FEDERAL 

RETIREMENT

OPM Actions Needed 

to Improve Application 

Processing Times

Report to Congressional Requesters

May 2019

GAO-19-217

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-19-217, a report to 

congressional requesters

May 2019

FEDERAL RETIREMENT

OPM Actions Needed to Improve Application 

Processing Times

What GAO Found

The Office of Personnel Management (OPM), which administers the federal 

retirement program, identified three root causes for retirement processing delays: 

1. the continuing reliance on paper-based applications and manual processing;

2. insufficient staffing capacity, particularly during peak workload season; and

3. incomplete applications. 

OPM has taken various actions to address these root causes and thereby reduce

delays. 

Vision for modernizing retirement processing. OPM’s strategic vision 

consists of five key initiatives for modernizing the application process, including 

developing an electronic application form and an electronic system to store 

retirement information. However, OPM was unable to provide estimated time 

frames or costs for the initiatives. OPM officials said that additional information 

technology (IT) modernization work is dependent on sufficient funding, among 

other factors. These factors are important but do not preclude OPM from 

establishing estimated cost ranges and time frames—practices consistent with 

industry best practices and IT project management principles.

Actions to increase staffing capacity. OPM’s actions have included using 

overtime pay and hiring additional staff. However, OPM generally does not 

assess the effectiveness of these actions or whether they reduce delays. For 

example, OPM does not measure overtime productivity or correlate overtime 

data with application processing data. Federal internal control standards state 

that management should review its performance compared to its goals. OPM 

officials stated that they have limited resources for assessments. However, 

without assessments, OPM is less able to make informed decisions on how to 

best use staffing practices to improve processing times.

Actions to reduce missing information in applications. OPM provides

assistance to agencies through guidance, training, communication through 

liaisons and email, and error reports. OPM’s monthly error reports to agencies 

include information on the type of error found and the volume of applications with 

the same error, according to OPM. The four agencies GAO interviewed—

Department of Defense (DOD), Department of Health and Human Services 

(HHS), National Aeronautics and Space Administration (NASA), and U.S. Postal 

Service (USPS)—reported that aspects of the error reports were not userfriendly. OPM stated that its assistance is intended to help agencies submit 

complete and accurate retirement packages for quicker processing. Federal 

internal control standards state that management should communicate quality 

information externally and periodically reevaluate its communication methods. 

OPM officials stated that the error report is intended to capture the overarching 

errors many agencies face and that revising the error report would not be costeffective. However, the current format of the error report may limit its usefulness 

to agencies in improving their retirement applications.

View GAO-19-217. For more information, 

contact Yvonne D. Jones at (202) 512-6806 or 

jonesy@gao.gov.

Why GAO Did This Study

According to OPM, it receives more 

than 100,000 retirement applications 

each fiscal year. Between 2014 to 

2017, OPM did not meet its goal of 

processing most retirement 

applications within 60 days. GAO was 

asked to review potential 

improvements in federal retirement 

processing at OPM. This report (1)

describes the root causes of retirement 

application processing delays, as 

determined by OPM; and (2) examines 

what strategies, if any, OPM has taken

to address those root causes, and how 

OPM has evaluated the effectiveness 

of the strategies. 

GAO reviewed OPM data and 

documents, and interviewed OPM 

officials. GAO also interviewed officials 

from DOD, HHS, NASA, and USPS

about their experiences with 

processing retirement applications. 

GAO selected these agencies because 

they represent a variety of application 

error rates and relatively high 

application volume.

What GAO Recommends

GAO is making 6 recommendations. 

These recommendations include that

OPM should develop a retirement 

services IT modernization plan for 

initial project phases; develop and 

implement policies for assessing

staffing strategies intended to improve 

processing times; and determine if 

there are cost-effective ways to make 

the retirement application error report 

more user-friendly. OPM concurred 

with 1 recommendation and partially 

concurred with 5 recommendations. 

GAO continues to believe all aspects 

of the recommendations are valid, as 

discussed in the report. GAO also 

incorporated technical comments.
Page i GAO-19-217 Federal Retirement

Letter 1

Background 3

OPM Attributes Processing Delays to Paper-Based Applications, 

Staffing, and Missing Information in Applications 8

OPM Conducts Limited Assessments of Its Processing Operation 

and Assistance to Agencies 12

Selected Agencies Have Developed Strategies for Compiling 

Accurate Applications 29

Conclusions 31

Recommendations for Executive Action 32

Agency Comments and Our Evaluation 33

Appendix I Comments from the Office of Personnel Management 36

Appendix II GAO Contact and Staff Acknowledgments 40

Tables

Table 1: Five Key Initiatives of Office of Personnel Management 

(OPM) Retirement Services Information Technology (IT) 

Strategic Vision 13

Table 2: Office of Personnel Management (OPM) Actions to 

Increase Staffing Capacity in Retirement Operations 21

Table 3: Overtime Did Not Track with Number of Applications 

Processed 22

Figures

Figure 1: Overview of Federal Retirement Application Process 5

Figure 2: Percentage of Federal Employees on Board as of 

September 30, 2017, Eligible to Retire in the Next 5 

Years by Agency 7

Figure 3: Overview of Processing Steps after Office of Personnel 

Management (OPM) Receives Federal Retirement 

Application 9

Figure 4: Number of Retirement Applications Office of Personnel 

Management (OPM) Received and Processed Monthly, 

October 2015 to September 2018 11

Contents
Page ii GAO-19-217 Federal Retirement

Figure 5: Selected Agencies Use Three Strategies to Compile 

Accurate Retirement Applications 29

Abbreviations

CSRS Civil Service Retirement System

DOD Department of Defense

FERS Federal Employees Retirement System

HHS Department of Health and Human Services

IT information technology

NASA National Aeronautics and Space Administration

OPM Office of Personnel Management

USPS U.S. Postal Service

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-19-217 Federal Retirement

441 G St. N.W.

Washington, DC 20548

May 15, 2019

The Honorable Elijah E. Cummings

Chairman

The Honorable Jim Jordan

Ranking Member

Committee on Oversight and Reform

House of Representatives

The Honorable Gerald E. Connolly

Chairman

The Honorable Mark Meadows

Ranking Member

Subcommittee on Government Operations

Committee on Oversight and Reform

House of Representatives

The Office of Personnel Management (OPM) manages and administers 

the federal retirement program, which includes processing the retirement 

applications that federal employees must submit through their agencies 

as paper applications. The federal retirement program covers more than 

2.4 million active employees and OPM receives more than 100,000 

retirement applications each fiscal year, according to OPM. Between 

2014 and 2017, OPM reported that it did not meet its goal of processing 

90 percent of retirement applications within 60 days. During this time 

period, OPM processed from 57 to 79 percent of retirement claims within 

60 days each fiscal year. OPM’s new goal as of April 2018 is to process 

all applications within an average of 60 days, which OPM reported that it 

achieved for 5 of the 9 months from April to December 2018.1

You asked us to review potential improvements in federal retirement 

processing at OPM. For this report, we (1) describe the root causes of 

retirement application processing delays, as determined by OPM; (2) 

examine what strategies, if any, OPM has developed and implemented to 

address those root causes, and how OPM has evaluated the 

effectiveness of the strategies; and (3) identify strategies selected 

agencies use to help them compile accurate retirement applications.

 1

OPM also reported that it met its new processing goal for the 2018 fiscal year. 

Letter
Page 2 GAO-19-217 Federal Retirement

To address our first and second objectives, we reviewed OPM documents 

and interviewed OPM officials in both the headquarters and in the 

Retirement Operations Center in Boyers, Pennsylvania. We toured the 

Boyers facility and interviewed staff on the retirement application process.

For our second objective, we also assessed OPM’s strategies against 

criteria that included federal standards for internal control and using data 

to manage performance.2 In addition, to provide background and context 

about OPM’s actions to identify root causes, we analyzed OPM data on 

processing volume for retirement applications. To determine the reliability 

of the data, we reviewed relevant OPM documents and consulted OPM 

officials about data collection methods. We found the data to be reliable 

for our purposes of reporting on processing volume for fiscal years 2016 

through 2018.

To address our third objective, we selected four agencies as case 

illustrations—the Department of Defense (DOD), the Department of 

Health and Human Services (HHS), the National Aeronautics and Space 

Administration (NASA), and the U.S. Postal Service (USPS). Our 

selection of agencies was based on analysis of several characteristics of 

OPM’s data on agency errors for fiscal years 2014 to 2016 across 97 

agencies.3 We narrowed our scope to 17 agencies that we categorized as 

having a relatively high number of applications—more than 1,000 for 

fiscal years 2014 through 2016 combined. Within that scope, we selected 

four agencies that represented a variety of error rates and levels of

application volume to provide a range of agency experiences.

