leading Practices Can 

Help Improve Agency Performance, GAO-17-627T (Washington, D.C.: May, 18, 2017).

6

We use the term “CHCO agencies” to refer to member agencies of the CHCO Council. 

We did not independently verify the spending amounts agencies reported. 

7

The Office of the Director of National Intelligence told us that it has its own personnel 

system and does not use the Title 5 pay authorities included in the scope of our review. 50 

U.S.C. § 3024.
Page 3 GAO-18-91 Federal Pay

overlapping data); reviewed OPM documentation; and interviewed OPM 

officials. We determined that the data were sufficiently reliable to describe 

agency use of these authorities over this time period.

To address our second objective, we analyzed CHCO agency responses 

from our questionnaire on the extent to which these agencies assessed 

the effectiveness of using these authorities, agency-reported challenges 

in using these authorities, and potential changes to operations or 

procedures to help agencies more effectively use these authorities.

To address our third objective, we reviewed OPM procedures to collect 

and analyze data, and provide tools and guidance on the effective use of 

special payment authorities. We also reviewed the processes OPM uses 

to review and approve agencies’ requests to use certain special payment 

authorities.8 We also interviewed OPM officials to discuss the review and 

approval processes and procedures. We compared the data collection, 

analysis, guidance, and approval processes for consistency and to 

determine whether they meet criteria for designing and implementing 

control activities in Standards for Internal Control in the Federal 

Government.9 See appendix I for a more detailed discussion of our 

objectives, scope, and methodology, and appendix II for a copy of our 

questionnaire.

We conducted this performance audit from September 2016 to December 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 8

These special pay authorities include: special rates; critical position pay; and recruitment, 

retention, and relocation incentives that exceed certain payment thresholds.

9

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014).
Page 4 GAO-18-91 Federal Pay

Generally, federal agencies have seven broadly applicable special 

payment authorities available government-wide under Title 5 of the United 

States Code (hereinafter “Title 5”)—listed below in table 1—for 

recruitment and retention.10 Table 1 describes each authority’s legal 

reference, purpose, payment ranges, and whether an agency must seek 

OPM approval prior to use.

Table 1: Title 5 Special Payment Authorities Generally Available to Agencies

Authority Description Payment ranges Approval authority

Special Rates

(5 U.S.C § 5305; 5 

C.F.R. part 530, subpart 

C.)

An agency may request OPM establish a higher 

rate of basic pay for an occupation or group of 

occupations in one or more geographic areas to 

address existing or likely significant handicaps in 

recruiting and retaining employees.

Minimum rate established 

may not exceed the 

maximum rate of basic pay 

for the rate range by more 

than 30 percent.a No rate 

may exceed Executive 

Schedule – Level IV 

($161,900 in 2017).

OPM.

Recruitment Incentives

(5 U.S.C. § 5753; 5 

C.F.R. part 575, subpart 

A)

May be paid to a newly-appointed employee if the 

agency determines that the position is likely to be 

difficult to fill in the absence of such incentive.

Not to exceed 100 percent 

of the employee’s annual 

rate of basic pay.b

Agency, up to 25 percent 

of the employee’s 

beginning annual rate of 

basic pay.c

OPM, up to 50 percent.d

Relocation Incentives

(5 U.S.C. § 5753; 5 

C.F.R. part 575, subpart 

B)

May be paid to a current employee who must 

relocate to accept a position in a different 

geographic area if the agency determines that the 

position is likely to be difficult to fill in the absence 

of such incentive.

Not to exceed 100 percent 

of the employee’s annual 

rate of basic pay.b

Agency, up to 25 percent 

of the employee’s 

beginning annual rate of 

basic pay.c

OPM, up to 50 percent.d

Retention Incentives

(5 U.S.C. § 5754; 5 

C.F.R. part 575, subpart 

C)

May be paid to a current employee (or group or 

category of employees) if the agency determines 

that the unusually high or unique qualifications of 

the employee or a special need of the agency for 

the employee’s services makes it essential to 

retain the employee and the employee is likely to 

leave federal service in the absence of such 

incentive.e

Not to exceed 50 percent 

of the employee’s rate of 

basic pay.

Agency, up to 25 percent 

of the employee’s rate of 

basic pay (10 percent for a 

group or category of 

employees).

OPM, up to 50 percent.

 10There are a number of other compensation flexibilities available to federal agencies, 

including those whose application is limited to senior executives, health care 

professionals, and employees serving in combat zones, among others.

Background

Title 5 Special Payment 

Authorities
Page 5 GAO-18-91 Federal Pay

Authority Description Payment ranges Approval authority

Superior Qualifications 

and Special Needs Pay 

Setting

(5 U.S.C. § 5333; 5 

C.F.R. § 531.212)

An agency may set the rate of basic pay of a 

newly-appointed employee at a rate above the 

minimum rate of the appropriate General 

Schedule (GS) grade because of:

• the superior qualifications of the candidate, or

• a special need of the agency for the 

candidate’s services.

Rate of basic pay set 

above the minimum rate of 

the appropriate GS grade.

Agency.

Student Loan 

Repayments

(5 U.S.C. § 5379; 5 

C.F.R. part 537)

An agency may make student loan repayments on 

behalf of an eligible employee who signs a service 

agreement for not less than 3 years with the 

agency in order to recruit or retain highly qualified 

personnel. 

Payments may be made to 

the loan holder of up to a 

maximum of $10,000 for 

an employee in a calendar 

year, and a total of not 

more than $60,000 per 

employee.

Agency.

Critical Position Pay

(5 U.S.C § 5377; 5 

C.F.R. part 535)

Permits an agency to set a higher rate of basic 

pay than would otherwise be payable for a 

position that requires expertise of an extremely 

high level in a scientific, technical, professional, or 

administrative field and is critical to the successful 

accomplishment of an important mission.

Not to exceed Executive 

Schedule–Level If

($207,800 in 2017).

OPM, in consultation with 

the Office of Management 

and Budget (OMB).

Source: GAO analysis of the U.S. Code of Federal Regulations and OPM documentation. | GAO-18-91.

a

Excluding any locality rate, other special rate, or similar payment under other authority.

b

The employee’s annual rate of basic pay at the beginning of the service period.

c

Multiplied by the number of years in the service period (not to exceed 4 years).

d

Multiplied by the number of years in the service period (up to 100 percent of basic pay).

e

Retention incentives may also be paid if the agency determines that it has a special need for the 

employee’s services (given agency mission requirements and employee’s competencies) that makes 

it essential to retain the employee during a period of time before the closure or relocation of the 

employee’s organization—and the employee is likely to leave for a different position in the federal 

service in the absence of such incentive.

f

In rare circumstances, a rate in excess of the rate for level I of the Executive Schedule may be 

approved by the President.

Federal agencies face mission-critical skills gaps that pose a risk to 

agencies’ ability to cost effectively serve the public and achieve results. 

Agencies can have skills gaps for different reasons. For example, skills 

gaps may arise in the form of: (1) staffing gaps, in which an agency has 

an insufficient number of individuals to complete its work; (2) competency 

gaps, in which an agency has individuals without the appropriate skills, 

abilities, or behaviors to successfully perform the work; or (3) both staffing 

and competency gaps. Mission-critical skills gaps may be broad—

affecting several agencies—or may be specific to a given agency.

We, and others including OPM and federal agencies, have identified and 

reported on mission-critical skills gap areas across the government and 

within specific agencies. In 2015, OPM and the CHCO Council worked 

Mission-Critical Skills
Page 6 GAO-18-91 Federal Pay

with agencies to refine their inventory of government-wide and agencyspecific skills gaps. They identified 6 government-wide and 48 agencyspecific mission-critical skills gap areas for closure. The six governmentwide areas identified were Cybersecurity; Acquisition; Human Resources; 

Auditing; Economics; and Science, Technology, Engineering, and 

Mathematics (STEM). Some of the agency-specific skills gaps included 

border patrol agents at the Department of Homeland Security and nurses 

at the Veterans Health Administration and the Department of Health and 

Human Services. Skills gaps played a contributing role in 15 of the 34 

high-risk areas identified in our most recent report on government 

operations with greater vulnerabilities to fraud, waste, abuse, and 

mismanagement, or that are in need of transformation to address 

economy, efficiency, or effectiveness challenges.11

OPM is responsible for performing a number of functions to assist 

agencies in using the compensation flexibilities, including issuing 

regulations and, as necessary, providing approval authority, to ultimately 

help agencies build successful, high-performance organizations. OPM 

provides agencies with guidance and assistance on using special 

payment authorities via individual consults, memorandums, its website, 

training, and initiatives that focus on specific issues. OPM’s website has 

guidance on each special payment authority including references to 

regulations.

For special payment authorities requiring OPM approval, OPM 

regulations provide agencies instruction concerning the information 

needed for OPM to review and decide whether to approve or deny 

requests.12 Although the information needs vary by authority, generally 

agencies are to submit information and evidence reflecting recruitment 

and retention challenges for the specific position(s), previous efforts to 

address the problem, and the basis for requested payment amounts.

OPM is responsible for oversight of the federal government’s use of 

special payment authorities to ensure agencies are acting in accordance 

 11GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts 

Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 15, 2017). 

12As identified in table 1, OPM approves use of special rates; recruitment, retention, and 

relocation incentives greater than 25 percent of the employee’s rate of basic pay (for 

retention incentives, greater than 10 percent for a group or category of employees); and 

critical position pay.

Office of Personnel 

Management
Page 7 GAO-18-91 Federal Pay

with applicable requirements.13 For example, as a part of its delegated 

examination audits and human resource management evaluations, OPM 

reviews selected samples of agency’s personnel actions to assess how 

well they complied with statutory and regulatory requirements. In cases 

where agencies used certain special payment authorities, OPM uses a 

checklist to guide its review of documents agencies must develop and 

maintain to justify their uses.

OPM also is responsible for reporting to Congress on the federal 

government’s use of certain special payment authorities. Annually, OPM 

requests or receives data from agencies and reports to Congress on 

agency use of two authorities—critical position pay and the student loan 

repayment. The reports include information on the use of these 

authorities each calendar year—such as data showing how many 

received payments—and the total dollar or relative amounts of special 

payments. OPM was required to annually report to Congress on 

agencies’ use of the recruitment, relocation, and retention (3R) incentives 

in calendar years 2005-2009.14

The Chief Human Capital Officers Act of 2002 established the CHCO 

Council to advise and coordinate the activities of member agencies on 

such matters as the modernization of human resources systems, 

improved quality of human resources information, and legislation affecting 

human resources operations and organizations.15 The Director of OPM is 

the Chairperson of the CHCO Council, and the Deputy Director for 

Management in OMB is the Vice Chairperson. The council includes 

CHCOs of the executive departments and any other members designated 

by OPM.16 It serves to coordinate and collaborate on the development 

and implementation of federal human capital policies. For example, the 

 13OPM is responsible for enforcement of laws, rules, and regulations governing the civil 

service 5 U.S.C. § 1103(a)(5). See also 5 U.S.C. § 1104(b)(2) which requires OPM to 

establish and maintain oversight over activities conducted by agencies under authority 

delegated by OPM. 

14The Federal Workforce Flexibility Act of 2004 required OPM to annually report to 

Congress on how agencies used the recruitment, relocation, and retention incentives.

Pub. L. No. 108-411, § 101(c), 118 Stat. 2305, 2309 (Oct. 30, 2004). This requirement 

terminated after the first five years of reporting. 

15Pub. L. No. 107-296, title XIII, § 1303, 116 Stat. 2135, 2288-89 (Nov. 25, 2002). 

16There are 27 CHCO Council agency members. For a complete list of CHCO Council 

members, see the discussion of scope and methodology in appendix I.

Chief Human Capital 

Officers Council
Page 8 GAO-18-91 Federal Pay

CHCO Council manages the Human Resources University (HRU) 

website, which is a web-based platform to share knowledge, training, best 

practices, and resources across agencies.17

CHCO agencies used a range of special payment authorities to recruit 

and retain employees. Our analysis of CHCO agency data found that for 

six selected authorities, 20 or more agencies used each between fiscal 

years 2014-2016, as shown in figure 1. Seven agencies reported having 

used the critical position pay authority.

