Audit Report

OIG-20-041

BILL AND COIN MANUFACTURING 

Mint Human Resources Practices Need 

Improvement 

 July 17, 2020 

Office of Inspector General

Department of the Treasury 
This Page Intentionally Left Blank
Contents 

Mint Human Resources Practices Need Improvement (OIG-20-041) i

Audit Report

Results in Brief .............................................................................................. 2

Background................................................................................................... 3 

Audit Results................................................................................................. 5 

The Mint Misassigned a Reemployed Annuitant Outside the Scope and 

Limitations of the Appointment ................................................................... 5 

Recommendation .................................................................................. 7 

The Mint Did Not Consistently Maintain Documentation of Personnel Actions... 8

Recommendations............................................................................... 11

Appendices

Appendix 1: Objectives, Scope, and Methodology........................................... 14 

Appendix 2: Summary of Complaints and Audit Results................................... 19

Appendix 3: Management Response.............................................................. 23

Appendix 4: Major Contributors to This Report............................................... 25

Appendix 5: Report Distribution.................................................................... 26

Abbreviations

ARC Bureau of the Fiscal Service’s Administrative Resource Center

DASHR/CHCO Deputy Assistant Secretary for Human Resources and Chief

Human Capital Officer 

e-OPF electronic Official Personnel Folder

EEO equal employment opportunity

GRS General Records Schedule 

GS General Schedule

HCAAF Human Capital Assessment and Accountability Framework

HCD Human Capital Directorate 

HCF Human Capital Framework

IRS Internal Revenue Service

Mint United States Mint

NDAA National Defense Authorization Act
Mint Human Resources Practices Need Improvement (OIG-20-041) ii

NARA National Archives and Records Administration

OIG Office of Inspector General

OPM Office of Personnel Management

SES Senior Executive Service

SF standard form

Treasury Department of the Treasury

WSD Workforce Solutions Department
Mint Human Resources Practices Need Improvement (OIG-20-041) 1

July 17, 2020 

David J. Ryder, Director 

United States Mint 

This report presents the results of our audit of human resources

practices at the Unites States Mint (Mint). We initiated this 

audit in response to four complaints received by our office that 

alleged, among other things, unethical and unfair hiring and 

promotion practices at the Mint.

The objectives of this audit were to (1) determine whether the

Mint conducted its human resources activities with respect to 

hiring for General Schedule (GS)-14, GS-15, and Senior 

Executive Service (SES)1 positions in accordance with federal 

and Department of the Treasury (Treasury) requirements and 

Mint policies and procedures and (2) assess the Treasury OIG 

Hotline complaints, alleging among other things, unfair and 

unethical human resource practices at the Mint. 

To accomplish our objectives, we (1) reviewed laws and 

regulations as well as Treasury and Mint policies and procedures 

related to human resources practices; (2) interviewed 

management and staff responsible for the hiring process; and 

(3) reviewed records of personnel actions, including files and

other documentation maintained for recruiting and promotions.

1

 Under the Civil Service Reform Act of 1978, SES members “...ensure that the executive 

management of the Government of the United States is responsive to the needs, policies, and 

goals of the Nation and otherwise is of the highest quality.” They serve in the key positions just 

below the top presidential appointees and are the major link between these appointees and the 

rest of the federal workforce. SES members operate and oversee nearly every government 

activity in approximately 75 federal agencies. Office of Personnel Management (OPM) manages 

the overall federal executive personnel program, providing the day-to-day oversight and 

assistance to agencies as they develop, select, and manage their federal executives.
Mint Human Resources Practices Need Improvement (OIG-20-041) 2 

We performed our fieldwork from August 2014 through March 

2015 with subsequent follow up through July 2018. 

Appendix 1 provides a more detailed description of our audit 

objectives, scope, and methodology.

Results in Brief

Although the Mint generally conducted its human resources

activities in accordance with federal and Treasury requirements, 

some improvements are needed. Specifically, we found that the 

Mint (1) misassigned a reemployed annuitant when it hired an 

annuitant for one position but then assigned the employee to 

another role outside the scope of the reemployed annuitant 

hiring authority, and (2) did not consistently maintain 

documentation of personnel actions and the related decisionmaking processes for new appointments and reassignments/ 

realignments. 

The four complaints received by our office contained 16

allegations, including human resources violations in the hiring 

and promotion processes, inappropriate assignment of a 

properly appointed reemployed annuitant, and general cronyism. 

Some complaints alleged poor communication from managers in 

the Workforce Solutions Department (WSD), which was 

responsible for the Mint’s human resources activities. During 

our audit scope period—October 1, 2011 through June 30, 

2014—WSD restructured its workforce three times. Several 

WSD staff told us that they did not understand the reasoning 

behind the reorganizations. We have summarized the allegations 

and our audit dispositions in appendix 2. 

We recommend that the Mint Director take action to: (1) ensure 

the Mint assigns reemployed annuitants in a manner consistent 

with the scope and limitations of the applicable appointment 

authorities, (2) ensure all required records are included in the 

electronic Official Personnel Folders (e-OPFs),2and (3) establish 

internal controls to properly manage and maintain all records 

related to the hiring and promotion processes. 