The four agencies represent 56 percent of all applications audited by 

OPM for agency errors in fiscal years 2014 to 2016. These agencies also 

represent 46 percent of all audited applications that OPM identified as 

having errors in fiscal years 2014 to 2016. Although these agencies do 

not represent the experiences of all agencies government-wide, they 

 2

GAO, Managing for Results: Government-wide Actions Needed to Improve Agencies’

Use of Performance Information in Decision Making, GAO-18-609SP (Washington, D.C.: 

Sept. 5, 2018) and Standards for Internal Control in the Federal Government, 

GAO-14-704G (Washington, D.C.: September 2014).

3

We received data for fiscal year 2013-2017, but determined that only 3 years of data 

were complete and reliable for the purposes of our analysis. We omitted fiscal year 2013 

because OPM provided partial year data and fiscal year 2017 because the number of 

applications for several agencies seemed to be outliers based on a comparison with 

previous years’ data. OPM attributed the data outliers to a temporary processing change. 

However, when we analyzed OPM’s documentation, we found that this did not explain the 

outliers.
Page 3 GAO-19-217 Federal Retirement

provide illustrative examples of experiences that agencies have with 

retirement applications. To determine the reliability of the agency error 

data, we reviewed relevant OPM documents and consulted OPM officials 

about OPM’s data collection methods. We found the data to be reliable 

for our purpose of selecting agencies. We also reviewed agency 

documentation related to the selected agencies’ retirement application 

operations and conducted semi-structured interviews with agency staff.

We conducted this performance audit from October 2017 to May 2019 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.

OPM administers two defined-benefit retirement plans that provide 

retirement, disability, and survivor benefits to federal employees.4 The 

Civil Service Retirement System (CSRS) provides retirement benefits for 

most federal employees hired before 1984. The Federal Employees 

Retirement System (FERS) covers most employees hired in or after 1984, 

and provides benefits that include Social Security and a defined 

contribution system.5 If a federal employee becomes disabled while 

employed in a position subject to the retirement system, and the 

employee meets the disability eligibility requirements, the employee may 

apply for a disability retirement.6

Agencies’ human resources offices, payroll offices, and OPM are 

responsible for compiling and processing federal employees’ retirement 

 4

A survivor benefit is when an eligible spouse is paid a portion of the annuity after the 

retiree dies.

5

The Social Security Administration administers Social Security, and the Federal 

Retirement Thrift Investment Board administers the defined-contribution system known as 

the Thrift Savings Plan. Defined-benefit plans calculate benefit amounts in advance of 

retirement based on factors such as salary level and years of service, and definedcontribution plans calculate benefit amounts based on how the amount is invested by the 

employee and employer.

6

The processing time for the disability retirement application starts after a disability 

determination has been approved for the applicant, according to OPM officials. For the 

purposes of this review, we did not analyze the disability determination process.

Background
Page 4 GAO-19-217 Federal Retirement

applications. The process begins when an employee submits a paper 

retirement application to his or her agency’s human resources office. 

OPM’s guidance states that both agencies and payroll offices must certify 

that specific portions of the application are accurate.

OPM employees then ensure that the package includes all the necessary 

information. An OPM adjudicator processes the retirement package, 

which contains the application documents from human resources and 

payroll. For example, the package includes the separation form, which 

finalizes the date that the employee will retire. The adjudicator determines 

if the eligibility requirements are met for an annuity as well as health and 

life insurance into retirement, and calculates the annuity. The process is 

completed when the individual begins receiving regular monthly benefit 

payments, as illustrated in figure 1. According to OPM officials, OPM then 

stores the paper retirement file until (1) all benefits have been applied for 

and paid to all eligible heirs, and (2) a specified amount of time has 

passed.7

 7

The time period is specified as 115 years from the date of the employee’s birth or 30 

years after the date of the employee’s death, whichever is sooner. 5 U.S.C 8345(i).
Page 5 GAO-19-217 Federal Retirement

Figure 1: Overview of Federal Retirement Application Process

Over several decades, OPM has attempted to modernize the retirement 

application process by automating paper-based functions and replacing 

antiquated information systems. However, as we have highlighted in our 

past work, the agency has experienced numerous challenges and has a 

history of undertaking modernization projects that did not yield the 
Page 6 GAO-19-217 Federal Retirement

intended outcomes.8 Specifically, we found that OPM’s efforts over 2 

decades to modernize its processing of federal employee retirement 

applications were fraught with (information technology) IT management 

weaknesses. In 2005, we made recommendations to address 

weaknesses in project, risk, and organizational change management. In 

2008, as OPM was on the verge of deploying an automated retirement 

processing system, we reported deficiencies in, and made 

recommendations to address, additional weaknesses in system testing, 

cost estimating, and progress reporting. In 2009, we reported that OPM 

continued to have deficiencies and made recommendations to address 

these and other weaknesses in the planning and oversight of the 

agency’s modernization effort. OPM began to address these 

recommendations; however, in February 2011, it terminated the 

modernization effort.

As figure 2 shows, 31.6 percent of federal employees who were on board 

as of September 30, 2017, will be eligible to retire in the next 5 years. 

Some agencies have particularly high levels of employees eligible to 

retire in the next 5 years.

 8

GAO, Federal Retirement Processing: Applying Information Technology Acquisition Best 

Practices Could Help OPM Overcome a Long History of Unsuccessful Modernization 

Efforts, GAO-15-277T (Washington, D.C.: Dec. 10, 2014); Federal Retirement Processing: 

OPM Is Pursuing Incremental Information Technology Improvements after Canceling a 

Modernization Plagued by Management Weaknesses, GAO-13-580T (Washington, D.C.: 

May 9, 2013); Office of Personnel Management: Retirement Modernization Planning and 

Management Shortcomings Need to Be Addressed, GAO-09-529 (Washington, D.C.: Apr. 

21, 2009); Comments on the Office of Personnel Management’s February 20, 2008 

Report to Congress Regarding the Retirement Systems Modernization, GAO-08-576R

(Washington, D.C.: Mar. 28, 2008); Office of Personnel Management: Improvements 

Needed to Ensure Successful Retirement Systems Modernization, GAO-08-345

(Washington, D.C.: Jan. 31, 2008); and Office of Personnel Management: Retirement 

Systems Modernization Program Faces Numerous Challenges, GAO-05-237

(Washington, D.C.: Feb. 28, 2005).
Page 7 GAO-19-217 Federal Retirement

Figure 2: Percentage of Federal Employees on Board as of September 30, 2017, Eligible to Retire in the Next 5 Years by 

Agency

Notes: Our calculations include permanent federal employees. “Eligible to retire” is defined as when a 

person is eligible to retire with an unreduced annuity. The graphic is a snapshot in time of fiscal year 

2017 employee’s retirement eligibility and is not a prediction of future eligibility rates. For example, 

the graphic does not take into account employees that may enter or leave the agency in the next 5 

years.

OPM’s reporting on its application processing timeliness also shows 

longer processing times or occasional improved processing times that 

were not sustained from fiscal year 2006 to 2017.9 We found it difficult to 

compare OPM’s performance across years because the performance 

measures have changed over time. For example, in 2009 through 2011, 

 9

OPM did not report its performance on processing timeliness for fiscal year 2012. OPM 

stated that it did not report on processing timeliness because it was transitioning to a new 

performance metric.
Page 8 GAO-19-217 Federal Retirement

OPM’s performance measure was the average number of days to 

process applications. During this time period, OPM met its target except 

for 1 year when OPM reported 108 days and the target was 45 days. In 

contrast, in 2014 through 2017, OPM’s performance measure was the 

percentage of applications processed in 60 days.10 During this time 

period, OPM did not meets its target of processing 90 percent of 

applications in 60 days as the percentage ranged from 57 to 79 percent 

each fiscal year.

Paper-based applications. Despite past attempts to modernize its 

retirement applications processing operation, OPM currently requires 

federal employees to submit their retirement application on paper. 

According to OPM officials, OPM has automated some front-end 

processing steps, despite various challenges, such as OPM’s and 

agencies’ legacy systems lacking functionality or integration, inaccurate 

data due to manual data-entry errors, and lack of real-time data because 

data are stored in inconsistent formats at multiple locations.11 OPM 

officials reported that payroll providers can electronically send OPM 59 

data elements, which allows OPM to authorize interim annuity payments 

to 50 percent of new applicants, as well as initiates other processing 

functions.12 However, as shown in figure 3, subsequent processing steps 

still require manual intervention, including assembling paper documents 

into folders, ensuring documents are in proper order, and addressing 

missing or incomplete information.