 17http://www.hru.gov. HRU is the federal government’s “one stop” human resources (HR) 

career development center. HRU is aimed at professionalizing the federal HR career field, 

and is designed to address competency and skills gaps within the HR community; identify 

and offer the best HR training across government; provide supervisors, managers, and 

executives with critical leadership competencies and HR technical knowledge; and 

establish a means for sharing resources across all agencies. 

Agencies Reported 

Using Special 

Payment Authorities 

to Varying Degrees 

but for Few 

Employees in Fiscal 

Years 2014-2016

Agencies Reported Using 

a Range of Special 

Payment Authorities
Page 9 GAO-18-91 Federal Pay

Figure 1: CHCO Agencies Used a Variety of Special Payment Authorities for Recruitment and Retention, Fiscal Years 2014-

2016

We found that CHCO agencies reported using the seven authorities for a 

small number of federal employees overall. For example, in fiscal year 

2016, less than 6 percent of the over 2 million federal employees at 

CHCO agencies received compensation under at least one of the seven 

special payment authorities, as shown in figure 2.18

 18In calculating the percentage, we used CHCO agency reported data for the numerator 

(about 120,000) and OPM EHRI data for the total number of federal employees at the 26 

CHCO agencies—as of September 30, 2016—for the denominator (over 2 million). Not all 

of the over 2 million employees are eligible for all of these special payments. For example, 

the superior qualifications and special needs pay-setting authority can only be used for 

General Schedule employees.

Agency Data Show, 

Overall, Few Employees 

Received Compensation 

from Special Payment 

Authorities
Page 10 GAO-18-91 Federal Pay

Figure 2: CHCO Agencies Used Special Payment Authorities for a Small Number of 

Their Employees, Fiscal Year 2016

Moreover, many agencies reported using most of these authorities for a 

limited number of employees each year. For example, of the 24 agencies 

that reported using superior qualifications and special needs pay 

setting—the authority reportedly used by the highest number of CHCO 

agencies—over half (13 agencies) reported using the authority for fewer 

than 100 employees per year. In addition, of the 23 agencies that 

reported using recruitment incentives in fiscal years 2014-2016, 11 

agencies reported using the authority for 10 or fewer employees per year.

As shown in table 2, agencies reported that more employees received 

compensation from the special rates authority, followed by use of 

retention incentives in fiscal years 2014-2016. Specifically, agencies 

reported using special rates for over 74,000 employees, of the over 2 
Page 11 GAO-18-91 Federal Pay

million CHCO agency employees, in each of these fiscal years.19 On the 

other end of the spectrum, agencies reported using the critical position 

pay authority for fewer than 40 employees in each of these years.

Table 2: Federal Employees at CHCO Agencies Who Received Compensation from 

Special Payment Authorities, Fiscal Years 2014-2016

Authority FY14 FY15 FY16

Special rates 74,452 76,298 77,696

Recruitment incentives 5,055 6,626 7,243

Relocation incentives 2,792 3,645 4,350

Retention incentives 13,488 13,729 13,598

Superior qualifications and 

special needs pay setting

6,109 8,011 9,010

Student loan repayment 5,110 7,441 7,860

Critical position pay 7 7 34

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

Note: Federal employees may receive compensation under more than one authority in a given fiscal 

year.

Special rates: Although CHCO agencies reported that more employees 

received special rates compensation than the other authorities in fiscal 

years 2014-2016, our analysis showed usage generally declined from 

between 2001- 2005, when over 139,000 employees received a special 

rate. An OPM official said that over time agencies have relied less on 

these special rates due to the introduction of locality pay.20 For example, 

in its 2005 annual review of special rates, OPM reported that 14 special 

rates schedules would be terminated because higher locality rates 

applied at all steps of each covered grade.21

 19The figures likely include some employees who received special rate payments under a 

non-Title 5 authority, such as under Title 38 authorities. Officials from some agencies said 

that their systems did not allow reporting data that excluded employees who received 

special rates payments under non-Title 5 authorities.

20Locality pay is an annual locality-based pay adjustment for GS employees designed to 

reduce the gap between federal and nonfederal pay in each locality to no more than 5 

percent. Locality pay may be extended to certain categories of non-GS employees by the 

President’s Pay Agent. 5 U.S.C. § 5304. Locality pay was created by the Federal 

Employees Pay Comparability Act of 1990. Pub. L. No. 101-509, title V, § 529, 104 Stat. 

1389 (Nov. 5, 1990). The first locality-based payments were provided in 1994.

21Office of Personnel Management, 2005 Annual Review of Special Rates, Memorandum 

for Heads of Executive Departments and Agencies (Washington, D.C.: Dec. 22, 2005). 
Page 12 GAO-18-91 Federal Pay

Critical position pay: We found that the critical position pay authority 

was used for the lowest number of employees of these authorities each 

year in fiscal years 2014-2016. The authority’s lower use relative to the 

other authorities is to be expected to some extent because of the 

government-wide cap of 800 positions for this authority.22

Our analysis of CHCO agency questionnaire responses found that these 

agencies reported spending about $805 million total on 3R incentives and 

the student loan repayment authorities in fiscal years 2014-2016.23 In 

addition, we found that these agencies reported spending more on 

retention incentives than on the other three authorities in each of these 

years, as shown in figure 3. Specifically, over 40 percent (about $333 

million) of this total reported spending was for retention incentives.

 22Under 5 U.S.C. 5377(f), OPM may not authorize the use of critical position pay authority 

to more than 800 positions government-wide at any one time, of which no more than 30 

authorizations may be for positions otherwise under Executive Schedule rates of pay.

Factors affecting level of use of critical position pay are addressed later in this report. 

23We did not ask agencies about spending for special rates, superior qualifications and 

special needs pay setting, or critical position pay because those authorities are changes to 

an employee’s base pay rather than separate payments as with the 3R incentives and 

student loan repayments. As noted, we did not independently verify the agency-reported 

data.

Agencies Reported 

Spending about $800 

Million on 3R Incentives 

and Student Loan 

Repayments
Page 13 GAO-18-91 Federal Pay

Figure 3: CHCO Agency Reported Spending on Selected Payment Authorities, Fiscal Years 2014-2016

In addition, the agency reported use of recruitment and relocation 

incentives increased in each year. Overall, recruitment and relocation 

incentives were about $174 million and $149 million, respectively, of the 

total approximately $805 million in reported spending between fiscal 

years 2014-2016. OPM officials stated that until recently agency spending 

on 3R incentives had been frozen, and many agencies had to limit their 

use of these incentives.24 Finally, agency reported use of the student loan 

 24In June 2011, OPM and OMB placed a limit on agencies’ spending on the 3Rs. OPM 

and OMB asked agencies to ensure that spending on the 3Rs during calendar years 2011 

and 2012 did not exceed calendar year 2010 levels. Office of Personnel Management and 

Office of Management and Budget, Guidance on Awards for Fiscal Years 2011 and 2012, 

Compensation Policy Memorandum 2011-10 (Washington, D.C.: June, 10, 2011). Further 

directives extended this spending limit for each year through November 2016, when OPM 

and OMB removed monetary caps for other awards that had been frozen at fiscal year 

2010 spending levels (i.e., group awards, referral bonuses, and suggestion/invention 

awards; 3R incentives; and quality step increases.) Office of Personnel Management and 

Office of Management and Budget, Guidance on Awards for Non-SES/SL/ST Employees 

for Fiscal Year 2017, Memorandum for Heads of Executive Departments and Agencies, 

M-17-07 (Washington, D.C.: Nov. 18, 2016). The factors affecting level of use of payment 

authorities is further addressed later in this report. 
Page 14 GAO-18-91 Federal Pay

repayment authority increased in each of these years and was 

approximately $148 million of the total approximately $805 in reported 

spending.

All 26 CHCO agencies reported using special payment authorities to 

support mission-critical skills gap areas in fiscal years 2014-2016.25 We 

found that the number of CHCO agencies that used each of these 

authorities varied by skills gap area, as shown in table 3. For example, we 

found that superior qualifications and special needs pay setting was the 

authority used by the largest number of CHCO agencies in two of the five 

skills gap areas—STEM and Cybersecurity. We also found that 19 or 

more agencies reported using at least one authority to support four skills 

gap areas—STEM, Cybersecurity, Acquisitions, and Human Resources.

Some CHCO agencies reported that certain skills gap areas were not 

mission critical for them. Specifically, 11 agencies reported that 

healthcare was not a skills gap area for them as compared to 2 or 3 

agencies each for the other skills gap areas.

STEM: Our analysis of the CHCO agency data found that, of the five 

skills gap areas, more agencies generally reported using the special 

payment authorities to support STEM occupations. Of the 21 agencies 

that reported using at least one authority to support the STEM area, we 

found that 18 agencies reported using the superior qualifications and 

special needs pay setting authority for these occupations in fiscal years 

2014-2016. The Department of Agriculture (USDA), for example, reported 

that this authority had been a valuable tool in recruiting for critical STEM 

positions from a small and highly competitive Ph.D. applicant pool. The 

Department of the Treasury (Treasury) reported using special payment 

authorities generally to match private-sector salaries or to help mitigate 

disparities between private- and public-sector compensation for STEM 

occupations.

 25We asked agencies about their use of special payment authorities to help address five 

skills gap areas that we had previously identified—acquisitions, cybersecurity, healthcare, 

STEM, and human resources—as well as agency-identified areas. 

Agencies Used the Range 

of Authorities to Address 

Skills Gaps

CHCO Agencies Reported 

Using Authorities to Help 

Address Different Skills Gaps, 

Particularly for STEM 

Occupations
Page 15 GAO-18-91 Federal Pay

Cybersecurity: Similarly, of the 21 agencies that reported using at least 

one authority to support the cybersecurity area, 16 reported using 

superior qualifications and special needs pay setting to support these 

positions in fiscal years 2014-2016, and 13 agencies reported using 

recruitment incentives. For example, the Small Business Administration 

reported that the superior qualifications and special needs pay setting 

authority has helped to attract top cybersecurity talent by narrowing the 

gap between public- and private-sector salaries.

Acquisitions: Of the 20 agencies that reported using at least one 

authority to support the acquisitions area, 14 agencies reported using the 

student loan repayment authority, and 13 agencies reported using the 

superior qualifications and special needs pay setting authority for these 

positions. For example, the Department of Education reported using 

student loan repayments to help retain acquisitions employees, and in 

one instance, had retained an expert in multiple functional areas of 

government contracting.
Page 16 GAO-18-91 Federal Pay

Table 3: CHCO Agency Use of Special Payment Authorities by Skills Gap Area, Fiscal Years 2014-2016

Authority STEM Cybersecurity Acquisitions

Human 

Resources Healthcarea

Special rates 16 12 6 1 7

Recruitment incentives 16 13 6 6 7

Relocation incentives 13 8 11 13 6

Retention incentives 13 9 6 10 9

Superior qualifications and 

special needs pay setting

18 16 13 9 8

Student loan repayment 15 9 14 10 7

Critical position pay 1 1 0 0 1

Number of agencies that 

reported using at least one 

authority to support the 

skills gap area

21 21 20 19 12

Source: GAO analysis CHCO agency questionnaire responses. | GAO-18-91

Note: STEM, cybersecurity, acquisitions, and human resources were among the government-wide 

skills gap areas identified by OPM and the CHCO Council.

a

Eleven CHCO agencies reported that healthcare was not a skills gap area for them, compared to 2 

or 3 agencies that did so for each of the other skills gap areas.

Other agency-identified skills gap areas: We also found that 20 of the 

26 CHCO agencies reported using special payment authorities to varying 

degrees to help address other or agency-specific skills gap areas. For 

example, Treasury reported using recruitment incentives for auditors, 

while the Department of Homeland Security (DHS) reported using 

multiple authorities, including the 3R incentives for law enforcement 

positions in fiscal years 2014-2016.

Our analysis of OPM’s Federal Student Loan Repayment Program 

Calendar Year 2015 Report on government-wide use found that agencies 

frequently used the student loan repayment authority for employees in 

mission-critical occupations (MCOs).26 Specifically, we found that for the 

five agencies that most frequently used student loan repayments that 

year—the Departments of Defense (DOD), Veterans Affairs (VA), Justice 

(DOJ), and State (State), and the Securities and Exchange Commission 

 26OPM’s Calendar Year 2015 Report was the most recent year available at the time of our 

analysis. Federal agencies are required under 5 U.S.C. § 5379(h) to report annually to 

OPM on their use of student loan repayments during the previous calendar and include 

additional agencies beyond the 26 CHCO agencies to whom we administered our 

questionnaire.