2

 The e-OPF system is maintained by the OPM as the electronic version of each federal employee’s 

official personnel folder.
Mint Human Resources Practices Need Improvement (OIG-20-041) 3 

In its response, Mint management concurs with our findings 

and recommendations. They are currently taking the 

necessary actions to address the recommendations outlined 

in this report. Management’s planned corrective actions meet 

the intent of our recommendations. The Mint’s management 

response, in its entirety, is provided in appendix 3.

Background

The Mint’s principal mission is to produce the nation’s 

circulation coinage for trade and commerce. The Mint also 

produces commemorative and investment products for 

collectors and investors. In addition to its headquarters in 

Washington, DC, the Mint has four production facilities located 

in Philadelphia, Pennsylvania; West Point, New York; Denver, 

Colorado; and San Francisco, California. It also maintains the 

U.S. bullion depository at Fort Knox, Kentucky.

Personnel Management

In the Federal Government, the Office of Personnel Management 

(OPM) has the authority to (1) manage personnel functions, 

which may be delegated by the Director of OPM to the heads of 

executive branch agencies that employ individuals in the 

competitive service; (2) establish standards that will apply to 

the activities of OPM or any delegated agencies; and 

(3) establish and maintain an oversight program to ensure that 

personnel management activities are carried out in accordance 

with the Merit System Principles.3

The United States Merit Systems Protection Board is an 

independent, quasi-judicial agency in the executive branch that 

serves as the guardian of federal merit systems. The board’s 

mission is to "protect the Merit System Principles and promote 

an effective federal workforce free of Prohibited Personnel 

Practices." The Merit System Principles are nine basic standards 

governing the management of the executive branch workforce

to ensure that the Federal Government is able to recruit, select, 

develop, and maintain a high-quality workforce to reduce 

 3

 5 U.S.C. 1104, Delegation of authority for personnel management (November 19, 1995) 
Mint Human Resources Practices Need Improvement (OIG-20-041) 4 

staffing costs and improve organizational results. The Prohibited 

Personnel Practices are specific behaviors that undermine the 

Merit System Principles and limit the effectiveness and 

efficiency of the federal workforce.

Treasury Human Resources and Chief Human Capital Officer

Treasury Directive 12-31 delegates the authority for decisions 

on personnel management matters to the Deputy Assistant 

Secretary for Human Resources and Chief Human Capital 

Officer (DASHR/CHCO).

4 The DASHR/CHCO is responsible for 

Treasury-wide policy and oversight in all areas of human capital

management.

5 The DASHR/CHCO’s mission is to develop and 

manage innovative human capital business practices to help 

supervisors, managers, and employees with workforce 

productivity, diversity, leadership effectiveness, and individual 

development.

The DASHR/CHCO is also responsible for implementing policies 

governing the creation, development, maintenance, processing, 

use, dissemination, and safeguarding of personnel records 

detailed in federal statute.

6 OPM requires agencies to 

(1) maintain personnel records in the personnel management or

personnel policy setting process, and (2) recognize the format 

of the official personnel folder as the official record in either 

paper or electronic format.

7 The e-OPF system should, among 

other things, be thoroughly documented and able to produce 

legible paper copies of all records.

 4

 Treasury Directive 12-31, Delegation of Personnel Authority to Deputy Assistant Secretary for 

Human Resources and Chief Human Capital Officer (December 15, 2009, Reaffirmed January 27, 

2017) 5 Human capital management includes employment and staffing, compensation, benefits, executive 

resources, succession planning, labor and employee relations, workforce development, performance 

management, diversity management, equal employment opportunity, and other human capital 

functions. 6 5 CFR 293.101, Purpose and scope (November 9, 1979) 7 Office of Personnel Management Operating Manual, The Guide to Personnel Recordkeeping,

Update 13 (June 1, 2011)
Mint Human Resources Practices Need Improvement (OIG-20-041) 5 

Workforce Solutions Department 

During the scope of this audit, WSD performed the human 

resources activities at the Mint.8 In addition to overseeing 

recruitment, hiring, and promotion activities, WSD was 

responsible for administering the full range of human resource 

programs available to Mint employees. 

Administrative Resource Center

The Mint uses the Bureau of the Fiscal Service’s Administrative 

Resource Center (ARC) for human resources services. The 

services include, among other things, payroll accounting 

services, payroll processing, employee benefits services, 

personnel recordkeeping, position classification services, and 

staff acquisition services.

Audit Results

Finding 1 The Mint Misassigned a Reemployed Annuitant Outside 

the Scope and Limitations of the Appointment

The Mint improperly reassigned a reemployed annuitant 

appointed under the National Defense Authorization Act (NDAA) 

for Fiscal Year 2010.9 Under this law, agencies may reemploy 

federal retirees to meet mission-critical needs, assist with 

emergency hiring and difficult recruiting, and retain individuals 

with a unique skill set or who serve on a critical project. When 

an annuitant is reemployed, either the annuity terminates or the 

annuity continues and the individual’s salary is offset by the 

amount of the annuity. A dual compensation waiver, allowing 

the retiree to retain their annuity and receive a full salary, may

be granted by OPM on a case-by-case basis.10 During the scope 

of our audit, the Mint properly requested three dual 

compensation waivers. 