 10In addition, the performance metric from 2009 through 2011 did not include disability 

applications, whereas the metric from 2014 through 2017 included disability applications 

after they were determined to be eligible.

11OPM, Annual Performance Report, Fiscal Year 2010.

12Other processing functions include creating records in various OPM systems and 

retrieving health insurance enrollment information. Officials added that such automation 

saves OPM several full-time equivalent positions but did not specify how many positions 

or how it made this determination. OPM established the interim payment process in the 

1960s so that annuitants would receive some income while waiting on their final annuity to 

be adjudicated.

OPM Attributes 

Processing Delays to 

Paper-Based 

Applications, Staffing, 

and Missing 

Information in 

Applications
Page 9 GAO-19-217 Federal Retirement

Figure 3: Overview of Processing Steps after Office of Personnel Management 

(OPM) Receives Federal Retirement Application

Note: This figure does not include automated front-end processing steps, such as electronically 

receiving data from payroll providers.

Staffing capacity. OPM attributed delays to not having enough staff to 

address its peak workload season, called the surge period. According to 

OPM, it hired additional staff in 2017 and 2018 to process applications 

throughout the year, but overtime pay was needed to increase staffing 

capacity during surge periods. Also, officials reported that hiring freezes, 

continuing resolutions, and other budget constraints affected hiring 

numbers and created hiring delays over the past 5 fiscal years.
Page 10 GAO-19-217 Federal Retirement

During the surge, OPM officials said they receive the bulk of applications 

starting in mid-January continuing through February (6 weeks). However, 

the effect of the surge workload lasts until mid-April because OPM takes 

about 60 days on average to process an application. Figure 4 illustrates 

the flow of applications OPM received and processed in fiscal years 2016 

to 2018. During the months of January and February in this time period, 

OPM received an average of about 13,200 applications per month, a 

considerable increase over its average of about 7,200 per month at other 

times of the year. Despite the increase in applications, OPM’s application 

processing numbers remained essentially the same in January and 

February (8,200 per month) compared to other months of the year (8,100 

per month), thus increasing OPM’s inventory of unprocessed applications, 

which ranged from approximately 11,400 to 24,200 for the time period 

shown.

The increase in inventory was partly mitigated in March of each year, 

when OPM processed an average of about 11,000 applications. OPM 

officials reported that they processed more applications in March because 

they used overtime pay and flexible staffing across work units, such as 

temporarily shifting staff to a different unit to expedite workflow; screened 

for complete applications; and received fewer applications as surge 

periods ended.13 We discuss these and other actions OPM has taken to 

increase staffing capacity during surge periods later in the report.

 13We use the term “work units” to describe how OPM organizes its staff by processing 

steps. OPM refers to these work units as “cells.”
Page 11 GAO-19-217 Federal Retirement

Figure 4: Number of Retirement Applications Office of Personnel Management (OPM) Received and Processed Monthly, 

October 2015 to September 2018

Note: OPM defines monthly inventory as all new pending claims under the Civil Service Retirement 

System (CSRS) and Federal Employees Retirement System (FERS), including all non-disability 

claims and disability claims after a determination has been made that disability retirement under 

CSRS or FERS is warranted. As of September 2018, OPM’s inventory was around 17,600.

Incomplete applications. According to OPM officials, in up to 40 percent 

of applications, OPM is missing information needed to finalize processing, 

which increases processing time. Incomplete applications generally fall 

into two categories:

• Missing information. OPM estimates about 10 percent of 

applications are missing information, such as a form or signature. For 

example, OPM officials said that documentation for the applicant’s 

preceding 5 years of health insurance coverage, which is necessary 

to continue health insurance into retirement, was often missing.

• Waiting for applicant decisions. OPM estimates about 30 percent of 

applications are delayed while waiting for applicant decisions. For 
Page 12 GAO-19-217 Federal Retirement

example, OPM stated that it must wait 30 days for the applicant to 

select an annuity option if deposits or redeposits are made.14

In addition to these three root causes, OPM officials reported that other 

factors, such as legislative changes, can also cause processing delays. 

For example, changes in the law may require OPM to revise its processes 

and train its staff, taking away time from core processing activities.15

Subsequent to terminating its retirement modernization effort in February 

2011, OPM refocused its retirement modernization efforts and in 2013 

developed a new strategic vision for modernizing retirement applications 

processing. OPM’s 2013 strategic vision for modernizing retirement 

applications processing envisioned a paperless system that would timely 

authorize accurate retirement benefit payments, answer customers’

questions, and promote self-service account maintenance. According to 

OPM officials, the strategic vision consists of five key initiatives which are 

 14Deposits and redeposits are payments applicants can make into the Civil Service 

Retirement System or the Federal Employees Retirement System for certain periods of 

federal service during which they either did not contribute towards their retirement and 

disability benefits, such as a temporary employee, or for which they received a refund of 

their retirement contributions. In these situations, OPM sends the applicant a letter with 

options and corresponding calculations of his or her annuity for each option. If the 

applicant does not respond within 30 days, OPM calculates the annuity as if the applicant 

opted to make no deposit or redeposit.

15For example, due to legislative changes, OPM officials reported that they recently 

trained staff on crediting availability pay towards certain Transportation Security 

Administration employees’ retirement. Availability pay is a type of premium pay that is paid 

to federal criminal investigators who are required to be available to work substantial 

amounts of unscheduled duty. FAA Reauthorization Act of 2018, Pub. L. No. 115-254, 

§1908, 132 Stat. 3186, 3548-49 (2018) (codified as amended at 5 U.S.C. § 8331.

OPM Conducts 

Limited Assessments 

of Its Processing 

Operation and 

Assistance to 

Agencies

IT Modernization Plan 

Remains Unclear
Page 13 GAO-19-217 Federal Retirement

in varying stages of development and implementation, as shown in table 

1.

Table 1: Five Key Initiatives of Office of Personnel Management (OPM) Retirement Services Information Technology (IT) 

Strategic Vision

Key initiative Description Stage of development and implementation

Electronic Retirement 

Record 

Contains 185 data elements on 

service history, insurance 

coverage, and military service, 

among others. Agency payroll 

submits the Electronic Retirement 

Record to OPM’s Retirement Data 

Repository.

Developed. Partially implemented. According to OPM, it is 

piloting the Electronic Retirement Record with the Interior 

Business Center (payroll). The Electronic Retirement Record is 

intended to replace the hardcopy Individual Retirement Record, 

which payroll submits to OPM when an employee separates from 

the agency. 

Retirement Data Repository Data warehouse where OPM will 

consolidate and store all data from 

retirement systems, applicants, 

human resources, and payroll. The 

Retirement Data Repository 

currently contains 3.1 million 

imaged records.

Developed. Partially implemented. OPM plans to expand 

access to the Retirement Data Repository for agencies and 

payroll offices. According to a recent OPM Inspector General’s 

report, as of August 2017, 793 external users from 44 federal 

agencies have access to view scanned records in the Retirement 

Data Repository.a At the same time, OPM continues to work with 

the Interior Business Center to test the Retirement Data 

Repository to address issues, such as inconsistent data between 

electronic and paper records.

Data Bridge Electronically transfers Retirement 

Data Repository data to the 

retirement benefit calculator.

Partially developed. The Data Bridge has been constructed, but 

additional business rules need to be developed and the data 

mapped before it is fully implemented.

Online Retirement 

Application Form

Web-based, interactive, electronic 

retirement application form.

Partially developed. OPM has developed requirements for the 

online retirement application but is waiting for further direction 

from OPM’s IT leadership.

Case Management System Automated system to manage 

electronic case files for processing.

Partially developed. OPM has developed requirements for the 

case management system but is waiting for further direction from 

OPM’s IT leadership.

Source: GAO analysis of OPM information. | GAO-19-217

a

U.S. OPM Office of the Inspector General, Final Evaluation Report, Evaluation of the U.S. Office of 

Personnel Management’s Retirement Services’ Imaging Operations, Mar. 14, 2018.

Partly in response to cancelling its third attempt to automate the 

processing of federal retirement applications in February 2011, OPM is 

now taking an incremental approach towards modernizing its retirement 

IT systems.16 According to OPM officials, they also recognize the need to 

improve OPM’s enterprise architecture before implementing significant 

 16GAO-15-277T.
Page 14 GAO-19-217 Federal Retirement

modernization efforts. As we have previously reported, these steps can 

help agencies successfully modernize and maintain IT environments.17

OPM’s current approach provides a framework to help the agency 

achieve its overall IT modernization strategic vision. However, OPM 

officials provided no further explanation about how retirement IT 

modernization activities would proceed, such as describing proposed time 

frames and estimated cost ranges, even for initial project phases. 