Agencies Frequently Used the 

Student Loan Repayment 

Authority to Support MissionCritical Occupations
Page 17 GAO-18-91 Federal Pay

(SEC)—over 50 percent of the employees at each agency who received 

these benefits were in agency-specific MCOs. For example, SEC 

reported to OPM that approximately 72 percent of its student loan 

repayments were made to employees in MCOs such as accountants, 

attorneys, and securities compliance examiners. We also found that other 

agencies used the authority for employees in MCOs. For example, the 

Department of the Interior (Interior) reported to OPM that using the 

authority has been helpful in filling MCOs such as petroleum engineers, 

geophysicists, and biologists.

Our analysis of OPM’s 2015 report also found that the 32 agencies that 

had used the authority that year did so for over 200 occupations. Overall, 

we found that agencies most frequently used student loan repayments for 

attorney-, engineer-, and contracting-related occupations, as shown in 

figure 4.

Figure 4: Agencies Most Frequently Used the Student Loan Repayment Program for Attorneys, Engineers, and Contract 

Specialists, Calendar Year 2015

a

Engineering, one of the STEM occupations, includes 18 engineering-related occupation series.
Page 18 GAO-18-91 Federal Pay

Our review of OPM’s report to Congress on critical position pay in 

calendar year 2015 found that, as of calendar year 2015, all four positions 

that received the critical position pay authority were for director or other 

senior executive positions.27 For example, the positions of Administrator 

of the Transportation Security Administration and the Director of the 

National Institutes of Health received compensation under this authority in 

calendar year 2015. Since OPM’s 2015 report, OPM officials told us that 

they had approved 68 additional positions for the critical position pay 

authority for certain Medical Center Director positions at VA. According to 

data provided by VA in response to our questionnaire, the agency 

reported using its recently approved authority in fiscal year 2016 for 27 of 

these positions.

CHCO agencies generally reported that special payment authorities 

positively affected areas of operation. More specifically, these agencies 

reported the authorities somewhat or very positively affected at least one 

of seven areas we identified in our questionnaire such as staff retention,

ability to meet staffing needs, or ability to fill mission-critical positions (see 

appendix III for the results for the other special payment authorities). For 

example, the 19 agencies that reported using the special rates authority 

said it had somewhat or very positively impacted their ability to meet their 

staffing needs, and 17 reported the same for staff retention and achieving 

their missions (see table 4).

 27OPM’s Calendar Year 2015 Report was the most recent year available at the time of our 

analysis. 

Agencies Limited Their Use of 

Critical Position Pay to a Few 

Senior Positions

Agencies Generally 

Reported Positive 

Impacts but Few 

Documented Their 

Assessments of 

Special Payment 

Authorities

Agencies Generally 

Reported Positive Impacts
Page 19 GAO-18-91 Federal Pay

Table 4: CHCO Agencies Reported Impacts of Special Rates Authority on Selected Areas, Fiscal Years 2014-2016

Agency area of operation

Number of agencies reporting impact of use of special rates (N=19)

Somewhat or very positively No effect Somewhat or very negatively

Staff retention 17 2 0

Applicant quality 16 3 0

Ability to meet staffing needs 19 0 0

Ability to fill mission critical 

positions

16 3 0

Continuity of operations 14 5 0

Staff morale 14 4 1

Ability to achieve agency 

mission

17 2 0

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

Note: One agency used this authority but did not report on impacts. We provided agencies an option 

to specify other impact areas not listed. One agency specified “addressing time to hire,” which is not 

included in our table.

CHCO agencies generally reported that special payment authorities 

somewhat or very positively affected their ability to fill mission critical 

positions. Agencies provided specific examples of the positive impact of 

special payment authorities and ways they responded to challenges using

special payment authorities:

• Student loan repayment authority: The Department of Commerce 

reported that multiple components found this authority useful for 

competing with the private sector and for building a pipeline of top 

talent given that most of these employees were at the beginning of 

their careers.

• Relocation incentives: The Department of Energy reported using 

these incentives to relocate employees to meet emergency needs, 

including a shutdown of the Waste Isolation Plant Project in Carlsbad, 

New Mexico.

• Recruitment incentives: DOD reported that it would not have been 

able to effectively recruit individuals in several career fields, including 

engineering and nursing, without these incentives. Moreover, the 

Social Security Administration credited these incentives for its 

success in hiring experts from major corporations for cybersecurity 

and other program policy area positions.

• Retention incentives: The Environmental Protection Agency credited 

a retention incentive for successfully retaining a senior research 

scientist, thereby addressing a mission-critical skills gap and allowing 
Page 20 GAO-18-91 Federal Pay

the agency’s mission to continue uninterrupted and at significant 

savings. Moreover, State explained how using a retention incentive 

helped to address its Bureau of Medical Services’ severe staffing 

shortages due to uncompetitive base salaries. VA also stated that 

these incentives helped create a smooth transition of institutional 

knowledge to newer employees and facilitate continuity of operations. 

DHS responded to its need to attract and retain employees in 

information technology (IT) and cybersecurity by developing a unique 

retention incentive plan that focused on specialized certification for 

employees in these fields. The Department of Health and Human 

Services’ (HHS) Centers for Disease Control and Prevention (CDC) 

used retention incentives to retain employees that might have moved 

to the private sector.

• Superior qualifications and special needs pay: HHS’s CDC 

reported it has been successfully using this authority to attract IT 

specialists, an occupation series designated as “hard-to-fill.” HHS 

credited this authority with attracting highly qualified applicants who 

would otherwise have accepted higher starting salaries outside the 

federal government. USDA included use of this authority in its 

approach to addressing challenges recruiting and retaining employees 

in the remote oil boom Bakken region in North Dakota and Montana.

Twenty-five of 26 CHCO agencies reported assessing the effectiveness 

of at least one special payment authority used in fiscal years 2014-2016. 

However, our analysis found in many cases agencies did not document 

their assessments. Moreover, agencies often did not assess the 

effectiveness of all authorities they used. For example,

• 4 agencies reported having no assessments for the majority of the 

special payment authorities they used, and

• 11 agencies reported not assessing at least one of the authorities they 

used.

As seen in table 5, overall, CHCO agencies reported conducting informal 

effectiveness assessments more often than documenting assessments of 

their uses of special payment authorities.

Most Agencies Reported 

Assessing Special 

Payment Authorities, but 

Few Agencies 

Documented Their 

Effectiveness 

Assessments
Page 21 GAO-18-91 Federal Pay

Table 5: CHCO Agencies Reported Assessing Special Payment Authorities, Fiscal Years 2014-2016

Special payment 

authority

Informal

assessment

Documented 

assessment

No

assessment 

Total agencies that 

used the authoritya

Special Rates 14 4 3 20

Recruitment 

Incentives

19 7 3 23

Retention Incentives 15 4 5 21

Relocation Incentives 17 4 4 21

Superior Qualifications 

and Special Needs 

Pay Setting

18 3 6 24

Student Loan 

Repayment 

16 5 3 21

Critical Position Pay 2 1 3 7

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

a

The sum of informal, documented and no assessment does not equal the total number of agencies 

that used the authority because some agencies reported conducting both informal and documented 

assessments for certain special payment authorities, and, in one instance, an agency did not report 

this information.

Our analysis of CHCO agency responses found the extent to which these 

agencies documented assessments of effectiveness varied by payment 

authority. For example, agencies reported most frequently documenting 

assessments for recruitment incentives and the student loan repayment 

authority. On the other hand, 3 of the 24 agencies using the superior 

qualifications and special needs pay setting authority reported 

documented assessments. For each of the authorities, a small number of 

agencies reported not assessing effectiveness at all. For instance, 5 of 

the 21 agencies using retention incentives did not assess their 

effectiveness. OPM said it did not document assessments of the 

effectiveness of the authorities the agency used for its own employees 

because meaningful analyses were not possible due to the few 

employees who received compensation under the authorities OPM used.

CHCO agencies that reported documenting assessments identified the 

various impacts they assessed for the special payment authorities they 

used. More specifically, of the 10 CHCO agencies that reported having 

documented assessments, agencies most frequently reported evaluating 

the impact of these authorities on meeting staffing needs and on their 
Page 22 GAO-18-91 Federal Pay

effectiveness relative to other human capital flexibilities.28 This included 

DOD, which reported documenting assessments for five authorities—

special rates, the 3Rs, and student loan repayments—on its operations.

We requested copies of documented assessments from the 10 CHCO 

agencies that reported having them and 9 responded.29 Three of the nine 

responding agencies provided documents with information on authorities’

effectiveness, such as the impact on meeting staffing needs. Specifically, 

Interior provided documentation that showed the agency tracked 

workforce data, such as the number of vacancies and turnover rates 

related to using the 3Rs and special rates focused on oil and gas 

extraction.30 DOD and DHS included information on the student loan 

repayment authority in their annual reports to OPM, and credited student 

loan repayments with helping to retain highly qualified employees. Six of 

the nine responding agencies provided documentation that justified or 

reported on the use of special payment authorities rather than 

documentation that assessed the impacts that using authorities had on 

agency operations. For example, three of these six agencies provided 

examples of reviews or information addressing compliance with 

regulations relevant to the use of special payment authorities. Three other 

of these six agencies provided documents to justify and request approval 

to use 3R incentives, such as to show applicants’ qualifications or current 

employees’ performance appraisals.

 28These flexibilities could include other compensation flexibilities or noncompensation 

flexibilities such as telework and flexible work schedules. 

29The Department of Education did not respond.

30This documentation resulted from a recommendation we made that pertained to 3Rs 

incentives as used by three Interior bureaus. We closed this recommendation after Interior 

implemented it. See GAO, Oil and Gas: Interior Has Begun to Address Hiring and 

Retention Challenges but Needs to Do More, GAO-14-205 (Washington, D.C.: Jan. 31, 

2014).
Page 23 GAO-18-91 Federal Pay

CHCO agencies reported that, among the six potential challenges we 

identified in our questionnaire, insufficient resources was the most 

common challenge they experienced in using special payment authorities. 

Most CHCO agencies reported they rarely or never experienced other 

challenges. With respect to insufficient resources, 13 of the 26 agencies 

said they regularly or always experienced this challenge (see figure 5). 

According to three of these agencies, budget constraints prevented them 

from using special payment authorities more frequently or limited their 

use to filling only the most critical vacancies.

Figure 5: CHCO Agencies Reported Challenges with Using Special Payment 

Authorities, Fiscal Years 2014-2016

Four CHCO agencies said they regularly or always experienced 

challenges with burdensome documentation or complex approval process 

when using special pay authorities.

We also sought feedback on certain agencies’ experiences with OPM’s 

approval processes for special payment authorities. Below are details of 

challenges that agencies provided.

Documentation challenges

• Interior stated that the department and its components were required 

to provide a significant amount of historical data to justify the need for 

special salary table, and that publicly-available data on market 

The Most Frequently 

Identified Challenge Was 

Insufficient Resources, but 

Most Agencies Reported 

Rarely or Never 

Experiencing Other Types 

of Challenges
Page 24 GAO-18-91 Federal Pay

analyses and trends should drive the special pay rate process, 

thereby making it easier for agencies to submit requests and to adapt 

to current conditions.

• HHS reported that documenting special payment authorities was 

overly complicated for some of its divisions with smaller human 

resources (HR) staffs.

Process challenges

• The Department of Transportation (DOT) commented on the 

timeliness of OPM and OMB approvals for using the critical position 

pay authority. DOT said this delay–approximately 5 months–could 

have been a driving factor that negatively affected recruitment for a 

position, as other agencies could negotiate to offer the candidate 

higher salaries.

• Interior similarly cited a concern with approval process timeliness due 

to OPM’s limited staff and expertise coordinating between all the 

involved federal agencies with which it must deal.

• Interior suggested that when an agency must request pay flexibilities 

that can be approved by only OPM, OPM should train the agency’s 

HR staff and managers on the processes and materials needed to 

justify their requests, and should provide a clear understanding of 

timelines for approvals.