 8

 WSD transitioned to become the Human Capital Directorate (HCD) in 2017. 9

 Public Law 111-84, National Defense Authorization Act for Fiscal Year 2010, Title XI, Civilian 

Personnel Matters, Subtitle B, Provisions Relating to Reemployment of Annuitants (October 28, 

2009) 10 5 CFR 553.201, Requesting OPM approval for reemployment without reduction or termination of 

annuity in individual cases (September 19, 2007)
Mint Human Resources Practices Need Improvement (OIG-20-041) 6 

In one of the three cases in which the Mint hired an annuitant, 

according to the complaints, the Mint hired the annuitant as a 

senior advisor to assist in policy writing. This employee was 

later assigned to serve as an acting director, a role outside of 

the scope of their reemployed annuitant status and the initial 

intended use of the annuitant’s skill set. This action was 

contrary to the intent of the reemployed annuitant hiring 

authority, which outlines the circumstances in which an 

annuitant may be hired—namely, to fill an emergency hiring 

need or for unique projects. The acting director position to 

which the reemployment was assigned following the original 

appointment did not meet any of these criteria. 

Additionally, an evaluation conducted by the Office of the 

DASHR/CHCO reported the same misassignment.

11 The report 

focused on the Mint’s talent management by assessing the 

effectiveness of recruitment and retention of qualified 

employees. As part of the evaluation, 22 delegated examining 

positions were reviewed, including two reemployed annuitants. 

The Human Capital Assessment and Accountability Framework

(HCAAF)

12 evaluation found that the Mint only “Partially Met” 

the critical assessment that: 

Recruitment, hiring, and merit promotion processes adhere to 

the merit system principles in 5 U.S.C. 2301 and follow 

other pertinent legal and regulatory requirements, including 

other congressionally mandated enabling legislation. 

Specifically, one of the reemployed annuitants reviewed, who is 

also referenced above, was being used “in a supervisory 

capacity outside of the scope of the NDAA and contradictory to

guidance received by the Mint from Treasury Headquarters.” 

The annuitant had been listed as the Acting Chief within WSD

on quarterly workforce documents distributed to managers

Mint-wide. Mint management claimed during the HCAAF audit; 

however, that “the annuitant did not perform in a supervisory 

capacity.”

 11 Treasury DASHR/CHCO, Human Capital Assessment and Accountability Framework (HCAAF) 

Evaluation, (October 15, 2014) 12 OPM replaced the HCAAF with the Human Capital Framework (HCF) on April 11, 2017.
Mint Human Resources Practices Need Improvement (OIG-20-041) 7 

Mint management reasserted, for our audit, that the annuitant 

did not act in any supervisory capacities. They stated that 

administrative duties previously performed and authorized by 

the former department director had been designated to upper 

management, not to the annuitant. However, we found that 

management had appointed the annuitant to acting director, 

reported the role in the human resources system, and 

communicated the role to the staff who report to the acting 

director. In addition, emails imply that the annuitant conducted 

performance appraisals for at least two subordinate employees 

while serving as the acting director. 

In changing the reemployed annuitant's duties, the Mint was 

non-compliant with the requirements of the NDAA for Fiscal 

Year 2010 and 5 CFR Part 553.201. The placement of the 

annuitant in the supervisory role also caused confusion among 

the WSD employees because the annuitant’s role was not 

properly communicated to them. Initially it was communicated 

that the annuitant was a policy specialist but shortly after she 

was hired, she became their de facto supervisor. 

Recommendation

We recommend the Director of the Mint:

1. Ensure that reemployed annuitants are assigned to 

positions consistent with the scope and limitations of the 

authority under which they are appointed. If future use of 

reemployed annuitants is sought, we recommend that the

Mint ensure employees appointed under the current 

NDAA are assigned consistent with the scope and 

limitations of those requirements.

13

 13 On December 20, 2019, President Trump signed the NDAA for Fiscal Year 2020, Public Law 

116-333, which re-extended the reemployed annuitant hiring authority under the NDAA for Fiscal 

Year 2015, Public Law 111-291, effective October 28, 2014 through December 31, 2019. The 

reemployed annuitant hiring authority was established under the NDAA for Fiscal Year 2010, 

Public Law 111-84, effective October 28, 2009 through October 27, 2014. 
Mint Human Resources Practices Need Improvement (OIG-20-041) 8 

Management Response

Mint management concurs with this finding and reaffirms 

its commitment to ensuring that appropriate hiring 

authorities are consistently and uniformly utilized in 

accordance with all laws, regulations, and policies. The 

Mint has recently appointed a new executive who has 

begun the process of evaluating the current Human 

Capital Directorate (HCD) and is fully engaged in making 

further improvements to ensure greater efficiencies and 

effectiveness in all hiring and staffing processes. 