Likewise, OPM’s Inspector General recently reported that the agency’s 

fiscal year 2018 IT modernization expenditure plan did not account for 

total costs nor identify the full scope of OPM’s modernization effort for the 

agency.18

Industry best practices and IT project management principles stress the 

importance of sound planning for system modernization projects. These 

plans should identify key aspects of a project, such as scope, responsible 

organizations, costs, schedules, and risks. Additionally, planning should 

begin early in the project’s life cycle and be updated as the project 

progresses.19 Further, according to federal internal control standards, 

management should define objectives in specific and measurable terms, 

such as defining what is to be achieved, who is to achieve it, how it will be 

achieved, and time frames for achievement.

OPM officials said that additional IT modernization work is dependent on 

sufficient funding, support from the Office of the Chief Information Officer, 

and development of a technical enterprise architecture roadmap. These 

 17Enterprise architecture is a “blueprint” that describes how an organization operates in 

terms of business processes and technology, how it intends to operate in the future, and 

how it plans to transition to the future state. A fuller discussion of enterprise architecture 

can be found at GAO, Organizational Transformation: Enterprise Architecture Value 

Needs to Be Measured and Reported, GAO-12-791 (Washington, D.C.: Sept. 26, 2012). 

For more information on incremental development, see GAO, Information Technology: 

Further Implementation of Recommendations Is Needed to Better Manage Acquisitions 

and Operations, GAO-18-460T (Washington, D.C.: Mar. 14, 2018).

18U.S. OPM Office of the Inspector General, Final Management Advisory, U.S. Office of 

Personnel Management’s Fiscal Year 2018 IT Modernization Expenditure Plan, June 20, 

2018; and Management Advisory, U.S. Office of Personnel Management’s Fiscal Year 

2017 IT Modernization Expenditure Plan, Feb. 15, 2018. 

19Since 2005, we have made numerous recommendations to OPM to develop an IT 

modernization plan for retirement processing that addresses weaknesses in project, risk, 

and organizational change management; cost estimating; system testing; progress 

reporting; planning; and oversight. See GAO-15-277T and GAO-05-237.
Page 15 GAO-19-217 Federal Retirement

components are important. However, they do not preclude OPM from 

establishing a basic project management plan that includes objectives, 

estimated cost ranges, and proposed time frames for its initial project 

phases. Without a plan that is consistent with IT project management 

principles, OPM is less able to articulate a path forward in measurable 

terms and assess performance towards achieving its objectives. Similarly, 

without an electronic application system, OPM is less able to 

automatically verify information upfront when the application is submitted 

and notify applicants of any discrepancies prior to accepting the 

application.

The administration’s proposal to move the retirement application 

processing operation to the General Services Administration (to be 

renamed as the Government Services Agency) has created additional 

uncertainty for OPM.20 Potential changes in organizational affiliation, 

policy, budget, and staff may make it difficult for OPM to plan for largescale changes in its operations.21 Nevertheless, continuing to develop 

plans to modernize retirement IT systems seems prudent, given that the 

details of the reorganization are still unknown and that the move to the 

General Services Administration may not occur in the near term, or at all. 

Further, IT modernization is a key theme in the March 2018 President’s 

Management Agenda and will likely be a key driver in changing agency 

operations for years to come.

We have previously reported that to successfully implement reforms and 

improve their operations and results, agencies need to robustly manage 

their performance.22 This involves not only measuring progress toward 

goals, but also using performance information (i.e., data collected to 

measure progress towards agency goals) to identify and correct 

problems, improve program implementation, and make other important 

management and resource allocation decisions. However, we found that 

 20Executive Office of the President of the United States, Delivering Government Solutions 

in the 21st Century: Reform Plan and Reorganization Recommendations, June 2018.

21In June 2018, we identified key questions Congress, OMB, and agencies should 

consider for developing and implementing government reforms. See GAO, Government 

Reorganization: Key Questions to Assess Agency Reform Efforts, GAO-18-427

(Washington, D.C.: June 13, 2018). The questions can help assess various aspects of 

reform efforts, including related goals and outcomes, and steps to implement and monitor 

progress.

22GAO-18-609SP.

OPM Lacks Performance 

Information That Could 

Improve Processing 

Timeliness and Staffing 

Capacity
Page 16 GAO-19-217 Federal Retirement

OPM does not use performance information on processing timeliness to 

manage for results. In addition, we found that OPM conducted limited 

assessments of its processing data and did not assess the effectiveness 

of its staffing actions.

OPM’s fiscal year 2019 processing timeliness goal is to process all 

retirement applications in an average of 60 days or less.23 The related 

performance measure is the average number of days to process 

retirement applications. However, we found that OPM did not use its 

timeliness performance measure to manage for results or provide 

external stakeholders and applicants a clearer picture of processing 

time.24

Performance measures not used to manage. Based on our 2017 

survey of federal managers, we found that OPM managers agency-wide 

reported a statistically significant decrease in using performance 

information to develop program strategy, allocate resources, and take 

corrective actions since 2013.25 Similarly, for this review, we found that 

OPM could enhance its use of performance information to manage for 

results in retirement applications processing. OPM has not established 

additional performance measures for the various parts of the application 

review and processing operation that would contribute towards achieving 

its overall processing timeliness goal. For example, OPM does not 

measure timeliness or have related performance goals for its various 

work units that process applications.

OPM officials do not use such performance goals and measures to 

manage for results in part because they do not perceive the information to 

be relevant to reducing processing delays. For example, OPM officials 

said that the new timeliness performance goal facilitates planning but 

does not improve processing time or otherwise provide better service to 

retirees. According to these officials, OPM does not have a requirement 

 23OPM began reporting this processing goal in April 2018. This goal replaces the previous 

goal of processing at least 90 percent of applications within 60 days. 

24OPM officials reported that, in addition to timeliness, they also measure processing 

accuracy. In fiscal year 2017, OPM estimated that it accurately processed about 94 

percent of retirement and survivor claims.

25We have developed a body of work on the use of performance information. Most 

recently, we surveyed federal managers in 2017 to obtain their perspectives on the use of 

performance information for management and decision-making. For more information, see 

GAO-18-609SP.

Performance Goals and 

Measures
Page 17 GAO-19-217 Federal Retirement

for completing its various processing steps within a certain amount of time 

because each application is different, and they do not want staff to rush 

and potentially make mistakes, thereby causing rework. In comparison, 

agencies and payroll centers that submit these applications to OPM are 

required to do so within a certain time frame.26

Similarly, OPM has not established a timeliness performance goal or 

measure for completing its review of applicants’ eligibility for disability 

retirement. OPM officials said that OPM does not have a performance 

goal or measure for the review for disability retirement eligibility because 

it has not reached a steady processing level for these applications. 

However, OPM did not provide a time frame for when it expects to reach 

a steady processing level, nor did officials explain why OPM has not 

established performance goals and measures based on past performance 

or other benchmarks. In comparison, the Social Security Administration, 

through partnerships with state agencies, also reviews applications for 

disability benefits eligibility and has established performance goals for 

both the accuracy and processing time for this review process.27 As of 

November 2018, OPM officials reported that they are collecting data to 

develop a separate performance goal for measuring the timeliness of 

reviewing disability retirement eligibility and expect to establish a 

performance baseline within the next 3 to 6 months.

The lack of management practices to encourage and enhance the use of 

performance measures at the operational level can make it challenging 

for OPM to use performance information to manage operations, such as 

identifying problem areas that cause delays and implementing corrective 

actions, and to make decisions, such as better targeting limited resources 

based on risk or other priorities.

 26Chapter 40 of the Civil Service Retirement System (CSRS) and Federal Employees 

Retirement System (FERS) Handbook states that an agency is expected to complete its 

processing actions and forward the retirement application package to OPM so that the 

package is received within 30 days after the employee separates from the agency. OPM 

officials reported that in 1990, Congress mandated that federal agencies meet a 

timeliness standard for submitting retirement records to OPM. According to OPM officials, 

the mandate’s timeliness standard is met if 80 percent of an agency’s retirement benefit 

related records are received at OPM within 32 days of the employee’s separation. The 

CSRS and FERS Handbook has not been updated to reflect the 32-day limit.

27For fiscal years 2015 to 2017, the Social Security Administration established several 

performance measures for timeliness of disability decisions as part of its strategic 

objective 3.1. For more details, see Social Security Administration, Annual Performance 

Report, 2015-2017.
Page 18 GAO-19-217 Federal Retirement

Unclear performance measures. OPM officials reported that the new 

processing timeliness goal also provides agencies and applicants a 

clearer, more realistic expectation of processing time. However, none of 

the four agencies we interviewed considered the new goal to be clearer or 

more helpful than past goals.28 The Departments of Defense and Health 

and Human Services, and the U.S. Postal Service were unaware that any 

such goal was ever established, prior to our discussions.