However, multiple CHCO agencies reported only rarely or never 

experiencing documentation or process challenges. For example, Interior 

credited OPM with collaborating to establish special rates to address 

challenges in competing with the oil and gas industry for the talent 

needed to meet Interior’s mission. DOD and DOJ also conveyed positive 

views on OPM’s approval process, crediting it with expediting a waiver 

request for a group retention incentive limitation and use of special rates, 

respectively.
Page 25 GAO-18-91 Federal Pay

CHCO agencies most frequently said training for agency managers is a 

change that would very likely or certainly improve the agency’s ability to 

effectively use special payment authorities (see figure 6). Conversely, 

about a quarter of responding agencies said legislative changes very 

likely or certainly would improve their ability to use special payment 

authorities.

Figure 6: CHCO Agencies Reported Likelihoods of Changes That Would Improve 

Their Use of Special Payment Authorities

CHCO agencies provided examples of how potential changes would 

improve their ability to effectively use special pay authorities. VA 

responded that its central HR office was developing a pay authority toolkit 

to provide information on processes and procedures for using the 

authorities and related training for HR specialists and managers. 

According to VA, the toolkit, mandatory training, and regularly-scheduled 

refresher training were likely to increase staff’s knowledge and ease with 

using pay flexibilities to develop competitive compensation packages to 

help recruit and retain quality talent and fill critical positions.31 HHS also 

expressed concerns about the use of special payment authorities in the 

 31In providing comments on a draft of this report, VA officials said these efforts had since 

been discontinued as the office to provide the services was closed as of September 30, 

2017.

Agencies Reported That 

Manager Training Would 

Likely Improve Use of 

Special Payment 

Authorities
Page 26 GAO-18-91 Federal Pay

context of ongoing budget constraints. Specifically, HHS noted that 

budget restraints over the last several years have led to retirements and 

resignations among its more experienced HR staff. This resulted in a loss 

of institutional knowledge on complex pay and leave authorities, including 

those affecting special payments. HHS officials said the loss of 

experienced HR staff diminishes the agency’s internal capacity to train 

remaining staff. In addition, budgetary controls result in fewer resources 

for external training. Also, Interior commented that, for special payment 

authorities that can be approved by only OPM, OPM should provide 

training for their HR staff and managers responsible for using them.

OPM has taken a number of steps to provide agencies with additional 

guidance and assistance on using special payment authorities. For 

example, in April 2015, OPM and the CHCO Council held a web-based, 

virtual human resources conference for agency officials which included a 

session on special payment authorities for recruitment and retention. 

Moreover, in January 2016, OPM issued a memorandum to agency 

CHCOs that stated that OPM recognized the 3Rs are essential pay 

flexibilities for agencies facing serious staffing challenges. The 

memorandum provided guidance on exceptions to spending limits on 3R 

incentives and OPM website links to related guidance on using the 

authorities.32 In August 2017, OPM posted a web-based training course 

 32The spending limits were lifted in November 2016.

OPM Has Provided 

Some Guidance and 

Collects Some Data, 

but Has Not 

Assessed 

Effectiveness or 

Documented 

Approval Processes

OPM Provided Guidance 

and Other Assistance
Page 27 GAO-18-91 Federal Pay

for agency officials on special payment authorities and other flexibilities, 

including examples of their use and resources for additional information.33

OPM has also pursued initiatives that focus attention on addressing 

mission-critical skills gaps areas. As part of government-wide efforts to 

develop and strengthen the cybersecurity workforce, in November 2016, 

OPM issued a memorandum and guidance to CHCOs on strategic and 

cost-effective use of the various flexibilities agencies may employ to 

recruit and retain employees in cybersecurity positions. The guidance 

included checklists of steps agencies need to complete to use various 

special payment authorities, and described ways to combine use of 

special payment authorities, when appropriate, to make federal agencies 

more competitive in recruiting and retaining cybersecurity employees.

OPM also formed Federal Agencies Skills Teams (FASTs) for 

occupations as an effort to help agencies address mission-critical skills 

gaps areas.34 As part of FASTs, OPM collected and reviewed information 

from agencies on the root causes of skills gaps and found that 

compensation levels play a role in skills gaps, in some cases. As of 

August 2016, OPM’s approach included a strategy to hold agencies 

accountable for closing skills gaps in their MCOs, and to monitor metrics 

and progress through fiscal year 2020. In January 2015, we reported that 

the measures agencies had in place limited OPM and the CHCO 

Council’s ability to track progress in closing skills gaps governmentwide. 35 Accordingly, we recommended that OPM strengthen the 

approach and methodology for addressing skills gaps by working with the 

CHCO Council to develop targets that are clear, measurable, and 

outcome oriented. OPM partially concurred with the recommendation.

 33The training is on the HRU website 

https://hru.gov/Course_Catalog.aspx?cid=250&mgr=false. 

34According to OPM, the FASTs are to analyze root causes, develop strategies to address 

skills gaps through action plans, and monitor progress in closing skills gaps within each 

occupation.

35GAO, Federal Workforce: OPM and Agencies Need to Strengthen Efforts to Identify and 

Close Mission-Critical Skills Gaps, GAO-15-223 (Washington, D.C.: Jan. 30, 2015). 
Page 28 GAO-18-91 Federal Pay

It is important to identify the necessary data and establish measures to 

track a program’s effectiveness, as well as establish a baseline to 

measure changes over time and assess the program in the future. We 

have reported that agencies can use these measurements to help them 

determine if a program is worth the investment, and to distinguish which 

of the available human capital flexibilities is better suited to address 

recruitment and retention needs.36 Standards for Internal Control in the 

Federal Government also state that management should obtain relevant 

data from reliable sources that can be used to effectively monitor 

programs.37 We have reported that understanding the relative

effectiveness of various flexibilities can help identify any changes needed 

for agencies to more effectively use them.38 As we also recently reported, 

collecting and using data to assess the effectiveness of authorities would 

be a critical first step in making more strategic use of flexibilities to 

effectively meet hiring needs.39

OPM collects agency data on the use of special payment authorities via 

annual reporting on certain authorities and EHRI, but has not analyzed 

whether the payment authorities help agencies to improve recruitment 

and retention government-wide. Nor has OPM assessed trends and 

factors that can affect the use of these authorities. As required by statute, 

OPM annually collects data from agencies to report to Congress on the 

use of the student loan repayment and critical position pay authorities.

• Student loan repayment: OPM collects some information from 

agencies about their use of student loan repayment authority and 

invites agencies to provide details about their experiences in 

administering the authority, but has not conducted an analysis of the 

authority’s effectiveness for addressing recruitment and retention 

needs. As discussed previously, we analyzed the government-wide 

use of this authority by occupation and identified those occupations 

for which agencies most frequently used the authority (see figure 4). 

In addition, we used OPM’s 2015 report and information from its 

 36GAO-05-762.

37GAO-14-704G. 

38GAO-16-521.

39GAO, Cybersecurity: Federal Efforts are Under Way That May Address Workforce 

Challenges, GAO-17-533T (Washington, D.C. April 4, 2017).

OPM Does Not Track 

Special Payment 

Authorities to Assess 

Whether Using Them 

Improves Recruitment and 

Retention
Page 29 GAO-18-91 Federal Pay

FASTs skills gap initiative to identify the use of this authority for 

MCOs. These are two examples of analyses that OPM could perform 

to help understand how agencies are using this authority.

• Critical position pay: OPM collects data on agency use of critical 

position pay from the agencies with existing OPM approval, but the 

information does not help OPM understand how the payment authority 

supports recruitment or retention. OPM collects data that it is required 

by statute to report to Congress such as who received the higher rate 

and the rate paid, but does not include information on the impact on 

recruitment and retention.40

OPM has stopped regularly collecting and analyzing data for the 3R 

incentives, except on the use of retention incentives for employees likely 

to leave for other federal agencies, and does not collect and analyze data 

for special rates, leaving a void for conducting government-wide analysis 

that would help determine whether special payment authorities help 

address agency recruitment and retention needs:

• 3R incentives: In a February 2010 memorandum to agency CHCOs 

on 3R incentives, OPM called for it and agencies to more actively 

manage the program and track data. OPM said that validated data 

would help OPM and agencies to understand the nature and trends of 

use of the incentives and better track incentives on an ongoing basis. 

OPM and agencies would also, if necessary, be better able to 

investigate any 3R data anomalies and take corrective actions. Based 

on its request to agencies in October 2011, OPM prepared a draft 

report on its analysis of agency-provided data and information on use 

of 3R incentives in calendar years 2010 and 2011, including what 

agencies reported as barriers to using the authorities and whether 3R 

improved recruitment and retention.41 However, OPM did not 

distribute the report or take action on it.42 Although OPM said it 

planned to conduct periodic reviews on an ongoing basis, since the 

 40OPM is required to annually report to the oversight committees of the House of 

Representatives and Senate on the number of positions (in the aggregate and by agency) 

for which higher rates were authorized or paid during the period covered, the name of 

each employee who received the higher rate, the rate paid each employee, the period of 

time during which the rates were paid, and what the rates would have been but for the 

authorization of a higher rate. 5 U.S.C. § 5377(h).

41Although OPM was no longer required to submit a 3Rs report to Congress, OPM 

requested the data consistent with its authority to review agency 3Rs determinations.

42According to OPM officials, the agency did not issue the report because it was not a 

required report to Congress. In addition, sequestration and 3Rs spending limits changed 

the focus on the issue.
Page 30 GAO-18-91 Federal Pay

3R reporting requirement expired and OPM’s October 2011 agency 

data request, OPM does not regularly collect and review governmentwide information on the level of use and potential barriers.43

• Special rates: In conducting its annual review of special rates, each 

year OPM asks that agencies review their respective applicable 

special pay rate tables to determine whether the rates should be 

terminated, reduced, or increased.44 OPM considers requests to make 

changes based on the agency reviews, but according to OPM 

officials, in recent years, agencies have not identified any needed 

changes to special rates during that annual review process.

Moreover, OPM has not used its EHRI data to better understand trends in 

the use of these authorities government-wide and how agencies are using 

them to address their recruitment and retention challenges. As an 

example, we analyzed EHRI data to describe government-wide use of 

selected authorities by occupational family in fiscal year 2014. From that 

analysis, we identified differences in use across various occupational 

families that could be helpful in understanding how agencies are using 

these authorities. For example, we found that the Medical, Hospital, 

Dental, and Public Health family was the top occupational family for four 

of the five authorities. See appendix IV for additional information.

OPM also has not explored trends in agency use of the critical position 

pay authority. OPM has not pursued reasons why agencies have not 

requested approval for over 750 available slots or why agencies have 

used only 4 of the 36 authorized positions as of calendar year 2015. As 

part of an initiative to close skills gaps for the STEM workforce, in October 

2014, the White House Office of Science and Technology Policy, OPM, 

and OMB identified the critical position pay authority as a potentially 

underused flexibility. However, according to the 2015 OPM report, OPM 

had authorized critical position pay for 36 positions in 10 agencies as of 

calendar year 2015. And, only four of those agencies reported using the 

 43The Federal Workforce Flexibility Act of 2004 required OPM to annually report to 

Congress on how agencies used the recruitment, relocation, and retention incentives.

Pub. L. No. 108-411, § 101(c), 118 Stat. 2305, 2309 (Oct. 30, 2004). This requirement 

terminated after the first five years of reporting. However, in response to the law’s 

instruction concerning monitoring of the retention incentives for employees likely to leave 

for other federal agencies, OPM continues to require annual agency reporting to OPM on 

use of this particular incentive. 5 C.F.R. § 575.314(i).

44OPM asks whether special rates should change by a percentage greater than any base 

General Schedule percentage increase that may become effective in January the 

following year.
Page 31 GAO-18-91 Federal Pay

critical position pay authority in 2015 for four current employees (see 

table 6).

Table 6: Agencies Utilization of Available Critical Position Pay Authority Slots in 

Calendar Years (CY) 2012-2015

CY 2012 CY 2013 CY 2014 CY 2015

Available 765 765 765 764

Approved but 

Unused

32 32 32 32

Used 3 3 3 4

Source: GAO analysis of OPM Critical Position Pay Reports (CY 2012-2015). | GAO-18-91

In July 2017, the Treasury Inspector General for Tax Administration 

(TIGTA) recommended that the Internal Revenue Service (IRS) pilot the 

use of critical position pay authority to recruit highly-qualified experts to 

lead IRS’s cybersecurity and related specialized functions. According to 

TIGTA, IRS would enhance its recruitment efforts by using the authority.45

OPM officials attribute low use of critical position pay to: (1) agencies’

views that the approval process is cumbersome; (2) management 

resistance or cultural issues based on views about pay inequity between 

employees, or employees receiving higher salaries than their managers; 

and (3) agencies using other compensation flexibilities that do not require 

prior OPM approval.