In addition, the HCD will ensure human resources 

employees responsible for appointing reemployed 

annuitants are trained in the scope and limitations of how 

these reemployed annuitants may be assigned following 

appointment. The Mint will also ensure that annual 

Human Capital Framework (HCF) evaluations will include 

a thorough review of appointments in which the 

reemployed annuitant hiring authority was utilized for 

compliance with the NDAA. 

OIG Comment

 

Mint management’s response meets the intent of our 

recommendation.

Finding 2 The Mint Did Not Consistently Maintain Documentation 

of Personnel Actions

The Mint did not consistently maintain documentation of

personnel actions. OPM provides guidance to federal agencies 

on how to process personnel actions14 in accordance with 

federal statute.15 Furthermore, OPM requires that each agency 

ensure that the e-OPF system, among other things, be 

 14 Office of Personnel Management Operating Manual, The Guide to Processing Personnel Actions, 

Update 54 (March, 1, 2011). The Guide to Processing Personnel Actions was revised by OPM 

subsequent to the scope of our audit. The updates reflected through the last revision issued 

March 5, 2017, do not change the results of our audit. 15 5 CFR 250.101, Standards and requirements for agency personnel actions (December 27, 2001)
Mint Human Resources Practices Need Improvement (OIG-20-041) 9 

thoroughly documented and able to produce legible paper copies 

of all records.

16

We reviewed the personnel actions for the GS17-14, GS-15, and 

SES positions initiated from October 1, 2011 through June 30, 

2014. We used a non-statistical methodology and selected 73 

personnel actions, excluding bargaining employees because of 

different criteria and requirements. For these personnel actions, 

we tested 65 e-OPF18 records, which included 24 new 

appointments, 4 promotions, 16 demotions,19 1 termination, 

and 20 reassignments/ realignments as well as recruiting 

records from 36 CareerConnector20 files. We reviewed the 

applicable e-OPFs, CareerConnector, and other hiring 

documentation, which was not sufficient to provide a complete 

understanding of some of the personnel decisions.

• A Standard Form (SF)-52, Request for Personnel Action,

21

was not in the e-OPF for 14 of the 65 (22 percent) 

personnel actions. 

 16 Office of Personnel Management Operating Manual, The Guide to Personnel Recordkeeping, 

Update 13 (June 1, 2011) 17 The GS classification and pay system covers most civilian white-collar federal employees in 

professional, technical, administrative, and clerical positions and has 15 grades. Agencies 

establish the grade of each job series based on the level of difficulty, responsibility, and 

qualifications required. Each grade has 10 steps, and within-grade or step increases can be given 

at intervals of 1, 2, or 3 years. 18 Eight (3 terminations and 5 reassignments/realignments) of the 73 e-OPFs were not available for 

review because the Mint employees transferred to another federal agency or resigned. Therefore, 

we tested 65 personnel actions. 19 The 16 demotions reflected employees who returned to lower grade positions at the end of 

temporary promotions. 20 CareerConnector is Treasury’s talent acquisition solution, providing Federal hiring software and 

associated services purchased through Monster Government Solutions. With Career Connector, 

Federal agencies can recruit, evaluate, assess, review, select, and on-board candidates received 

from USAJobs. The CareerConnector files we reviewed related to 24 new hires, 4 promotions, 

and 8 reassignments/realignments. 21 Supervisors and managers use the SF-52 to request (1) position actions, such as the 

establishment of a new position or the reclassification of an existing position; (2) employee 

actions, such as an appointment or promotion; and (3) actions involving both a position and an 

employee, such as the establishment and filling of a position or the reclassification of a position 

and reassignment of an employee to the reclassified position.
Mint Human Resources Practices Need Improvement (OIG-20-041) 10

• The SF-50, Notification of Personnel Action,

22 was not in 

the e-OPF for 6 of the 65 (9 percent) of the personnel 

actions. 

• The evaluation panel records for 9 of the 24 (38 percent) 

new appointments and 5 of the 20 (25 percent) 

reassignments/realignments were not available. 

• The selection memoranda were not available for 18 of the 

24 (75 percent) new appointments.

According to Treasury guidance,23 bureaus must use the 

General Records Schedule (GRS), issued by National Archives 

and Records Administration (NARA), for administrative records, 

but can request deviations. The heads of bureaus must ensure 

that their respective bureaus and offices develop, implement, 

and maintain a continuous record disposition program consistent 

with the provisions of federal records regulations. 

Although, Mint management told us that they follow NARA for 

record disposition, the Mint did not comply with the following

requirements of the NARA GRS: 

• Schedule number24 N1-GRS-79-2, Item 1, which requires 

that records related to the promotion of an individual (and

that document qualification standards, evaluation 

methods, selection procedures, and evaluations of 

candidates) be destroyed after an OPM audit or 2 years 

after the personnel action is completed, whichever is 

sooner. 

• Schedule number NC1-64-77-10, Item 8, which requires 

that correspondence related to interviews should be 

destroyed 6 months after the separation or transfer of an 

employee. 