We found that this performance goal was unclear because it lacked 

explanatory information that would make it more meaningful for applicants 

and external stakeholders, such as agency benefit officers and 

congressional oversight committees. Specifically, the new performance 

goal and related measure are expressed as an average, which allows for 

potentially wide variation in processing times while still meeting OPM’s 

goal. In past work, we have reported that including explanatory 

information on goals and measures helps improve the usefulness of 

performance information.29 Without explanatory information, reporting an 

average can obscure aspects of OPM’s processing timeliness, such as 

the number and types of applications OPM processes faster or slower 

than 60 days and the range of processing times.

Also, OPM’s processing timeliness goal and measure do not include all 

phases of the application review process, specifically the time OPM takes 

to determine eligibility for disability retirements, which can be lengthy.30

We have previously reported that performance information could be more

useful if it identified significant data limitations and their implications for 

assessing performance. OPM officials reported that the processing 

 28We interviewed agencies to obtain their perspectives on working with OPM to submit 

retirement applications, among other topics. We selected agencies based on various 

factors, such as volume of applications and error rate. We discuss our selection 

methodology in the introduction of this report.

29GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999).

30As an example, the U.S. Postal Service (USPS) Inspector General recently reported that 

approximately 2,000 USPS employees applied for disability retirement in fiscal year 2017. 

As of September 30, 2017, 1,195 employees had been waiting 6 months or longer for a 

decision from OPM on their applications. Of these employees, 398 had been waiting for a 

year or longer. In addition, the USPS Inspector General reported that when disability 

determination decisions are not rendered timely, applicants can be adversely affected, 

including loss of income and health and life insurance benefits. See USPS Office of the 

Inspector General, Audit Report, Postal Service Disability Retirement Application Process, 

(HR-AR-18-005), June 11, 2018. 
Page 19 GAO-19-217 Federal Retirement

timeliness goal and measure exclude data on disability retirement 

applications pending approval because OPM does not consider reviewing 

disability retirement eligibility as part of processing. OPM includes 

disability applications in its processing timeliness goal after these 

applications have been approved. Not providing explanatory information 

about what the processing goal includes or excludes can lead to 

agencies’ and applicants’ false expectations and confusion about the 

amount of time OPM is taking to review applications.

OPM has implemented various strategies for improving processing 

timeliness, as discussed below. However, we found multiple examples 

where OPM did not assess whether the strategies were effective.

Assessment of processing applications. According to OPM officials, 

senior and frontline managers review processing data, such as age of 

pending applications, weekly to identify potential concerns, and adjust 

staffing and workload if necessary. However, we found that OPM’s 

performance information may be of limited use for assessing processing 

delays because the data lacked elements that would provide a more 

complete measure of performance.

For example, we found that OPM did not review about half of applications 

government-wide for errors in fiscal years 2014 to 2016 combined, 

including all disability retirement applications.31 Likewise, OPM officials 

said that the number of unprocessed applications in inventory does not 

include disability retirement applications still pending approval. As a 

result, OPM’s performance information for both application errors and 

inventory does not reflect the full extent of processing delays because 

various applications have been excluded. OPM officials were unable to 

explain to us why or how they decided to exclude certain applications.

Also, OPM generally does not assess the accuracy of the data it collects 

on application errors. OPM most recently reviewed the accuracy of the 

error data in 2014, despite additional feedback from agencies that some 

 31Since 2009, OPM has audited retirement applications for incorrect, missing, or 

incomplete information, compiled the error data, and sent agencies a monthly report 

detailing the number and nature of errors. The audit is separate from OPM’s adjudication 

process. In 2018, OPM moved the timing of the audit to after the adjudication process, 

rather than during, to avoid processing delays. OPM officials said that they used the error 

data for developing training webcasts and conferences. We discuss OPM’s assistance to 

agencies, such as training, later in the report.

Limited Assessments of 

Processing and Staffing 

Strategies
Page 20 GAO-19-217 Federal Retirement

errors charged to them were incorrect.32 We also found outliers in the 

data that OPM officials were unable to explain.33

Assessment of staffing actions. OPM has taken actions to increase 

staffing capacity in retirement operations throughout the year, as well as 

during surge periods, as shown in table 2.

 32OPM reviewed agency disputes about application errors received in July and August 

2014. Of the 93 agency disputed errors that OPM reviewed, it found that it had incorrectly 

charged 56 errors, either because it noted an error that did not exist or incorrectly 

characterized the error. However, OPM also determined that less than 1 percent of all 

applications were affected by incorrectly charged errors.

33OPM attributed the data outliers to a temporary processing change, which OPM officials 

said resulted in some agencies sharing the same agency code. However, when we crosschecked these agencies to agencies with data outliers, we found that the agencies were 

largely different. Therefore, the processing change would not explain the outliers. 
Page 21 GAO-19-217 Federal Retirement

Table 2: Office of Personnel Management (OPM) Actions to Increase Staffing Capacity in Retirement Operations

Actions Description

Cross-functional training When OPM reorganized its processing workflow into units, OPM trained staff to perform multiple 

functions, enabling staff to move between units to increase capacity. For example, workers in unit 

five review applications for completeness but are also trained, and can be called upon, to perform 

tasks in units one through four, such as assembling application materials and collecting missing 

documents. 

Hiring additional staff In fiscal year 2017, OPM hired 15 additional legal administrative specialists to process applications. 

OPM estimated that these staff will process 8,500 additional applications in their first year and 

progressively more (up to about 15,000 additional applications per year) as staff complete training 

and gain experience. 

Monitoring workload Managers review weekly reports showing number of applications received, processed, and in 

inventory, as well as the amount of time elapsed since OPM received the application.

Overtime pay OPM used overtime pay to compensate for reduced staffing in fiscal years 2013 to 2016 and to 

process additional applications in fiscal year 2017. 

Work specialization Based on staff suggestions, OPM began training senior staff to specialize in low volume applications, 

such as those from Bureau of Indian Affairs. According to OPM officials, these staff have been 

trained for more than 10 years and work these applications to maintain expertise.

During surge periods

Leveraging external agencies From 2015 to 2017, OPM brought in four to five employees from the U.S. Postal Service to help at its 

Boyers, Pennsylvania processing facility during surge periods. These employees stayed an average 

of 6 weeks and assisted with authorizing the initial interim payment to applicants. From 2016 to 2018, 

OPM had a similar arrangement with employees from the Defense Finance and Accounting Service.

Overtime pay OPM officials said that they require certain staff to work overtime to reduce inventory before and 

during surge periods.

Temporary processing 

changes

From January through March 2017, OPM sent most applications directly to adjudication, bypassing 

earlier processing steps. OPM reverted to its usual processing steps in 2018 but may use this 

method again for future surge periods.

Tiger teams Since 2013, OPM has assembled teams of 15 staff members each to expedite processing. Teams 

focus on applications screened for completeness, resulting in quicker processing because the 

applications required fewer steps to finalize.

Source: GAO analysis of OPM information. | GAO-19-217

Note: Defense Finance and Accounting Service is the payroll provider for the Department of Defense, 

Department of Health and Human Services, and other agencies.

However, we also found that OPM does not assess the effectiveness of 

its staffing actions, even though OPM officials reported that they are 

consistently looking for opportunities to improve OPM’s current 

processes. For example, OPM officials said that staffing actions improved 

efficiency but were unable to provide supporting data or documentation of 

their assessments, such as how often cross-functionally trained staff 

worked in other units and resulting improvements in output or quality.
Page 22 GAO-19-217 Federal Retirement

Likewise, OPM has not assessed the results of using overtime pay. As 

shown in table 3, any increased use of overtime pay during fiscal years 

2013 to 2017 did not increase the number of applications processed. 

Table 3: Overtime Did Not Track with Number of Applications Processed

Fiscal 

year

Overtime hours Overtime cost 

(dollars)

Number of applications 

processed

2013 57,585 2,228,981 130,832

2014 63,717 2,466,701 98,542

2015 83,714 3,275,223 95,651

2016 59,116 2,376,252 94,545

2017 64,773 2,653,912 92,125

Source: Office of Personnel Management (OPM) data. | GAO-19-217

Note: Overtime data include both processing and nonprocessing activities. OPM was unable to 

provide a more detailed breakdown of the data.

OPM officials said that overtime pay does not necessarily translate into 

increased output because some actions performed during overtime, such 

as quality review, do not contribute towards finalizing additional 

applications. They added that other factors can decrease production, 

such as reduced staff. Reduced staffing from fiscal years 2013 and 2016 

may have contributed to decreased output, even with the use of overtime. 