OPM is not tracking government-wide data on the use of the range of 

special payment authorities to better understand whether or how various 

authorities improve recruitment and retention. OPM officials said the 

information they collect on special payment authorities depends on 

reporting requirements for the specific payment authority. For example, 

they said they collect information on assessing the effectiveness of 

student loan repayments because of the reporting requirements in the 

law. However, the reporting requirement does not include assessments to 

 45IRS had previously used its own streamlined critical pay authority since 1998 to fill 

positions that it had designated as critical, primarily related to information technology. 5 

U.S.C. § 9503. However, that authority expired on September 30, 2013, and the 

appointments of the few employees still serving under that authority will expire by 

September 30, 2017. In congressional testimony in July 2017, the Commissioner of IRS 

said he hopes that Congress will approve reinstating the authority through 2021, as 

proposed in the President’s fiscal year 2018 budget. See 

https://www.appropriations.senate.gov/download/072617-koskinen-testimony downloaded 

8/15/17.
Page 32 GAO-18-91 Federal Pay

examine effectiveness or impediments to help OPM determine whether 

potential changes may be needed to address recruitment and retention 

challenges.46 Instead, OPM’s annual data request memorandums invite 

agencies to provide additional details on their experiences in 

administering the student loan repayments.

OPM officials said they may sometimes perform ad hoc analyses of EHRI 

data on certain authorities but do not regularly analyze EHRI data on the 

use of the various authorities government-wide. For example, OPM 

officials said they have queried the EHRI database on the use of selected 

special payment authorities for cybersecurity employees and found the 

numbers of 3R incentives and agencies using them increased from fiscal 

year 2015 to 2016, while use of student loan repayments decreased 

during that period. However, OPM does not regularly conduct such 

analyses on this or other uses of special payment authorities to 

understand how they are used to address skills gaps.

By not tracking and analyzing data on the use of special payment 

authorities, OPM and the CHCO Council do not have the information they 

need to help determine what potential changes may be needed, and have 

limited assurance that special payment authorities are helping agencies 

meet their needs and achieve recruitment and retention goals.

Standards for Internal Control in the Federal Government requires that 

agency management design and implement control activities, which are 

the actions management puts in place through policies and procedures to 

achieve objectives and respond to risks. We have reported on OPM’s 

important leadership role and the CHCO Council’s support in assisting 

agencies with identifying and applying human capital flexibilities across 

the federal government.47 In its most recent strategic plan, OPM reported 

it would lead federal human capital management by partnering with its 

stakeholders—including federal agencies—to develop and implement 

effective and relevant human resources solutions to build an engaged, 

productive, and high-performing workforce and develop effective 

 46Agencies are required to annually submit to OPM information on the number of 

employees who received the benefit, the job classification of recipients, and the cost of 

providing these benefits. OPM is to prepare and submit to Congress a report with this 

information. 5 U.S.C. § 5379(h); 5 C.F.R. § 537.110. 

47GAO-03-428.

OPM May Be Missing 

Opportunities to Promote 

Strategic Use of Special 

Payment Authorities
Page 33 GAO-18-91 Federal Pay

compensation packages, among other things.48 OPM also has 

acknowledged its leadership role in strategically promoting the effective 

use of at least one special payment authority—student loan repayment—

and assisting agencies in the strategic use of this and other recruitment 

and retention tools as necessary to attract and retain a well-qualified 

federal workforce and support agency mission and program needs.49

We have also previously reported on the lack of awareness among 

federal managers about using flexibilities to address human capital 

challenges.50 In 2014, we reported that in a forum of CHCO Council 

agencies we convened, CHCOs said they wanted OPM to do more to 

raise awareness and assess the utility of tools and guidance it provides to 

agencies to address key human capital challenges.51 Accordingly, we 

recommended that OPM evaluate the communication strategy for and 

effectiveness of relevant tools, guidance, or leading practices created by 

OPM or the agencies to help ensure agencies are getting the guidance 

and tools that they need. OPM concurred with the recommendation.

OPM does not provide guidance on assessing effectiveness of special 

payment authorities in the agency’s handbook on human capital 

flexibilities for any of the authorities we reviewed. For example, OPM 

does not offer examples of assessments to illustrate what data are 

needed and what methodologies are available for determining whether 

special payment authorities improve recruitment and retention. OPM has 

provided supplemental information on assessing effectiveness in some 

student loan repayment authority annual reports and provided links to 

those reports on its website, but has not done so for other payment 

authorities. OPM officials said that they believe agencies are in the best 

position to collect and analyze data to determine which special payment 

authorities are effective for addressing recruitment and retention needs at 

their agency.

 48OPM Strategic Plan FY2014-2018, 

https://www.opm.gov/about-us/budget-performance/strategic-plans/2014-2018-strategic-pl

an.pdf, accessed March 9, 2017.

492015 Federal Student Loan Repayment Program Report to Congress.

50GAO-03-428. 

51GAO-14-168.

Guidance on Assessing 

Effectiveness
Page 34 GAO-18-91 Federal Pay

However, we found that CHCO agencies often did not document 

assessments for the special payment authorities they used. The 

documents agencies prepared were most often focused on justifying or 

reporting on use of authorities rather than on evaluating their 

effectiveness in improving recruitment and retention. As mentioned 

previously, documents addressed compliance with regulations and 

justifications that agencies prepared to request approval for using the 

authorities.

Our review found examples of data and methodologies that agencies 

could use to help assess whether an authority helped improve recruitment 

and retention. For example, DOD used data from interviews with 

employees hired into its entry-level developmental trainee programs to 

gather feedback on student loan repayment. The feedback consistently 

indicated that the program was a major contributing factor in employees’

decisions to accept these positions. Also, Interior collected and monitored 

data on retention rates to assess the effectiveness of special rates in 

retaining its oil and gas workforce. State said that it conducted some 

informal assessments of its use of retention incentives but could add a 

question to its employee exit survey to collect data on how these 

incentives affect attrition. Some CHCO agency questionnaire responses 

included examples of other types of data or analyses that could be used 

to assess special payment authorities such as (1) the reduced level of 

resignations in a department that had experienced staffing shortages; (2) 

an increased rate of filling certain hard-to-fill positions; and (3) counts of 

the numbers of employees successfully recruited into mission-critical 

skills gap areas.

OPM does not provide consistent information via tools and guidance to 

support effective use of special payment authorities. OPM’s website 

guidance for the student loan repayment authority provides agencies with 

tools including best practices, sample agency plans, and answers to 

frequently asked questions. However, its website guidance for superior 

qualifications and special needs pay setting authority, for example, only 

has fact sheets which generally restate and reference the related 

regulations. Table 7 summarizes the various types of tools and guidance 

information on the agency’s website about special payment authorities.

Tools and Guidance to Support 

Strategic Decisions
Page 35 GAO-18-91 Federal Pay

Table 7: Tools and Guidance on OPM’s Website for Title 5 Special Payment 

Authorities 

Authority

Best 

practices

Sample 

plans

Answers to 

frequently 

asked 

questions

Fact sheet with 

legal 

requirements

Special rates — N/A — X

Recruitment 

incentives — — X X

Retention 

incentives — — X X

Relocation 

incentives — — X X

Superior 

qualifications — — — X

Student loan 

repayment X X X X

Critical position 

pay — N/A — X

Source: GAO analysis of OPM information. | GAO-18-91

Note: X indicates that OPM’s website provides information on the type of tool or guidance and “—”

indicates that OPM’s website does not provide information on the type of tool or guidance. N/A 

indicates that the tool or guidance does not apply to the authority, according to OPM.

In addition to the tools and guidance noted above, the student loan 

repayment website includes links to OPM annual reports which include 

details that could support agency use of this authority. In OPM’s annual 

requests for data on student loan repayments, OPM regularly invites 

agencies to submit information for these reports, including on these 

topics:

• lessons learned,

• establishing a business case,

• program impediments, and

• ways to improve the student loan repayment program.

OPM’s guidance on using special pay authorities to address cybersecurity 

skills gaps illustrates how OPM provides useful information which could 

be applied in other mission-critical skills areas. In assisting agencies on 

ways to combine authorities to hire cybersecurity specialists, the 

guidance includes hypothetical scenarios where desirable job candidates 

have competing job offers or are currently employed, and provides 

example competitive compensation packages for entry-, mid-, and 
Page 36 GAO-18-91 Federal Pay

senior/expert-level employees. Such information could be useful for other 

government-wide or agency-identified mission-critical skills gaps or other 

positions where agencies face serious recruitment or retention 

challenges.

OPM officials said they recognized tension between any effort to promote 

use of special payment authorities and OPM’s role of providing oversight 

of special payment authorities. OPM officials said the agency promotes 

the use of the authorities when agencies seek OPM’s help, rather than 

undertaking efforts to more broadly ensure agencies are fully aware of the 

potential benefits and innovative ways to use authorities. Further, OPM 

has not worked with the CHCO Council to gather and disseminate 

illustrative examples of data needed and methodologies to assess the 

effectiveness of the authorities.

With guidance to assess effectiveness and consistent tools and guidance 

across the range of authorities, OPM and CHCO agencies could more 

fully support strategic use of special payment authorities to improve 

recruitment and retention across the federal government.

Standards for Internal Control in the Federal Government require 

management to design and implement control activities through policies 

to achieve objectives and respond to risks.52 Documentation and periodic 

review of policies and procedures are important parts of the standards 

and are necessary to design, implement, and operate controls effectively.

Documentation provides a means to retain organizational knowledge and 

mitigate the risk of having that knowledge limited to a few personnel. 

Documentation is also evidence that controls can be monitored and 

evaluated. As we previously reported, streamlining administrative 

processes is a key practice for effectively using human capital 

flexibilities.53 Since agency officials must view administrative processes 

as worth their time compared to the expected benefit to be gained, 

perceived burdens and slow approval processes could dissuade them 

from seeking approval to use special payment authorities that could 

address recruitment and retention needs.

 52GAO-14-704G 10.01, 12.01.

53GAO-03-2.

OPM Approval Processes 

Are Not Fully Documented
Page 37 GAO-18-91 Federal Pay

OPM regulations implementing the statutory provisions set forth the basic 

criteria for OPM approval of certain special payment authorities, but OPM 

does not have documented procedures to guide OPM staff in assessing 

agency requests for approval. For example, OPM does not have 

documented criteria to assess the sufficiency of the information to support 

the request, such as

• the soundness of the methodology or reliability of underlying data for 

calculating payment amounts, or

• the sufficiency of prior agency efforts to recruit and retain employees 

without having to resort to additional pay.

OPM officials noted that the complexity and nature of recruitment and 

retention difficulties can vary significantly between agencies and the 

authority requested. To make decisions about an agency’s request for 

approval, OPM officials said they apply the criteria in law, regulations, and 

guidance posted on OPM’s website.

Our analysis shows that, since January 2009, OPM generally took 4 to 6 

months to make approval decisions on CHCO agency special rates and 

critical position pay requests.54 OPM officials said they have 

conversations with agency officials about their views on the process, but 

do not have procedures to systematically monitor or evaluate the process, 

such as to seek agency feedback on whether the approval processes are

burdensome, complex, and a barrier to wider use. As noted earlier, we 

sought feedback on certain agencies’ experiences with OPM’s approval 

processes for special payment authorities. Although some had positive 

comments, others expressed concerns about the timeliness of the 

process, including that the length of the process may lead to missed 

opportunities to hire desirable candidates.

The July 2017 Treasury Inspector General for Tax Administration (TIGTA) 

report also said that lengthy approval processes for using critical position 

pay is a reason for low overall use of the authority. If pursued by IRS, the 

approval process would include getting the request cleared internally, 

approved by the Secretary of the Treasury and then, in turn, by OPM and 

OMB. OPM has not established a time frame within which agencies could 

expect a decision from OPM and OMB. OPM officials estimated that it 

may take several weeks or up to several months to complete the approval 

 54OPM data showed that approvals for 3Rs incentive waivers generally took about one 

and one half months since January 2009.
Page 38 GAO-18-91 Federal Pay

process, according to TIGTA. As part of its recommendation to IRS, 

TIGTA recommended tracking in detail the time and effort to get the 

request for approval cleared internally and approved by the Secretary of 

the Treasury, OPM, and OMB.