 22 The SF-50 documents a personnel action that affects the federal employee’s position or pay. 23 Treasury Directive Publication TD P 80-05, Records and Information Management Manual

(June 27, 2002). TD P 80-05 was revised by Treasury subsequent to the scope of our audit. The 

updates reflected through the last revision issued January 31, 2018, do not change the results of 

our audit. 24 NARA assigns a unique identifier to a category of records indicating that their disposition has 

been approved by NARA. This is also known as the schedule number.
Mint Human Resources Practices Need Improvement (OIG-20-041) 11

Mint management told us that:

• ARC, the Mint’s service provider, is responsible for 

uploading documents into the e-OPFs; however, 

according to OPM, the Mint is responsible for maintaining 

the e-OPFs. 

• They do not maintain paper copies of the SF-52 and SF50 after providing them to ARC to upload to the e-OPFs. 

• Evaluation panel records were not maintained because 

there was no clear policy for record retention. The 

selection memoranda were not available because of an 

oversight (1) in records management or (2) during the 

hiring process.

The DASHR/CHCO HCAAF Evaluation referenced in finding 1, 

also reported that the Mint was not reviewing its e-OPFs. As 

part of the evaluation, 3 case files were reviewed. The HCAAF 

evaluation found that several Mint employees either did not 

have e-OPFs or the personnel documentation included in the eOPFs was not complete or accurate. Consequently, the HCAAF

evaluation determined that the Mint had “Not Met” the 

“Personnel action (SF-50) processing, Official Personnel Folder 

maintenance, and other administrative activities conform to 

regulatory and legal requirements” portion of the review.

Because Mint management did not ensure that the e-OPFs were 

complete and documentation of personnel actions was properly 

maintained, there is not an adequate audit trail of the hiring and 

promotion processes. Additionally, for a new appointment, such 

documentation may be needed if an unsuccessful job applicant 

files a complaint.

Recommendations 

We recommend the Director of the Mint work with ARC to: 

2. Ensure all required records are included in the e-OPFs. 
Mint Human Resources Practices Need Improvement (OIG-20-041) 12

Management Response

Mint management concurs with this finding and will 

continue to work with ARC to ensure required records are 

included in employees’ e-OPF files.

OIG Comment

Mint management’s response meets the intent of our 

recommendation.

3. Establish internal controls to ensure all records related to 

the hiring and promotion processes are properly managed 

and maintained. 

Management Response

Mint management concurs with this finding and is 

committed to establishing more effective 

communication with ARC to ensure all appropriate 

personnel documentation is submitted timely for 

processing. The Mint looks to ARC as an important 

business partner and will explore additional efforts to 

effectuate improvements to include audits of e-OPFs 

during HCF Talent Management evaluations. 

The HCD has also established a policy that requires all 

supervisors record selections in CareerConnector, 

currently utilized by Treasury, to include documentation 

of the interview process. These records will be reviewed 

during HCF Talent Management evaluations. 

OIG Comment

Mint management’s response meets the intent of our 

recommendation.
Mint Human Resources Practices Need Improvement (OIG-20-041) 13

* * * * * *

We appreciate the cooperation and courtesies extended to our staff 

during the audit. If you wish to discuss the report, you may 

contact me at (202) 927-8783. For major contributors to this 

report, see appendix 4, and for report distribution, see appendix 5. 

 /s/

Katherine E. Johnson

Audit Director 
Appendix 1

Objectives, Scope and Methodology

Mint Human Resources Practices Need Improvement (OIG-20-041) 14

The objectives for this audit were to (1) determine whether the 

United States Mint (Mint) conducted its human resources 

activities with respect to hiring for General Schedule (GS)-14, 

GS-15, and Senior Executive Services (SES) positions in 

accordance with federal and Department of the Treasury 

(Treasury) requirements and Mint policies and procedures and 

(2) assess the Treasury OIG Hotline complaints, alleging among 

other things, unfair and unethical human resource practices at 

the Mint. 

To accomplish our objectives, we identified the legal authorities 

used by the Mint to conduct its human resources operations. 

We reviewed the following laws, regulations, and guidance 

associated with personnel actions, including recruitment, 

promotions, demotions, reassignments/realignments, and 

separations:

• 5 U.S.C. 1104, Delegation of authority for personnel 

management (November 19, 1995)

• 5 U.S.C. 2301, Merit systems principles 

• 5 U.S.C. 2302, Prohibited personnel practices

• Public Law 107-174, Notification and Federal Employee 

Antidiscrimination and Retaliation Act of 2002 (May 15, 

2002)

• Public Law 111-84, National Defense Authorization Act 

for Fiscal Year 2010, Title XI, Civilian Personnel Matters, 

Subtitle B, Provisions Relating to Reemployment of 

Annuitants (October 28, 2009)

• Public Law 113-291, Carl Levin and Howard P. "Buck" 

McKeon, National Defense Authorization Act for Fiscal 

Year 2015, Title XI, Civilian Personnel Matters, Section 

1107, Extension of part-time reemployment authority

(December 19, 2014) 