However, OPM officials were unable to provide the number or types of 

positions that were reduced. Likewise, OPM does not measure how and 

to what extent the various factors affect output.

OPM officials also said that they use overtime pay during surge periods to 

move applications through processing during its busiest time of the year, 

thereby decreasing an otherwise longer waiting time for applicants. 

However, OPM does not measure overtime productivity, or productivity in 

general, nor are they able to correlate overtime data with applications 

processing data or outcomes. OPM officials explained that they expect 

staff to be equally productive during overtime as they are during regular 

work time. Although OPM officials may set these productivity 

expectations, they do not collect productivity data to measure whether 

and to what extent staff meet these expectations.

Further, OPM officials could not provide basic staffing data, such as the 

number of staff who have processed retirement applications for the past 5 

years or number of processing staff paid overtime. Such information is 
Page 23 GAO-19-217 Federal Retirement

valuable because it provides the basis for assessing whether OPM’s 

staffing actions are improving performance and meeting their intended 

purpose.

We have previously reported that to be useful, performance information 

must meet users’ needs for completeness, accuracy, consistency, 

timeliness, validity, and ease of use.34 Other attributes that affect the 

usefulness of information include, but are not limited to, relevance, 

credibility, and accessibility. Further, federal internal control standards 

state that management should use quality information and design control 

activities to achieve the agency’s objectives. Examples of control 

activities include top-level reviews of performance compared to plans, 

goals, and objectives; management reviews at the functional or activity 

level; comparing and assessing related data sets so that relationships can 

be analyzed and appropriate actions taken; and clearly documenting 

control activities, transactions, and other significant events so that the 

documentation is readily available for examination. Federal internal 

control standards also state that management should implement control 

activities through policies.

OPM officials reported that OPM’s systems were not robust enough to 

produce better performance information beyond basic processing data. 

OPM officials added that they have limited resources to assess data on 

strategies intended to improve processing timeliness. As such, OPM 

could consider a risk-based approach to collecting data and conducting 

assessments. For example, OPM could prioritize assessments of more 

resource-intensive activities over less resource-intensive activities. OPM 

could also focus its assessments on situations that could potentially 

introduce processing errors or data inconsistencies, such as when 

regulatory or process changes are implemented, or when staff are newly 

employed or are taking on new responsibilities. OPM officials also said 

that processing time is one of multiple factors they use to determine the 

effectiveness of staffing actions. However, as noted earlier, processing 

times have not consistently improved, further underscoring the need for 

better data and assessments of strategies intended to improve 

processing timeliness. Lack of useful performance information and 

policies and procedures to conduct assessments can hinder managers 

from identifying causes and corrective actions to problems in existing 

 34GAO-05-927 and GAO, Results-Oriented Government: GPRA Has Established a Solid 

Foundation for Achieving Greater Results, GAO-04-38 (Washington, D.C.: Mar. 10, 2004).
Page 24 GAO-19-217 Federal Retirement

programs, as well as developing and prioritizing strategies and related 

resources for future programs.

To obtain agencies’ perspectives on the retirement application process 

and better understand their coordination and collaboration with OPM, we 

interviewed four selected agencies using a standardized set of questions 

in a semi-structured interview format. After we met with the agencies, we 

discussed the agencies’ perspectives on OPM’s assistance with OPM 

officials and incorporated their comments, as appropriate.

OPM provides four main types of assistance to agencies: written 

guidance, training, communication through assigned liaisons and email, 

and monthly error reports.

• Guidance. OPM provides written guidance to agencies on submitting 

retirement applications through the Civil Service Retirement System 

and Federal Employees Retirement System Handbook for Personnel 

and Payroll Offices and Benefit Administration Letters. The letters 

provide guidance to agencies on various topics, such as on retirement 

policy and process issues. The most recent version of the handbook 

posted on OPM’s website is from 1998. OPM officials reported that 

the handbook is updated on an ongoing basis and as resources 

permit. Of the 47 chapters on OPM’s website, five had been updated 

between 2013 and 2017. NASA reported that OPM’s handbook is out 

of date and found it unreliable because some of the information is no 

longer accurate. All of the four selected agencies reported that the 

Benefit Administration Letters were very important. The Department of 

Defense (DOD), the Department of Health and Human Services 

(HHS), and the U.S. Postal Service (USPS) reported that the Benefit 

Administration Letters were issued at about the right frequency. In 

addition, DOD, the National Aeronautics and Space Administration 

(NASA), and USPS also stated that the Benefit Administration Letters 

were helpful or very helpful.

• Training. OPM officials reported that OPM provides training 

opportunities to agencies which include semi-annual multi agency 

conferences, training for benefit officers, webcasts, self-paced online 

training, and onsite training if requested. DOD and HHS reported that 

they were satisfied with the training, and NASA and USPS reported 

that they were dissatisfied. For example, NASA reported that OPM’s 

training would be improved with more virtual trainings that are shorter. 

NASA also reported that cost constraints prohibited sending all 

OPM Provides Assistance 

to Agencies, but Lacks a 

Robust Process for 

Assessing That Assistance

Selected Agencies Have Mixed 

Perspectives on OPM 

Assistance
Page 25 GAO-19-217 Federal Retirement

retirement staff to in-person training while virtual training is accessible 

to more staff.

• Liaisons and emails. OPM officials stated that it communicates with 

agencies by assigning all agencies a liaison to contact for technical 

assistance and communicating directly via email. For example, HHS 

reported that its previous liaison had helped locate missing records, 

such as a federal employee’s federal service history. All of the four 

selected agencies reported that the interaction with the liaisons was 

very important, and DOD, NASA, and USPS reported that the 

interactions were very helpful and about the right frequency. OPM 

also stated that it communicates with benefit officers and other 

interested parties through emails. USPS reported that the emails from 

OPM included Benefit Administration Letters and announcements 

about meetings and upcoming trainings. DOD, NASA, and USPS 

reported that emails were the most helpful form of communication with 

OPM.

• Error reports. OPM provides agencies with a monthly error report 

after it analyzes each agency’s batch of applications. This report 

includes information on the type of error found and the volume of 

applications with the same error, according to OPM. The error report 

includes retirement applications for those who retired while working 

for the federal government, which, for example, does not include 

disability retirement applications, according to OPM officials. OPM 

officials reported that the intent of the error reports is to educate the 

agencies. DOD and USPS reported that the error reports were helpful 

for identifying application errors. However, all four selected agencies 

reported that aspects of the error reports were not user-friendly. For 

example, the error reports are in a format that cannot be manipulated, 

thereby requiring agencies to manually enter data to track the type of 

errors found, and analyze the data and share the information 

internally. Such manual entry increases the risk of data entry errors 

that could compromise the accuracy of the original data. The four 

selected agencies also reported that the error reports lack some types 

of information, such as clear descriptions of errors, data on trends, 

and information on disability retirement applications.

OPM officials reported they review two of the four types of assistance 

(guidance and training) and also conducted a review of error reports in 

2014. They also stated that they had taken some actions in response to 

agency feedback. However, OPM did not provide documentation of their 

assessments of guidance or training.

OPM Conducts Limited 

Reviews of Its Assistance to 

Agencies
Page 26 GAO-19-217 Federal Retirement

• Guidance. OPM officials reported that they continue to evaluate their 

guidance and had taken some actions in response to agency 

feedback. For example, in response to agencies’ feedback that they 

experienced difficulty obtaining paper documentation of 5 years of 

health insurance, OPM officials reported that they developed a new 

form that agencies could use to certify that employees had the 

required coverage, which has resulted in decreased errors. However, 

OPM could not provide us with documentation of its reviews of its 

guidance. In addition, OPM had no schedule for updating guidance to 

agencies, according to OPM officials.

• Training. OPM officials reported that they receive agency feedback 

on training in multiple ways and had taken some actions in response. 

For example, OPM officials said that agencies provide feedback on 

trainings informally during conversations with liaisons and at in-person 

trainings. OPM officials also said they read training evaluation forms, 

which include multiple choice questions on the value of the different 

aspects of the training and an area to write any comments or 

suggestions. In addition, OPM periodically surveys benefit officers on 

their training, including open-ended questions about how and on what 

topics the respondent would prefer to receive training. However, the 

benefit officer survey does not include broader questions about how 

the training or other types of assistance could better meet the needs 

of agencies.

In addition, OPM officials reported that in response to agency feedback, 

they made improvements to the class offerings, such as enhancing 

training on military discharges. OPM officials also reported that one of the 

actions they take in response to the most common errors that agencies 

make in retirement applications is to provide training on these topics. For 

example, OPM officials reported that they identified common errors on 

federal health benefits and military service documentation and 

subsequently provided training on both topics. OPM officials did not 

provide us with documentation of their reviews of agency feedback on 

training.