OPM officials said they do not have documented procedures with criteria 

for approving use of special payment authorities because the complexity 

and nature of the requests vary significantly between agencies and the 

authority requested. OPM officials noted that in reviewing applications 

they need to be able to take into account relevant and important variables 

necessary to make fact-specific and reasonable determinations to help an 

agency find the most appropriate solution to its staffing problems. They 

said there is no “one-size-fits-all” formula for approving or denying 

requests.

However, without documented procedures for assessing requests for 

approval, OPM lacks a means to review and assure that approval 

processes achieve their objectives. Without such documents, OPM also 

increases the likelihood of inconsistent decisions to grant or decline 

approval for the use of special pay authorities. Moreover, it also increases 

the risk of losing organizational knowledge of the personnel with expertise 

in assessing requests. Additionally, by not periodically examining the 

procedures, OPM is not well-positioned to consider alternatives for 

streamlining the approval process.

To deal with staffing challenges resulting from skills gaps, reduced 

budgets, and the upcoming wave of retirements, agencies have 

compensation tools at their disposal that can be coupled with other 

flexibilities to produce an attractive package for potential and current 

employees. CHCO agencies generally reported that special payment 

authorities positively contributed to areas such as employee retention, 

applicant quality, and ability to meet staffing needs, among others.

OPM has acknowledged its leadership role in strategically promoting the 

effective use of at least one special payment authority—student loan 

repayment—and assisting agencies in strategic use of this and other 

human capital tools. However, OPM has not tracked or analyzed the 

government-wide data on agencies’ use of various special payment 

authorities to better understand whether or how various authorities 

improve recruitment and retention. By tracking and analyzing these data, 

OPM could have information it needs to determine what potential 

changes may be needed, and have better assurance that special 

Conclusions
Page 39 GAO-18-91 Federal Pay

payment authorities are helping agencies meet their needs and achieve 

recruitment and retention goals. Moreover, OPM has not been consistent 

in providing guidance on assessing effectiveness of the range of special 

payment authorities in attracting and retaining a well-qualified federal 

workforce to support agency mission and program needs. Few agencies

are documenting assessments. OPM has not worked with the CHCO 

Council agencies to provide illustrative examples of data needed and 

methodologies to assess the effectiveness of the authorities. By providing 

guidance on assessing effectiveness of these authorities, OPM and 

CHCO agencies could be better positioned to know whether use of the 

authorities is improving recruitment and retention or what changes might 

be needed to improve their effectiveness.

Agency officials may also perceive documentation and approval 

processes as time consuming or burdensome barriers to using 

compensation tools. Perceived delays or inefficiency in OPM’s approval 

processes could discourage agencies from seeking to use Title 5 special 

payment authorities that could address recruitment and retention 

challenges. OPM also had not documented procedures for assessing the 

sufficiency of the information agencies submit to request approval. By 

establishing documented procedures and periodically reviewing them, 

OPM would increase the likelihood of consistent decisions to grant or 

decline agency requests for approval to use these authorities.

We are making the following three recommendations to OPM.

The Director of OPM, together with the CHCO Council, should track 

government-wide data to establish a baseline and analyze the extent to 

which the seven Title 5 special payment authorities are effective in 

improving employee recruitment and retention, and determine what 

potential changes may be needed to improve the seven authorities’

effectiveness. (Recommendation 1)

The Director of OPM, together with the CHCO Council, should provide 

guidance on assessing effectiveness and tools—such as best practices or 

frequently asked questions—for the range of Title 5 special payment 

authorities. (Recommendation 2)

The Director of OPM should establish documented procedures to assess 

special payment authority requests requiring OPM approval and 

periodically review approval procedures to consider ways to streamline 

them. (Recommendation 3)

Recommendations for 

Executive Action
Page 40 GAO-18-91 Federal Pay

We provided a draft of this report to OPM for review and comment. We 

also provided relevant draft report excerpts to CHCO agency officials for 

comment in cases where we more extensively reported an agency’s 

illustrative examples, or where an agency’s views were more significant in 

context of the report.55 OPM provided written comments, which are 

reproduced in appendix V and summarized below. Of our three 

recommendations, OPM concurred with one and partially concurred with 

the other two. OPM also outlined its planned steps to implement the 

recommendations. OPM and CHCO Council agency officials also 

provided technical comments, which we incorporated as appropriate.

In response to our first recommendation, OPM partially concurred and 

outlined its plans to track data that cover a limited period to analyze 

agencies’ use of certain Title 5 special payment authorities. OPM said it 

planned to analyze both student loan repayment authority data by 

occupation for one calendar year (2016) and the most recently available 

data for five of the other six special payment authorities covered in this 

report. This includes use for government-wide mission-critical 

occupations. While these actions may provide some degree of insight into 

the extent to which and how agencies use some of the special pay 

authorities, examining only recent and available data will not support 

establishing a baseline to measure changes over time, tracking 

effectiveness, or determining any changes needed in future years. We 

made revisions to the recommendation to clarify the value of tracking data 

over time for the seven special payment authorities. OPM stated that 

tracking government-wide workforce data available to them will not 

provide a complete assessment of the effectiveness of the special 

payment authorities because agencies are in the best position to analyze 

such information. We agree that agencies have first-hand information on 

use of special payments. Agencies also have data that can inform 

discussions between OPM and the CHCO Council on potential strategies 

for a government-wide approach to enhance strategic use of these 

authorities to address mission-critical skill gaps. By working with the 

agencies through the CHCO Council, OPM is better positioned to track 

government-wide data to analyze the extent to which Title 5 special 

payment authorities improve employee recruitment and retention and 

 55The agencies were the Departments of Defense, Health and Human Services, 

Homeland Security, Interior, Transportation, and Veterans Affairs. 

Agency Comments 

and Our Evaluation
Page 41 GAO-18-91 Federal Pay

determine what potential changes may be needed to improve authorities’ 

effectiveness.

In response to our second recommendation, OPM concurred and outlined 

plans such as issuing guidance with examples of assessments to 

illustrate what data are needed and what methodologies are available for 

determining whether special payment authorities help improve 

recruitment and retention. We believe OPM could also assist agencies by 

providing tools or other guidance for the authorities that OPM does not 

approve—such as on establishing a business case, best practices, 

answers to frequently asked questions, or lessons learned—to help 

ensure consistent information is shared with agencies to support effective 

use for the range of Title 5 special payment authorities. OPM could also 

provide agencies with tools and guidance for other mission-critical skills 

areas similar to those shared for addressing cybersecurity skills gaps. 

Such tools and guidance could include hypothetical recruitment 

scenarios, checklists of required steps, and examples of competitive 

compensation packages. OPM stated it would work on any guidance that 

the CHCO Council identifies to improve use of special payment 

authorities. With consistent tools and guidance across the range of 

authorities, OPM and CHCO agencies can be positioned to fully support 

strategic use of special payment authorities to improve recruitment and 

retention across the federal government.

In response to our third recommendation, OPM partially concurred and 

commented that there is no “one-size-fits-all” formula for approving or 

denying agency requests. It added that applying a rigid formula could 

result in unwarranted disapprovals. OPM also stated that it would 

document additional procedures to guide staff in evaluating agency 

requests and periodically review the procedures. We believe establishing 

documented procedures would guide staff in considering such complex 

factors such as the soundness of the methodology and the reliability of 

underlying data for calculating payments amounts. Documentation of 

policies and procedures is an important part of internal control standards. 

By documenting procedures to review requests, OPM will help ensure 

consistency in approval decisions and retain organizational knowledge of 

personnel with expertise in assessing requests.
Page 42 GAO-18-91 Federal Pay

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 14 days from the 

report date. At that time, we will are send copies of this report to 

appropriate congressional committees, the Acting Director of OPM, and 

other interested parties. In addition, the report will be available at no 

charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2717 or jonesy@gao.gov. Contact points for our offices

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made key contributions to this report 

are listed in appendix VI.

Yvonne D. Jones

Director

Strategic Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-18-91 Federal Pay

This report (1) describes what is known about how much Chief Human 

Capital Officer (CHCO) Council agencies used selected special payment 

authorities in fiscal years 2014-2016; (2) assesses the extent to which 

CHCO agencies evaluate the effectiveness of these authorities and 

identifies challenges, if any, the agencies reported facing in using the 

authorities to address mission-critical skills gap areas; and (3) evaluates 

how the Office of Personnel Management (OPM) has helped agencies 

address federal recruitment and retention needs. We limited our scope to 

the seven broadly available special payment authorities generally 

available government-wide under Title 5 of the United States Code to 

address federal agencies’ recruitment and retention issues: (1) special 

rates, (2) recruitment incentives, (3) relocation incentives, (4) retention 

incentives, (5) superior qualifications and special needs pay setting, (6) 

student loan repayments, and (7) critical position pay.1

To describe what is known about how much CHCO Council agencies 

used selected special payment authorities in fiscal years 2014-2016, we 

developed and administered a questionnaire to the 27 CHCO agencies to 

collect their fiscal years 2014-2016 data—to the extent available—on 

frequency of use, dollars spent, and whether they used the authorities to 

help address recruitment and retention needs in mission-critical skills gap 

areas.2 All 26 CHCO agencies that reported use of the authorities 

responded to our questionnaire.3 We asked agencies to not report 

 1

There are a number of other compensation flexibilities available to federal agencies, 

including those whose application is limited to senior executives, health care 

professionals, and employees serving in combat zones, among others. 

2

The 27 CHCO Council agencies include the Departments of Agriculture, Commerce, 

Defense, Education, Energy, Health and Human Services, Homeland Security, Housing 

and Urban Development, Interior, Justice, Labor, State, Treasury, Transportation, and 

Veterans Affairs; the Environmental Protection Agency, General Services Administration, 

National Aeronautics and Space Administration, National Science Foundation, Nuclear 

Regulatory Commission, Office of Management and Budget, Office of Personnel 

Management, Office of the Director of National Intelligence, Small Agency Council, Small 

Business Administration, Social Security Administration, and the U.S. Agency for 

International Development. Federal Trade Commission received a questionnaire as the 

small agency representative on the CHCO Council at the time of our review.

3

The State Department responded but excluded employees in the Foreign Service from its 

reporting. The Office of the Director of National Intelligence was excluded because 

officials told us that it has its own personnel system and does not use the Title 5 pay 

authorities included in the scope of our review. 50 U.S.C. § 3024.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-18-91 Federal Pay

information related to agency-specific or non-Title 5 authorities.4 In our 

report, we use the aggregate CHCO agency reported data by authority. 

Federal employees may receive compensation under more than one 

authority in a given fiscal year, and in these instances would be counted 

for each authority received. For example, an employee who received a 

recruitment incentive and student loan repayments in the same fiscal year 

would be counted once for each authority in that year. We did not verify 

the amounts agencies reported spending.

In addition, we used CHCO reported data to determine the total use of 

these authorities and OPM Enterprise Human Resources Integration 

(EHRI) personnel data, which contains personnel action and workforce 

data for most federal civilian employees, to identify the approximate 

percentage of employees who received at least one of these seven 

authorities in fiscal year 2016.5 In calculating the percentage, we used 

CHCO agency reported data for the numerator and OPM EHRI data for 

the total number of federal employees at the 26 CHCO agencies—as of 

September 30, 2016—for the denominator.

We also analyzed OPM EHRI personnel data for fiscal year 2014 to 

describe the government-wide use of certain authorities by occupational 

family. To do so, we calculated the number of unique employees who 

received a certain authority in each fiscal year. We included federal 

employees on permanent and nonpermanent appointments, and all work 

schedules (seasonal, nonseasonal, intermittent, and full-time and parttime). Individual employees who switched occupational families during a 

fiscal year could be counted more than once if they received a special 

payment authority under both occupational families. We primarily relied 

on the following EHRI data variables to describe agencies’ use of certain 

authorities:

 4

For example, the Department of Energy has authority to fix compensation, without regard 

to how compensation is fixed under title 5, for no more than two hundred scientific, 

engineering, professional, and administrative personnel within specified limits under 42 

U.S.C. § 7231(d). However, reported data from some agencies likely include some 

employees who received special payments under a non-Title 5 authority. Some agency 

officials said that their systems did not allow reporting data to exclude employees who

received special rates payments under non-Title 5 authorities.