• Public Law 116-333, National Defense Authorization Act 

for Fiscal Year 2020, Title XI, Civilian Personnel Matters, 

Section 1117, Extension of Authority for Part-Time 

Employment (December 20, 2019) 
Appendix 1

Objectives, Scope and Methodology

Mint Human Resources Practices Need Improvement (OIG-20-041) 15

• 5 CFR 293.101, Purpose and scope (November 9, 1979) 

• 5 CFR 250.101, Standards and requirements for agency 

personnel actions (December 27, 2001)

• 5 CFR 553.201, Requesting OPM approval for 

reemployment without reduction or termination of annuity 

in individual cases (September 19, 2007) 

• National Archives and Records Administration General 

Records Schedules, Transmittal 22 (April 2010)

• Office of Personnel Management Operating Manual, The 

Guide to Processing Personnel Actions, Update 54 

(March 1, 2011). 

• Office of Personnel Management, The Guide to Personnel 

Recordkeeping, Update 13 (June 1, 2011)

• Treasury Directive Publication TD P 80-05, Records and 

Information Management Manual (June 27, 2002)

• Treasury Memorandum for United States Mint Human 

Resources Specialists, United States Mint Staffing 

Policies (November 14, 2008)

• Treasury Directive 12-31, Delegation of Personnel 

Authority to Deputy Assistant Secretary for Human 

Resources and Chief Human Capital Officer

(December 15, 2009, Reaffirmed January 27, 2017)

• Treasury Directive 12-41, Delegation of Authority 

Concerning Equal Employment Opportunity (EEO) 

Programs and Treasury Complaint Center (TCC) (June 8, 

2010)

• Treasury Directive 67-01, Collection and Safeguard 

Requirements for Ethnicity, Race, and Disability Data

(May 6, 2014)

• Treasury Deputy Assistant Secretary for Human 

Resources and Chief Human Capital Officer 

(DASHR/CHCO), Human Capital Assessment and 

Accountability Framework (HCAAF) Evaluation

(October 15, 2014) 
Appendix 1

Objectives, Scope and Methodology

Mint Human Resources Practices Need Improvement (OIG-20-041) 16

• Mint-Wide Policy Memo HR-40, Disciplinary or Adverse 

Action for Employees Who Violate Antidiscrimination and 

Whistleblower Protection Laws (February 12, 2010)

• Mint Directive 335.B, Chapter 6, Human Resources 

Management, Promotion and Internal Placement for 

Bargaining and Non-Bargaining Unit Positions

(October 2001)

• Mint Directive 337.C, Chapter 6, Human Resources 

Management, Competitive Examining–Category Rating

(October 2010)

• Mint Directive 1614-002, Chapter 5, Equal Employment 

Opportunity, Prevention of Unlawful Harassment

(September 2013)

• Mint Directive1614-003, Chapter 5, Equal Employment 

Opportunity, Part A Management, Prevention of Unlawful 

Sexual Harassment (September 2013)

We interviewed Mint management and staff responsible for Mint 

personnel actions. During these interviews, we obtained an 

understanding of the hiring and promotion processes and the 

overall Mint work environment.

To address the four complaints of unethical and unfair hiring 

and promotion practices at the Mint received by our office, we 

reviewed the personnel actions for the GS-14, GS-15, and SES 

positions initiated during our audit scope period—October 1, 

2011 through June 30, 2014. We used a non-statistical 

methodology and selected 73 personnel actions, including 24 

new appointments, 4 promotions, 16 demotions, 

4 terminations, and 25 reassignments/realignments. This 

selection excluded bargaining employees because of different 

criteria and requirements.
Appendix 1

Objectives, Scope and Methodology

Mint Human Resources Practices Need Improvement (OIG-20-041) 17

For these personnel actions, we reviewed 65 electronic Official 

Personnel Folders (e-OPFs) 25 records, as well as recruiting 

records from 36 CareerConnector files.26 Specifically, we 

reviewed the e-OPF documentation, including the vacancy 

announcements, certificates of eligibility, the Standard Form 

(SF)-50 and SF-52, and other supporting documentation. In 

CareerConnector, we reviewed job announcement data, position 

descriptions, job applications, candidate evaluation criteria, and 

candidate selection data. Mint management also provided the 

approving officials’ and evaluation panels’ records for all hiring 

and reassignment actions, as well as the personnel management 

advisory committee and/or hiring freeze waivers for all hiring, 

permanent promotion, reassignment, and realignment personnel 

actions. 

We also reviewed all Equal Employment Opportunity (EEO)

27 and

Notification and Federal Employee Antidiscrimination and 

Retaliation Act of 2002 (No FEAR Act)28 complaints alleging 

unfair Mint hiring and promotion practices. Mint employees in 

GS-14 positions and above filed 12 EEO complaints from 

October 1, 2011 through June 30, 2014. None of the EEO 

complaints we reviewed involved improper hiring practices at 

the Mint. 