• Error reports. In 2014, OPM conducted a review of the errors that 12 

agencies disputed in the agencies’ error reports. OPM officials 

reported that the review concluded that less than 1 percent of OPM’s 

incorrectly identified errors would have affected the annuitant. 

According to OPM officials, the cost of reviewing and adjusting the 

error rate for accuracy outweighs the benefits. In addition, the four 

selected agencies reported that they had shared information with 

OPM on errors that the agencies thought were erroneously identified 
Page 27 GAO-19-217 Federal Retirement

as errors. The four selected agencies reported that OPM had not 

changed the error rates in response. In addition, HHS and USPS 

reported that OPM did not share the information on disputed errors 

with its staff who audit the applications for errors. USPS officials also 

stated that OPM had not used this information to train its staff.

OPM’s fiscal year 2018 budget justification cited partnering with agencies 

to help them submit complete and accurate retirement packages for 

quicker processing.35 While OPM officials reported that they have 

reviewed certain types of assistance, they have limited or no 

documentation on the analysis or the results of these reviews. Federal 

internal control standards state that management should compare actual 

performance to expected results and evaluate and document monitoring 

results. The standards also state that management should complete and 

document corrective actions to remediate control deficiencies in a timely 

manner.36 In relation to training, which is one of the types of assistance 

OPM provides to agencies, we have also reported that a leading training 

investment practice is to evaluate the benefits achieved through training, 

such as having a formal process for evaluating improvement in 

performance and tracking the impact of training on the agency’s 

performance goals. Another leading practice is to compare the merits of 

different delivery mechanisms (such as classroom or computer-based 

training) and determine what mix of mechanisms to use to ensure efficient 

and cost-effective delivery.37

OPM officials reported that effectiveness of their assistance to agencies is 

a contributing factor to decreased errors in retirement applications. For 

example, according to OPM, the percentage of complete applications 

submitted government-wide improved from 77 percent in fiscal year 2010 

to about 92 percent in fiscal year 2017. OPM officials also noted that they 

assessed the effectiveness of their guidance and trainings and any 

modifications by observing if particular types of errors decrease overall.

 35OPM, Congressional Budget Justification Fiscal Year 2018, (Washington, D.C.: May 

2017).

36GAO-14-704G.

37GAO, Federal Training Investments: Office of Personnel Management and Agencies 

Can Do More to Ensure Cost-Effective Decisions, GAO-12-878 (Washington, D.C.: Sept. 

17, 2012); and Human Capital: A Guide for Assessing Strategic Training and 

Development Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: 

March 2004).
Page 28 GAO-19-217 Federal Retirement

OPM officials provided us a list of the most common errors for fiscal year 

2017, such as a missing marriage certificate.

Although OPM officials have stated that they review two of the four types 

of assistance (guidance and training), OPM lacks a robust process for 

assessing and documenting its analysis and findings regarding all forms 

of the assistance it provides to agencies. This makes it more difficult for 

OPM to clearly demonstrate the effectiveness of its assistance. Thus, for 

example, there is limited understanding as to whether OPM’s training is 

being delivered through the most efficient and cost-effective mix of 

mechanisms. OPM may be missing opportunities to better partner with 

agencies by tailoring its assistance to help agencies improve their own 

processes and training. Assessments that result in enhancing OPM’s 

assistance to agencies could improve the completeness of applications 

submitted, which could in turn improve OPM’s application processing 

time.

With respect to the agency error report, federal internal control standards 

state that management should communicate quality information externally 

so that external parties can help the entity achieve its objectives, and 

periodically evaluate its methods of communication so that it 

communicates quality information.38 OPM officials reported that the 

current structure of the agency error reports was designed to capture the 

large overarching error-based issues many agencies face, such as 

applicants electing more life insurance coverage than permitted. OPM 

officials reported that they have not solicited input from agencies about 

the usefulness of the monthly error reports, but agencies regularly provide 

feedback to their OPM liaisons. OPM officials reported that they are 

evaluating the trends in the feedback. However, revising the structure of 

the current error reports would not be cost-effective, according to OPM 

officials. They also reported that they are considering including disability 

applications in future error reports.

The current format of the agency error report may limit its usefulness to 

agencies in improving their retirement applications and educating staff on 

how to address or minimize errors. Without user-friendly error reports, 

such as one that could be manipulated in Excel, agencies could find it 

more challenging to efficiently share the data among agency divisions 

and for the divisions to further sort the data. This challenge may be 

 38GAO-14-704G.
Page 29 GAO-19-217 Federal Retirement

particularly burdensome at agencies comprised of numerous subagencies that share responsibility for preparing higher volumes of 

retirement applications.

We found that the four selected agencies we interviewed used three 

strategies to compile accurate retirement applications, as shown in figure 

5 below.39 Some agencies also had additional strategies, such as tracking 

identified issues in applicant’s retirement applications.

Figure 5: Selected Agencies Use Three Strategies to Compile Accurate Retirement Applications

Preparing employees for retirement. The four selected agencies 

provide retirement counseling and had an agenda or a checklist to guide 

the discussion. Some of the topics included designating beneficiaries and 

eligibility to continue health insurance into retirement. DOD, HHS, USPS, 

and NASA also reported providing additional assistance to prepare 

employees for retirement. DOD’s website had calculators that could be 

 39NASA and USPS each have one office that processes retirement applications. Multiple 

components within DOD and HHS process retirement applications. So, when we mention 

an agency, it could refer to these agencies as a whole or one or more components within 

the agency.

Selected Agencies 

Have Developed 

Strategies for 

Compiling Accurate 

Applications
Page 30 GAO-19-217 Federal Retirement

used for estimating a Thrift Savings Plan annuity and survivor benefits.40

HHS stated that its employees have access to online pre-retirement 

seminars and financial planning resources. In addition, USPS has an 

employee retirement kit for that includes health insurance information, 

general retirement information, and retirement forms, such as for 

documenting life insurance and retirement effective date.

NASA also prepares employees for retirement in two additional ways. 

First, NASA reviews new employees’ electronic Official Personnel 

Folders, which contain their federal employment history, and makes 

corrections as needed. NASA officials stated it tries to resolve any issues 

in an employee’s electronic Official Personnel Folder rather than waiting 

until an employee retires. Samples of these files are then audited. 

Second, NASA stated that it encourages employees to ask for an annuity 

estimate every year for the 7 years prior to planned retirement. NASA 

reported that each annuity estimate generated includes a review of an 

employee’s files, and enables the agency to identify and address any 

errors.

Educating and training staff that compile retirement applications.

The four selected agencies hold periodic staff meetings that include 

discussions of retirement applications. For example, NASA’s meeting 

includes a discussion of common errors to avoid, unique or complex 

retirement cases, process improvements, and lessons learned. The four 

selected agencies also conduct retirement application training. For 

example, DOD provided a multiday training that included topics such as 

creditable service, annuity computation, and retirement eligibility. HHS 

also stated that it partnered with its payroll provider to present the payroll 

side of retirement processing, including retirement application processing 

and disability retirement processing. DOD, HHS, NASA, and USPS also 

reported that new staff is mentored by experienced staff.

Procedures for compiling applications. The four selected agencies 

have procedures for compiling applications. For example, the four 

selected agencies have checklists to help staff compile the required 

documents. DOD’s checklist includes a list of more than 30 documents in 

sequential order with instructions on which documents to include for each 

of the two retirement plans. In addition, the four selected agencies 

 40The Thrift Savings Plan allows federal employees to contribute a portion of their current 

compensation through payroll salary deductions, and allocate their contributions and any 

associated earnings among the available investment options.
Page 31 GAO-19-217 Federal Retirement

reported having a system to track the process of compiling applications.

DOD’s, NASA’s, and USPS’ respective systems also include tracking 

identified issues. For example, USPS’ system monitors the overall 

progress of each application, as well as tracks the status of each 

identified issue, such as missing documents, and whether the issue had 

been resolved.

The four selected agencies also conduct audits on some or all of the 

applications before submitting applications to OPM. The agencies 

reported that the audits are used to increase accuracy of submitted 

applications and provide feedback to staff on any identified errors. For 

example, DOD has an audit checklist with more than 30 items to review, 

such as whether a marriage certificate is included if applicable and if the 

application is signed.

Delays in processing retirement applications for federal employees have 

been a longstanding problem. According to OPM, it has identified root 

causes for the delays and has developed and implemented strategies to 

improve its processing operation. For example, the agency has 

developed a strategic vision for modernizing the current paper-based 

application, and employed strategies to address staffing capacity and 

minimize the number of incomplete applications. However, without 

improving its data collection and assessments of its strategies, OPM 

cannot know whether its strategies are effective at reducing the delays, or 

could be modified to yield better results. Furthermore, OPM’s plan for 

modernizing its information technology (IT) retirement processing lacks 

cost estimates and timelines, which means there are no measurable 

results with which to evaluate resource needs or interim progress.