5

EHRI is the primary government-wide source for information on federal employees. The 

EHRI data we analyzed include executive branch civilian employees, but do not include 

the U.S. Postal Service, most legislative or judicial branch employees, or intelligence 

agencies. 
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-18-91 Federal Pay

• Special rates: We used the “pay rate determinant” to identify 

employees who were receiving a special rate as of the end of the 

applicable fiscal year, and then used the “special pay table identifier”

to limit our analysis to special rates authorized under 5 U.S.C § 5305.6

OPM officials provided a list of all authorized Title 5 special rate tables 

active during the fiscal years included in our review.

• 3R incentives: We used the “legal authority” and “nature of action”

codes to identify employees for whom 3R incentives were authorized 

during the fiscal year.

• Superior qualifications and special needs pay setting: We used 

the “pay rate determinant” and “nature of action” codes for new 

appointments to identify the number of employees who had received a 

superior qualifications and special needs pay setting authority during 

the fiscal year.

We reviewed OPM documentation, including OPM’s Guide to Data 

Standards—the guidance document that describe data elements in 

EHRI—to identify the specific codes used to designate employees who 

had received these authorities.

We also analyzed OPM calendar year 2015 reports—the most recently 

available at the time of our review—on the student loan repayment 

authority and the critical position pay authority to describe agencies’ use 

of these two authorities by occupation.7 For the student loan repayment 

authority, we calculated the top occupations series that received this 

authority government-wide. We aggregated the 18 engineering-related 

occupations into one engineering series.8 In addition, for the agencies 

that most frequently used the authority, we calculated the approximate 

 6

Some agencies have their own authority to establish pay rates for certain employees. 

These agency-specific pay rates are outside the scope of our review.

7

We used these data because OPM officials said that they considered the data included in 

the annual reports OPM provides to Congress to be more reliable than the EHRI reported 

information for these two authorities.

8

The 18 individual series were general engineering (0801 series), engineering technical 

(0802 series), safety engineering (0803 series), materials engineering (0806 series), civil 

engineering (0810 series), environmental engineering (0819 series), mechanical 

engineering (0830 series), nuclear engineering (0840 series), electrical engineering (0850 

series), computer engineering (0854 series), electronics engineering (0855 series), 

electronics technical (0856 series), bioengineering and biomedical engineering (0858 

series), aerospace engineering (0861 series), mining engineering (0880 series), petroleum 

engineering (0881 series), chemical engineering (0893 series), and industrial engineering 

(0896 series).
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-18-91 Federal Pay

percentage of occupations that received the authority that were identified 

as mission critical by these agencies as part of OPM’s and the CHCO 

Council’s initiative to close skills gaps.

To assess the reliability of the CHCO agency reported data and OPM 

data, we compared frequencies from the various data sources by agency 

for fiscal year 2014 (the one year of available overlapping data); reviewed 

OPM documentation; and interviewed OPM officials. We determined that 

the data were sufficiently reliable to present agency use of special 

payment authorities over this time period.

To assess the extent to which CHCO agencies evaluate the effectiveness 

of special payment authorities and to identify challenges they reported 

facing in using the authorities, in our questionnaire to agencies we asked 

about their views on the impacts of each authority used in fiscal years 

2014-2016. We analyzed and summarized closed-ended question 

response data agencies reported on authorities’ impacts on agency 

operations, including the extent of positive or negative effects in areas 

such as employee retention, applicant quality, and ability to achieve the 

agency mission. We also asked whether and how they assessed each 

authority’s effectiveness. We summarized closed-ended question 

response data on whether agencies had done documented, informal, or 

no effectiveness assessments of authorities in impact areas such as 

agency mission, meeting staffing needs, or addressing mission-critical 

skills gap areas. We contacted the 10 agencies that reported having 

documented assessments for one or more authorities to request copies of 

them. Nine agencies provided requested documents.9 We analyzed the 

documents to determine the type of information they provided, including 

whether they had information on how use of the authority had been 

effective in the impacts the questionnaire asked about. To learn more 

about agencies views on authorities’ effectiveness, we also asked an 

open-ended question for agencies to provide examples of how authorities 

helped address mission-critical skills gaps. We reviewed the narratives 

agencies provided to identify and report examples appropriate to illustrate 

the various effects agencies reported.

 9

The following agencies provided documents: the Environmental Protection Agency, 

General Services Administration, Small Business Administration; and the Departments of 

Commerce, Defense, Health and Human Services, Homeland Security, Justice, and the 

Interior. The Department of Education did not respond to our request for documentation.
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-18-91 Federal Pay

We also asked agencies about their views on any challenges they 

experienced in using special payment authorities and potential changes 

to operations or procedures to help improve effective use of authorities. 

We analyzed and summarized the closed-ended question response data 

agencies reported on how often they experienced certain challenges, 

including insufficient resources, management resistance, burdensome 

documentation, and complex approval process. For the two most 

common challenges agencies reported other than insufficient resources—

burdensome documentation and the complex approval process—we 

followed up with the three agencies that reported regularly or always 

experiencing both challenges. Two agencies responded.10 We also asked 

an open-ended question for agencies to provide narrative examples of 

how they identified and responded to challenges in using these 

authorities. We analyzed the content of the narrative responses to identify 

and report examples appropriate to illustrate various challenges and 

responses to challenges agencies reported.

To learn more about agencies’ experiences with OPM’s approval 

processes for special payment authorities, we analyzed OPM’s data on 

agency requests to use the special payment authorities that OPM 

approves. In addition to our CHCO agency questionnaire response followup, we contacted selected agencies that OPM data identified as having 

requested approval to use a special payment authority since 2009. We 

asked seven agencies to provide narrative of their views on such topics 

as what worked well, challenges experienced, and any suggestions for 

improving the process. To provide an opportunity to learn how approval 

processes could affect agency decisions to not seek such approvals, we 

included two agencies—EPA and HHS—that had not made such 

requests to ask for narrative explanations of why they had not sought 

such approvals. All agencies provided their views.11 We analyzed 

agencies’ narrative responses to illustrate examples of the experiences 

agencies reported.

We also analyzed and summarized the closed-ended question response 

data agencies reported on how likely potential changes would improve 

use of special payment authorities. We followed up with five agencies that 

 10The General Service Administration and Department of the Interior responded. The 

Federal Trade Commission did not respond.

11The following agencies provided views: the Environmental Protection Agency and the 

Departments of Defense, Health and Human Services, Homeland Security, the Interior, 

Justice, State, Transportation, and Veterans Affairs.
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-18-91 Federal Pay

identified the three most common potential changes that would very likely 

or certainly improve their ability to effectively use special pay authorities—

changes to training for agency managers, training for agency human 

resources employees, and OPM regulations. We asked them to provide 

narrative descriptions of changes they had in mind and how changes 

would improve their agency’s effective use of special payment authorities.

Four agencies responded.12 We reviewed the narratives agencies 

provided to identify examples appropriate to illustrate the various views 

on potential changes agencies reported.

To evaluate how OPM has helped agencies address federal recruitment 

and retention needs, we interviewed OPM officials and reviewed OPM’s 

procedures to collect and analyze data on agency use of special payment 

authorities, including through automated systems (EHRI) and information 

requests and reporting. We reviewed the procedures to assess whether 

OPM tracks data to assess the level and effective use of the payment 

authorities to improve recruitment and retention. We also reviewed and 

summarized the various ways OPM provides agencies information on 

special payment authorities, including through OPM’s memorandums, 

opm.gov website tools and guidance on each special payment authority, 

and guidance for using special payment authorities to address 

cybersecurity skills gaps. We compared the types of information and 

consistency of the various ways OPM provides information to promote the 

strategic use of special payment authorities to include supporting agency 

effectiveness assessments and increased awareness and strategic 

decision making on the use special payment authorities. We reviewed 

procedures to collect information on the use of critical position pay 

authority and a July 2017 Treasury Inspector General for Tax 

Administration report on the topic. We also interviewed OPM officials and 

reviewed available documents on OPM’s processes to review and 

approve agencies’ requests to use certain special payment authorities, 

and analyzed OPM data to determine the average months it took OPM to 

make approval decisions on CHCO agency requests received from 

January 2009 through January 2017.13 We compared OPM’s procedures 

for collecting, analyzing, and providing information on the effective, 

strategic use of special payment authorities, and its procedures for 

 12The following agencies provided narrative descriptions: General Services Administration 

and the Departments of Health and Human Services, the Interior, and Veterans Affairs. 

The Federal Trade Commission did not respond.

13These special pay authorities include: special rates; critical position pay; and 

recruitment, retention, and relocation incentives that exceed certain payment thresholds.
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-18-91 Federal Pay

approving use of special payment authorities, to criteria identified in our 

related reports on federal human capital management and in Standards 

for Internal Control in the Federal Government, including standards that 

agency management design and implement controls and document 

procedures.

We conducted this performance audit from September 2016 to December 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Page 50 GAO-18-91 Federal Pay

1. Mission critical skills gaps are one or more of the following and may 

impede the federal government from cost-effectively serving the public 

and achieving results:

• staffing gap in which an agency has an insufficient number of 

individuals to complete its work; and/or a

• competency gap in which an agency has individuals without the 

appropriate skills, abilities, or behaviors to successfully perform 

the work.

Mission critical skills gaps may be identified broadly as affecting 

several agencies or may be specific to a given agency (such as 

mission-critical occupations agencies have identified to the Office of 

Personnel Management (OPM) for skills gap closure).

Note: We also provided definitions of the seven special payment 

authorities similar to their descriptions provided in table 1 of this report.

1. For the special pay authorities below, does your agency have agencyspecific guidance (including documented policies or plans) on the use 

of the special pay authorities below? (Check all that apply)

Yes, at the 

agency level

Yes, at subagency 

level(s) No

Special Rates ☐ ☐ ☐

Superior Qualifications & Special 

Needs Pay Setting ☐ ☐ ☐

Critical Position Pay ☐ ☐ ☐

Recruitment Incentives ☐ ☐ ☐

Retention Incentives ☐ ☐ ☐

Relocation Incentives ☐ ☐ ☐

Student Loan Repayment Program ☐ ☐ ☐

Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Section I: Definitions

Section 2: Use of Special 

Pay Authorities at Your

Agency
Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Page 51 GAO-18-91 Federal Pay

2. In the last three fiscal years (2014-2016), how many federal 

employees in your agency received compensation under the following 

special pay authorities? (if none, enter zero)

Number of 

employees

(FY 2014)

Number of 

employees

(FY 2015)

Number of 

employees

(FY 2016)

Special Rates

Superior Qualifications & 

Special Needs Pay Setting 

Critical Position Pay 

Recruitment Incentives

Retention Incentives

Relocation Incentives

Student Loan Repayment 

Program

3. In Fiscal Years 2014-2016, what was your agency’s total spending (in 

dollars) for the following special pay authorities?

FY2014 FY2015 FY2016

Agency has not 

used this 

authority

Recruitment 

Incentives ☐

Retention Incentives

☐

Relocation Incentives

☐

Student Loan 

Repayment Program ☐
Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Page 52 GAO-18-91 Federal Pay

4. In the last three fiscal years (2014-2016), how often has your agency 

experienced the following challenges related to using special pay 

authorities? 

Never Rarely Occasionally Regularly Always

Management 

resistance ☐ ☐ ☐ ☐ ☐

Unclear requirements ☐ ☐ ☐ ☐ ☐

Burdensome 

documentation ☐ ☐ ☐ ☐ ☐

Complex approval 

process ☐ ☐ ☐ ☐ ☐

Lack of clear benefits ☐ ☐ ☐ ☐ ☐

Insufficient resources 

(e.g. budget, staff) ☐ ☐ ☐ ☐ ☐

Other (please 

specify): ☐ ☐ ☐ ☐ ☐

5. In your opinion, how likely would changes in the following areas 

improve your agency’s ability to effectively utilize special pay 

authorities at your agency?