We assessed the reliability of the Mint’s data by (1) performing 

electronic testing of required data elements, (2) reviewing 

existing information about the data and the system that 

produced them, and (3) interviewing agency officials 

 25 Eight (3 terminations and 5 reassignments/realignments) of the 73 e-OPFs were not available for 

review because the Mint employees transferred to another federal agency or resigned. Therefore, 

we tested 65 personnel actions. 26 The CareerConnector files we reviewed related to 24 new hires, 4 promotions, and 8 

reassignments/realignments. 27 A federal employee or job applicant, who believes that a federal agency has discriminated against 

them, has a right to file a complaint, generally within 45 days from the day the discrimination 

occurred. 28 Public Law 107-174, the No FEAR Act became effective on October 1, 2003 and imposes 

additional duties upon Federal agency employers intended to reinvigorate their longstanding 

obligation to provide a work environment free of discrimination and retaliation.
Appendix 1

Objectives, Scope and Methodology

Mint Human Resources Practices Need Improvement (OIG-20-041) 18

knowledgeable about the data. In addition, we traced data 

provided to us back to source documents. 

Although we could not independently verify the reliability of all 

this data due to some missing documentation (see finding 2 for 

details), we compared it with other available supporting 

documents to determine data consistency and reasonableness. 

For these efforts, we believe the information we obtained is 

sufficiently reliable for this report.

We performed our fieldwork from August 2014 through 

February 2015 at the Mint Headquarters in Washington, DC.

We also conducted a subsequent follow up through July 2018.

We conducted this performance audit 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. 
Mint Human Resources Practices Need Improvement (OIG-20-041) 19

Appendix 2

Summary of Complaints and Audit Results

The results of our audit of the 16 allegations made in the 4 

anonymous complaints are as follows:

Allegation Results

Leaders do not 

communicate 

effectively. 

The United States Mint (Mint) employees told us that Mint 

leadership does not communicate well. For example, the 

Mint staff did not understand (1) the Workforce Solutions 

Department (WSD) reorganizations and (2) why certain 

managers were removed from their positions. Although 

poor communication is not effective leadership, we did 

not find evidence of any violation of federal or Department 

of the Treasury (Treasury) regulations or of intent by 

management to create a hostile working environment.

Senior management is 

aware of, but does not 

resolve, staff 

complaints.

Although Mint senior management acknowledged the 

complaints, the employees told us that the issues are not 

resolved because of a lack of communication.

Telework policies are 

unsatisfactory. 

Several WSD employees told us that they were upset 

when the telework policy was changed. Full-time telework 

was previously available, but under the revised policy, 

employees are required to come into the office at least 1 

day per week. They believed the policy change was unfair 

because some long-distance employees were still allowed 

to work remotely on a full-time basis. However, we found 

no violation of federal or Treasury regulation. Telework is 

an employee privilege and is available at management’s 

discretion.
Appendix 2

Summary of Complaints and Audit Results

Mint Human Resources Practices Need Improvement (OIG-20-041) 20

Allegation Results

Internal Revenue Service 

(IRS) affiliates were 

preselected.29

In our testing, we found that IRS affiliates, including 

reemployed annuitants, were selected for (1) noncompetitive positions and (2) non-competitive, temporary 

appointments. For Senior Executive Service (SES) 

positions, lateral transfers are allowable on a noncompetitive basis. We also noted that, in several of the 

competitive positions, evaluation panel records and other 

documentation was not available to evaluate candidate 

rankings. Finding 2 in the report discusses the lack of 

documentation in detail.

WSD leadership hired IRS 

employees without 

competition to fill new 

Mint positions.

The Mint used its reemployed annuitant hiring authority to 

fill temporary positions. Under the National Defense 

Authorization Act for Fiscal Year 2010, the Mint may fill 

certain non-competitive, limited-term positions by sending 

justifications to the senior management advisory 

committee. Finding 1 in the report discusses the 

inappropriate assignment of a properly appointed 

reemployed annuitant in detail.

Selection of IRS officials 

hurt morale and 

productiveness.

Based on our Mint staff interviews, employee morale 

has been impacted by the hiring of former IRS officials. 

However, we did not find evidence of any violation of 

federal or Treasury regulations.

Equal Employment 

Opportunity (EEO) 

complaints are not 

handled by the Mint until 

they become formal EEO 

filings. 

Based on our review of the 12 EEO complaints from 

October 1, 2011 through June 30, 2014, we found that 

the Mint handled complaints in the informal process 

prior to the complainants filing formal EEO complaints 

through the Deputy Assistant Secretary for Human 

Resources and Chief Human Capital Officer

(DASHR/CHCO). However, in all 12 cases, alternative 

dispute resolutions offered in the informal process were 

either rejected by the complainants or had failed and the 

complainants elected to file formal complaints, or the 

complainant simply filed a formal complaint.