In addition, although OPM has established a performance goal on 

processing timeliness, its related performance measure does not include 

explanatory information that could make it more meaningful. OPM also 

has not set performance measures for various parts of the application 

review and processing operation that could provide clearer insights into 

where improvements may be needed. Lack of quality performance 

information hinders applicants and external stakeholders from 

understanding OPM’s timeliness in processing applications, and limits 

OPM from better managing and monitoring program performance.

Furthermore, OPM lacks a robust process for assessing its assistance to 

agencies, which makes it difficult for OPM to demonstrate the 

effectiveness of its assistance.

Conclusions
Page 32 GAO-19-217 Federal Retirement

Potential organizational changes and other external factors have created 

additional uncertainty for OPM. These challenges notwithstanding, 

approximately 100,000 federal employees depend on OPM each year to 

process retirement benefits, such as life and health insurance, in a timely 

manner. As such, OPM should endeavor to reduce processing delays, 

monitor and report on its progress through better performance 

information, and effectively partner across the federal government to 

improve processing timeliness.

We are making the following six recommendations to OPM:

The Associate Director of OPM’s Retirement Services, working in 

coordination with the Chief Information Officer, should develop, 

document, and implement a Retirement Services IT modernization plan 

for initial project phases that is consistent with key aspects of IT project 

management, such as determining objectives, costs, and time frames for 

each initial phase. (Recommendation 1)

The Associate Director of OPM’s Retirement Services should adopt 

management practices to enhance the use of performance information on 

processing timeliness to inform how OPM manages operations, identifies 

problem areas, and allocates resources. For example, OPM could 

enhance use of performance measures at the operational level or 

establish a timeliness performance goal for reviewing disability retirement 

eligibility. (Recommendation 2)

The Associate Director of OPM’s Retirement Services should provide 

explanatory information, such as the range of processing times and the 

exclusion of disability retirement eligibility determinations, as part of the 

performance measure on processing timeliness. (Recommendation 3)

The Associate Director of OPM’s Retirement Services should develop 

and implement policies and procedures for assessing strategies intended 

to improve processing times, including collecting and improving data 

needed to support those strategies, such as collecting better productivity 

data or staffing data and linking them to processing outcomes. 

(Recommendation 4)

The Associate Director of OPM’s Retirement Services should examine its 

process for assessing its assistance to agencies on retirement 

applications. For example, OPM could incorporate into its assessment 

process more agency feedback or documentation of assessment results, 

Recommendations for 

Executive Action
Page 33 GAO-19-217 Federal Retirement

which could improve its partnership with agencies to strengthen the 

assistance provided. (Recommendation 5)

The Associate Director of OPM’s Retirement Services should work with 

agencies to determine if there are cost-effective ways to make the 

retirement application error report that it sends to agencies more userfriendly. For example, explore whether there are cost-effective ways to 

provide the error report in a format that could be manipulated (e.g., Excel 

spreadsheet), or to include additional information, such as incorporating 

disability retirement applications or providing clearer descriptions of errors 

or trend data, some of which OPM already collects. (Recommendation 6)

We provided a draft of the report to OPM, DOD, HHS, NASA, and USPS 

for review and comment. In its comments, reproduced in appendix I, 

OPM concurred with 1 recommendation and partially concurred with the 

remaining 5 recommendations. HHS and NASA provided technical 

comments, which we incorporated as appropriate. DOD and USPS had 

no comments on the draft. 

OPM partially concurred with our first recommendation to develop, 

document, and implement a Retirement Services IT modernization plan 

that includes costs and time frames for initial project phases. OPM stated 

that it has established initial high-level funding estimates for each of its 

five key IT initiatives, but OPM did not provide any documentation or 

further details. OPM cited that its ability to implement the modernization 

plan depends on the availability of funding and coordination with the 

agency’s top leadership. We agree these are important elements, which 

further underscore our recommendation. An IT modernization plan with 

objectives, cost estimates, and time frames could help support funding 

requests, as well as measure progress in implementing the initiatives.

OPM partially concurred with our second recommendation to enhance the 

use of performance information on processing timeliness to make more 

informed management decisions. OPM responded that it measures 

overtime spending, reviews daily work level in each work unit, and 

assesses employee productivity in these units. Collecting and reviewing 

such operational-level data contributes to monitoring efforts; however our 

recommendation emphasizes the importance of using performance 

information to better manage operations to align with organizational 

goals. 

Agency Comments

and Our Evaluation
Page 34 GAO-19-217 Federal Retirement

OPM partially concurred with our third recommendation to provide 

explanatory information as part of its reporting of processing timeliness. 

OPM agreed to add an explanation about disability retirement eligibility 

determinations to its public reports. OPM disagreed that reporting data on 

the range of processing times would be beneficial because, according to 

OPM, it provides processing information through other means, such as 

through applicants’ online accounts and agency benefit officers. While 

providing this information is beneficial, publically reporting data on the 

range of processing times helps improve the usefulness of performance 

information for applicants and external stakeholders, such as 

congressional oversight committees. Further, OPM acknowledged that it 

already collects and shares such data, which confirms it has the 

information and ability to implement this recommendation by adding 

appropriate summary notes to its public reporting. This action coupled 

with adding an explanation about disability retirement eligibility 

determinations should address the recommendation. 

OPM partially concurred with our fourth recommendation to develop and 

implement policies and procedures for assessing strategies intended to 

improve processing times, including collecting data needed to support 

those strategies. OPM stated that a new case management system could 

provide better productivity and staffing data with which to assess 

effectiveness, but is dependent on funding and IT support. However, 

developing policies and procedures to manage and monitor its 

assessment process—such as determining when, how, and how often to 

conduct assessments and what data to collect—is not dependent on 

having a new case management system. In fact, establishing such 

policies and procedures could help inform system requirements in terms 

of data and reporting needs. 

OPM concurred with our fifth recommendation to examine its process for 

assessing its assistance to agencies on retirement applications, and 

stated that it will incorporate more agency feedback into its assessment 

results on non-disability immediate retirement applications. 

OPM partially concurred with our sixth recommendation to work with 

agencies to determine if there are cost-effective ways to make the error 

report more user-friendly. OPM stated that it will explore using MS Excel 

spreadsheets and incorporating clearer descriptions of errors and data 

trends. OPM asserted that our report incorrectly states that the data sent 

to agencies cannot be manipulated as agencies receive the data in 

MSWord documents from which they can create MS Excel spreadsheets. 

However, as OPM acknowledges, agencies have to create their own 
Page 35 GAO-19-217 Federal Retirement

spreadsheets. Doing so requires agencies to manually enter the data to 

track and analyze errors, which increases the risk of data entry mistakes 

that could compromise the accuracy of original data, as we reported. 

OPM also stated that collecting disability application error information is 

not an inexpensive or simple process change. While we recognize OPM’s 

audit efforts may need to be modified to capture this type of error 

information, it would provide agencies with more comprehensive error 

data that could be used to improve the agencies’ application processes.

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

this report earlier, we plan no further distribution until 30 days from the 

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

appropriate congressional committees, the Acting Director of OPM, the 

Secretary of DOD, the Secretary of HHS, the Administrator of NASA, and 

the Postmaster General and Chief Executive Officer of USPS. In addition, 

the report is available at no charge on the GAO website at 

http://www.gao.gov.

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

me at (202) 512-6806 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 II.

Yvonne D. Jones

Director, Strategic Issues
Appendix I: Comments from the Office of 

Personnel Management

Page 36 GAO-19-217 Federal Retirement

Appendix I: Comments from the Office of 

Personnel Management
Appendix I: Comments from the Office of 

Personnel Management

Page 37 GAO-19-217 Federal Retirement
Appendix I: Comments from the Office of 

Personnel Management

Page 38 GAO-19-217 Federal Retirement
Appendix I: Comments from the Office of 

Personnel Management

Page 39 GAO-19-217 Federal Retirement
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-19-217 Federal Retirement

Yvonne D. Jones, (202) 512-6806 or Jonesy@gao.gov

In addition to the contact name above, Leah Querimit Nash (Assistant 

Director), Maya Chakko (Analyst in Charge), Mark Bird, Jackie Chapin, 

Jeff DeMarco, Elizabeth Fan, Gina Hoover, Ted Hu, Ben Licht, Meredith 

Moles, Robert Robinson, and Kayla Robinson made key contributions to 

this report.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102347)
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