Not at 

all likely

Not very 

likely

Somewhat 

likely

Very

likely Certainly

OPM regulations ☐ ☐ ☐ ☐ ☐

OPM guidance ☐ ☐ ☐ ☐ ☐

Agency regulations ☐ ☐ ☐ ☐ ☐

Agency guidance ☐ ☐ ☐ ☐ ☐

Training for agency 

human resources/capital 

staff

☐ ☐ ☐ ☐ ☐

Training for agency 

managers ☐ ☐ ☐ ☐ ☐

Legislation ☐ ☐ ☐ ☐ ☐

Other (please specify):

☐ ☐ ☐ ☐ ☐
Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Page 53 GAO-18-91 Federal Pay

Instructions: If your agency utilized [this authority] during FY2014-2016, 

please complete this section, otherwise continue onto the next Section.

1. In Fiscal years 2014-2016, did your agency use [this authority] to 

support the following mission critical skills gap areas?

Yes No

Does not apply 

at my agency 

(not mission 

critical)

Acquisitions (e.g. Contract Specialist) ☐ ☐ ☐

Cybersecurity ☐ ☐ ☐

Healthcare Professionals (non-Title 38) ☐ ☐ ☐

Science, Technology, Engineering and 

Mathematics ☐ ☐ ☐

Human Resources Specialist ☐ ☐ ☐

Other agency-specific mission-critical 

occupation(s) (please specify): ☐ ☐ ☐

2. Does your agency assess the following to determine the effectiveness 

of using [this authority]?

Documented 

assessment

Informally 

assess

Do not 

assess

Impact on agency mission ☐ ☐ ☐

Impact on agency performance goals ☐ ☐ ☐

Impact on meeting staffing needs ☐ ☐ ☐

Impact on addressing mission critical 

skills gap areas ☐ ☐ ☐

Impact on employee performance ☐ ☐ ☐

Effectiveness relative to other human 

capital flexibilities (e.g., other special 

pay authorities, non-compensation 

flexibilities) 

☐ ☐ ☐

Agency workforce data (e.g., quit 

rate, attrition) ☐ ☐ ☐

Other (please specify):

☐ ☐ ☐

Sections 3-9: For each 

authority, respectively: (3) 

Special Rates; (4) 

Superior Qualifications & 

Special Needs Pay 

Setting; (5) Critical 

Position Pay; (6) 

Recruitment Incentives; 

(7) Retention Incentives; 

(8) Relocation Incentives; 

and (9) Student Loan 

Repayment
Appendix II: Special Payment Authorities 

Questionnaire Sent to Chief Human Capital 

Officer Agencies

Page 54 GAO-18-91 Federal Pay

3. In your opinion, how has the use of [this authority] impacted the 

following?

Very 

negatively

Somewhat 

negatively

No 

impact

Somewhat 

positively

Very 

positively

Staff retention ☐ ☐ ☐ ☐ ☐

Applicant quality ☐ ☐ ☐ ☐ ☐

Ability to meet 

staffing needs ☐ ☐ ☐ ☐ ☐

Ability to fill 

mission critical 

positions

☐ ☐ ☐ ☐ ☐

Continuity of 

operations ☐ ☐ ☐ ☐ ☐

Staff morale ☐ ☐ ☐ ☐ ☐

Ability to achieve 

agency mission ☐ ☐ ☐ ☐ ☐

Other (please 

specify): ☐ ☐ ☐ ☐ ☐

1. In what ways have special pay authorities helped your agency to 

successfully address mission critical skills gaps? (Please provide at 

least one specific example)

2. In what ways has your agency identified and responded to challenges 

related to the use of special pay authorities? (Please provide at least 

one specific example)

Section 10: Agencyspecific Examples of 

Special Pay Authorities 

Use
Appendix III: CHCO Agencies Reported Use of 

Special Payment Authorities Affecting 

Selected Areas of Operation

Page 55 GAO-18-91 Federal Pay

The following six tables present data on the responses reported by CHCO 

agencies on the impacts on selected areas of operation from using the 

following special payment authorities—superior qualifications, critical 

position pay, recruitment incentives, retention incentives, relocation 

incentives, and student loan repayment.

Table 8: CHCO Agencies Reported Impacts of Superior Qualifications on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of Superior Qualifications (N=22)

Somewhat and

Very Positively

No 

impact

Somewhat and Very 

Negatively

Staff retention 16 5 1

Applicant quality 15 6 1

Ability to meet staffing needs 17 4 1

Ability to fill mission critical 

positions

17 5 0

Continuity of operations 14 8 0

Staff morale 13 6 3

Ability to achieve agency 

mission

17 4 1

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

Table 9: CHCO Agencies Reported Impacts of Critical Position Pay on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of Critical Position Pay (N=4)

Somewhat and

Very Positively

No

impact

Somewhat and Very 

Negatively

Staff retention 4 0 0

Applicant quality 3 1 0

Ability to meet staffing needs 4 0 0

Ability to fill mission critical 

positions

4 0 0

Continuity of operations 3 1 0

Staff morale 3 1 0

Ability to achieve agency 

mission

3 1 0

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

Appendix III: CHCO Agencies Reported Use 

of Special Payment Authorities Affecting 

Selected Areas of Operation
Appendix III: CHCO Agencies Reported Use of 

Special Payment Authorities Affecting 

Selected Areas of Operation

Page 56 GAO-18-91 Federal Pay

Table 10: CHCO Agencies Reported Impacts of Recruitment Incentives on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of Recruitment incentives (N=various)

Somewhat and

Very Positively

No

impact

Somewhat and 

Very Negatively

Staff retentiona 14 8 0

Applicant qualitya 17 5 0

Ability to meet staffing needsb 21 2 0

Ability to fill mission critical 

positionsb 20 3 0

Continuity of operationsa 16 6 0

Staff moraleb 13 8 2

Ability to achieve agency 

missionb 19 4 0

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

a

22 agencies provided answers.

b

23 agencies provided answers.

Table 11: CHCO Agencies Reported Impacts of Retention Incentives on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of Retention Incentives (N=20)

Somewhat and 

Very Positively

No

impact

Somewhat and 

Very Negatively

Staff retention 19 1 0

Applicant quality 8 12 0

Ability to meet staffing needs 17 3 0

Ability to fill mission critical 

positions

17 3 0

Continuity of operations 17 3 0

Staff morale 11 7 2

Ability to achieve agency 

mission

19 1 0

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91
Appendix III: CHCO Agencies Reported Use of 

Special Payment Authorities Affecting 

Selected Areas of Operation

Page 57 GAO-18-91 Federal Pay

Table 12: CHCO Agencies Reported Impacts of Relocation Incentives on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of Relocation Incentives (N=19)

Somewhat and 

Very Positively

No

impact

Somewhat and 

Very Negatively

Staff retention 16 3 0

Applicant quality 14 5 0

Ability to meet staffing needs 16 3 0

Ability to fill mission critical 

positions

17 2 0

Continuity of operations 15 4 0

Staff morale 11 7 1

Ability to achieve agency 

mission

15 3 1

Source: GAO analysis of CHCO agency questionnaire responses. | GAO-18-91

Table 13: CHCO Agencies Reported Impacts of Student Loan Repayment Authority on Selected Areas, Fiscal Years 2014-2016

Agency area 

of operation

Number of agencies reporting impact of use of special rates (N=19)

Somewhat or 

very positively

No

effect

Somewhat or

very negatively

Staff retention 18 1 0

Applicant quality 13 6 0

Ability to meet staffing needs 17 2 0

Ability to fill mission critical 

positions

17 2 0

Continuity of operations 13 6 0

Staff morale 16 2 1

Ability to achieve agency 

mission

17 2 0

Source: GAO analysis of CHCO agency questionnaire responses. |GAO-18-91
Appendix IV: Office of Personnel Management 

Data on Use of Special Payment Authorities by 

Occupational Family

Page 58 GAO-18-91 Federal Pay

Our analysis of OPM data found that, overall, agencies used five special 

payment authorities—special rates; superior qualifications and special 

needs pay setting; and the recruitment, relocation, and retention (3R) 

incentives—to varying extents for different occupational families.1 When 

we analyzed OPM data to identify the top five occupational families for 

each of these five special payment authorities, we found certain 

occupational families appeared among the top groups for multiple 

authorities (see those highlighted in table 14). Specifically, we found that 

two occupational families—(1) Medical, Hospital, Dental, and Public 

Health; and (2) Engineering and Architecture—were among the top five 

families for four and five of these special payment authorities, 

respectively. The Medical family was the top occupational family for four 

of the five authorities—superior qualifications and special needs pay 

setting, and the 3R incentives. Further, we found that certain occupational 

families were among the top five for one or two authorities but not for the 

other authorities. For example, the Information Technology and 

Copyright, Trademark, and Patent occupational families were among the 

top five families for special rates and superior qualifications and special 

needs pay setting, but not for the other three authorities.

 1

We could not analyze OPM data to include critical position pay and the student loan 

repayment authority by occupational family. Instead, we analyzed the most recently 

available OPM reports for these two authorities. 

Appendix IV: Office of Personnel 

Management Data on Use of Special 

Payment Authorities by Occupational Family
Appendix IV: Office of Personnel Management 

Data on Use of Special Payment Authorities by 

Occupational Family

Page 59 GAO-18-91 Federal Pay

Table 14: Top Five Occupational Families with Most Frequent Government-wide Use for Selected Special Payment 

Authorities, Fiscal Year 2014 

Occupational family

Recruitment 

incentives

Relocation 

incentives

Retention 

incentives

Superior 

qualifications

and special 

needs pay 

setting

Special 

rates

Total 

number of 

employees 

per family

0000 – Miscellaneous Occupationsa 217 150 828 100 4,240 89,433

0100 – Social Science, Psychology, 

and Welfare

156 92 249 228 37 98,448

0300 – General Administrative, 

Clerical, and Office Services

681 222 162 653 108 332,705

0400 – Natural Resources 

Management and Biological 

Sciences

21 22 420 64 1,026 71,928

0600 – Medical, Hospital, Dental, 

and Public Health

1,816 483 3,920 1,159 2,820 274,272

0800 – Engineering and Architecture 410 350 301 1,056 4,626 130,335

1100 – Business and Industry 42 211 59 170 Less than 

10

98,925

1200 – Copyright, Patent, and 

Trademark

0 0 0 876 9,188 9,881

1500 – Mathematical Sciences 66 17 258 153 323 18,736

1800 – Inspection, Investigation, 

Enforcement, and Compliance

Less than 10 310 203 31 32 193,920

2100 – Transportation 17 12 51 51 3,049 44,870

2200 – Information Technology 37 41 143 684 14,211 82,063

All Other Occupational Familiesb 735 446 298 813 92 624,622

TOTAL 4,198c 2,356 6,892 6,038 39,752c 2,070,138

Source: GAO analysis of OPM Enterprise Human Resources Integration data. | GAO-18-91

Notes: Our analysis provides only a snapshot of a single fiscal year and the use of special payment 

authorities for occupational families may be influenced by pay and hiring trends.

Individuals who switched occupational families during the fiscal year would be counted twice if they 

received the same authority under both occupational families.

Gray shading denotes the top five occupational families with the most frequent use of each authority.

a

Miscellaneous occupations includes those positions that administer, supervise, or perform work that 

cannot be included in other occupational families either because the duties are unique, or are 

complex and come in part under various families.

b

Includes those occupational families that did not appear among the top five families with most 

frequent government-wide use for any of the selected authorities in fiscal year 2014.

c

Total number excludes cells with counts of less than 10.
Appendix V: Comments from the Office of 

Personnel Management

Page 60 GAO-18-91 Federal Pay

Appendix V: Comments from the Office of 

Personnel Management
Appendix V: Comments from the Office of 

Personnel Management

Page 61 GAO-18-91 Federal Pay
Appendix V: Comments from the Office of 

Personnel Management

Page 62 GAO-18-91 Federal Pay
Appendix VI: GAO Contact and Staff 

Acknowledgements

Page 63 GAO-18-91 Federal Pay

Yvonne D. Jones, Director, (202) 512-2717 or jonesy@gao.gov.

In addition to the contact named above, Signora May, Assistant Director; 

Ronald W. Jones, Analyst-in-Charge; Melinda Cordero, Ann Czapiewski, 

Sara Daleski, Christopher Falcone, Karin Fangman, Kerstin Hudon, John 

Hussey, Steven Putansu, Alan Rozzi, and Albert Sim contributed to this 

report.

Appendix VI: GAO Contact and Staff 

Acknowledgements

Contact

Staff 

Acknowledgments

(101147)
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