 29 Preselection is defined as knowing in advance who they are going to select and following through 

regardless of the qualifications of other applicants. (Preserving the Integrity of the Federal Merit 

Systems: Understanding and Addressing Perceptions of Favoritism, December 2013). Preselection is 

unlawful where a decision maker intentionally grants an unauthorized preference or advantage to a 

candidate. Preselection requires evidence that the hiring process was manipulated with the intent of 

improving or injuring a particular person’s chances of selection.
Appendix 2

Summary of Complaints and Audit Results

Mint Human Resources Practices Need Improvement (OIG-20-041) 21

Allegation Results

Unqualified individuals 

were hired into senior 

leadership positions.

Our testing showed that qualified candidates were 

selected for some non-competitive positions. However, 

for several competitive positions, evaluation panel 

records and other documentation was not available to 

evaluate candidate qualifications. Finding 2 in the report 

discusses the lack of documentation in detail.

Executive core 

qualifications (ECQs) 

were written for a Mint 

SES employee before 

joining the Mint.

Based on our review of the Office of Personnel 

Management (OPM) guidance, we found (1) OPM, not 

the Mint, prescribes the ECQs based on the position, and 

(2) no evidence that the ECQ requirements were revised 

by the Mint to favor a SES candidate. 

Mint employees have 

not had the opportunity 

to compete or advance 

for any of the General 

Schedule (GS)-15 

positions because 

positions were offered 

to IRS candidates.

Our testing showed that at least three GS-15 positions 

were announced during our audit scope period 

(October 1, 2011 through June 30, 2014), and non-IRS 

candidates were competitively selected for all of them.

Employees were 

improperly demoted.

The complaints alleged that two non-WSD managers 

were demoted because of their involvement in a specific 

contract. We found that one manager left the Mint and 

the other manager was laterally transferred within grade, 

which is not a demotion. In addition, a GS-15 WSD 

manager was also laterally transferred to a GS-15 

position with different job responsibilities after 

completing a detail at another agency.

A disproportionate 

number of African 

American leaders have 

been demoted.

We found that none of the Mint employees named in the 

complaints were demoted. Instead, one manager left the 

Mint and two other managers were laterally transferred 

to new positions. Two of the three managers were 

African Americans; however, we found no evidence that 

the transfers were motivated by racial discrimination.
Appendix 2

Summary of Complaints and Audit Results

Mint Human Resources Practices Need Improvement (OIG-20-041) 22

Allegation Results

Complaints made by 

Caucasian employees 

are resolved more 

quickly than those made 

by African Americans.

We found no evidence to support this allegation. The 

only correlations we noted were based on the 

circumstances of the cases. Such as, if the EEO 

complainant elected to request an Equal Employment 

Opportunity Commission hearing, the timeline for 

resolution was longer than if a settlement was reached. 

However, our testing was limited to positions at the GS14 level and above. We are not making any assertion for 

positions at the GS-13 level or below. Furthermore, if no 

EEO complaint was filed we did not receive information 

on the details of how complaints were resolved so we 

would not have insight into any informal complaints. 

Unfair advantage was 

given in the promotion 

of an employee to GS14.

The complaints stated that an employee was given an 

unfair advantage to fill a GS-14 vacancy in WSD. 

Specifically, because the employee was not qualified to 

fill the vacancy, another GS-14 employee’s 

responsibilities were given to the named GS-13 employee 

prior to the announcement to allow the GS-13 employee 

to be more competitive for the GS-14 vacancy. However, 

we found insufficient evidence that the employee was 

given an unfair advantage.

The Mint has an 

excessive number of 

GS-15 and SES level 

managers given its small 

size. 

During our audit, we did not analyze job classifications so 

we cannot assess the appropriate level of leadership

positions. However, the Mint justified its WSD 

reorganizations by attempting to streamline and reduce 

the number of leadership positions. Ultimately, the total 

number of GS-15 and SES positions did not decrease.

Many EEO complaints 

center on discrimination.

From October 1, 2011 through June 30, 2014, 9 of the 

12 complaints tested alleged discrimination based on 

age, sex, race, color, or some combination of those 

factors. 
Appendix 3

Management Response

Mint Human Resources Practices Need Improvement (OIG-20-041) 23
Appendix 3

Management Response

Mint Human Resources Practices Need Improvement (OIG-20-041) 24
Appendix 4

Major Contributors to This Report

Mint Human Resources Practices Need Improvement (OIG-20-041) 25

Kiira M. Jones, Auditor-in-Charge

Justin D. Summers, Program Analyst 

Justin M. Walker, Auditor

Shaneasha Edwards, Referencer 
Mint Human Resources Practices Need Improvement (OIG-20-041) 26

Appendix 5

Report Distribution

The Department of the Treasury

Secretary 

Deputy Secretary 

Treasurer 

Office of Strategic Planning and Performance Improvement

Office of the Deputy Chief Financial Officer, Risk and Control

 Group

United States Mint

Chief Administrative Officer

Director of Human Capital

Audit Liaison

Office of Management and Budget

Office of Inspector General Budget Examiner

U.S. Senate

Chairman and Ranking Member 

Committee on Banking, Housing, and Urban Affairs

U.S. House of Representatives 

Chairman and Ranking Member 

Committee on Financial Services

Chairman and Ranking Member 

Subcommittee on National Security, International Development, 

and Monetary Policy
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