GAO/GGD-00-170R PricewaterhouseCoopers’ Management Review of ONDCP

United States General Accounting Office

Washington, DC 20548

General Government Division

June 26, 2000

The Honorable Ben Nighthorse Campbell

Chairman

The Honorable Bryon L. Dorgan

Ranking Minority Member

Subcommittee on Treasury and General Government

Committee on Appropriations

United States Senate

The Honorable Jim Kolbe

Chairman

The Honorable Steny H. Hoyer

Ranking Minority Member

Subcommittee on Treasury, Postal Service,

 and General Government

Committee on Appropriations

House of Representatives

Subject: PricewaterhouseCoopers’ Review of the Office of National Drug Control

Policy

Enclosed is the final report by PricewaterhouseCoopers LLP on the performance,

efficiency, and effectiveness of the Office of National Drug Control Policy’s

(ONDCP) operations. Senate Conference Report 106-87 directed GAO to contract

with an independent entity for the purpose of conducting a management review

of ONDCP’s operations. In this regard, we developed a scope of work that

addressed the management concerns raised by the conferees and identified in the

conference report; specifically:

“The review should include, but not be limited to, a review of the agency’s (1) execution

of its statutory responsibilities; (2) organizational planning, management, budgeting,

accounting and financial reporting systems; and (3) human resource management to

include a review of staff hiring and retention.”

We performed the administrative duties necessary to award and monitor the

contract, and ensured that the contractor deliverables were responsive to the

scope of the contract. As directed by the conferees, we also consulted with the

Committees on Appropriations on the parameters of this review.
Page 2 GAO/GGD-00-170R PricewaterhouseCoopers’ Management Review of ONDCP

PricewaterhouseCoopers was selected in a competitive process to perform this

review, and they met the terms contained in the contract statement of work. The

findings and conclusions expressed in their report are solely those of

PricewaterhouseCoopers. Please contact me or Weldon McPhail on (202) 512-8777 if

you or your staff have any questions about the management of this effort. Questions

regarding the findings or conclusions of the report should be directed to

PricewaterhouseCoopers’ Michael Cosgrove on (703) 633-4000.

Richard M. Stana

Associate Director, Administration

 of Justice Issues

Enclosure


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TABLE OF CONTENTS

EXECUTIVE SUMMARY..................................................................................1

OUR FINDINGS........................................................................................................................................................1

1.0 OUR APPROACH.........................................................................................5

2.0 WHAT WE HAVE OBSERVED.......................................................................6

 2.1 IN GENERAL, ONDCP IS A SOPHISTICATED ORGANIZATION OPERATING FROM A PROCESS

 PERSPECTIVE........................................................................................................................................................6

 2.2 ...BUT THE INCREASING WORKLOAD AND INABILITY TO RETAIN PERSONNEL IS

 SIGNIFICANTLY HINDERING PERFORMANCE..............................................................................................9

3.0 THE INSTITUTIONALIZATION OF ONDCP...................................................13

 3.1 AUTHORITY IS CENTRALIZED AND THE LINES OF AUTHORITY ARE UNCLEAR.........................13

3.1.1(a) Authority has been centralized in the Office of the Director..........................................................13

3.1.1(b) The chain of command can be confusing.......................................................................................15

3.1.1(c) The managerial role of the Deputy Director of ONDCP is unclear...............................................18

3.1.1(d) ONDCP has had difficulty recruiting and retaining component Deputy Directors.......................19

3.1.1(e) What are other explanations for the difficulty in recruiting and retaining component Deputy

Directors?....................................................................................................................................................19

3.1.1(f) How would the presence of component Deputy Directors affect ONDCP?...................................21

3.1.1(g) Other Relevant Business Practices – Senior Advisory Steering Group.........................................21

 3.2 ONDCP'S TURNOVER HAS BEEN VERY HIGH........................................................................................23

 3.2.1 Turnover Rates............................................................................................................................................23

3.2.1(a) ONDCP Calendar Year 1998 Turnover.........................................................................................24

3.2.1(b) ONDCP Calendar Year 1999 Turnover.........................................................................................24

3.2.1(c) ONDCP Calendar Year 2000 Actual Turnover and Potential Turnover Associated with the year

2000 Election...............................................................................................................................................24

3.2.1(d) Reasons for Turnover.....................................................................................................................30

3.2.1(e) Human Resource Business Practices..............................................................................................34

3.2.1(f) Other Relevant Business Practices – Leadership Style...................................................................36
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3.2.1(g) The Director’s Schedule.................................................................................................................37

 3.3 FORMAL GUIDANCE TO GOVERN THE COMPONENTS AND OFFICES BEYOND THE CURRENT

 DIRECTORSHIP WAS NOT AVAILABLE..........................................................................................................40

 3.3.1 ONDCP-Specific written policies and procedures were not available........................................................41

 3.3.2 The Organization Charts provided are temporary and in conflict with each other.....................................41

 3.3.3 Other Relevant Business Practices – Policies and Procedures....................................................................42

 3.4 SUMMARY OF HR AND ORGANIZATIONAL ANALYSIS.......................................................................42

4.0 BUDGETING, ACCOUNTING, AND FINANCIAL REPORTING SYSTEMS AND

INTERNAL CONTROLS..........................................................................................................43

 4.1 INTERNAL CONTROL RISK..........................................................................................................................43

 4.2 DISCRETIONARY AND NON-DISCRETIONARY FUNDING AVAILABLE TO THE DIRECTOR AND

 ONDCP SENIOR MANAGEMENT.......................................................................................................................45

 4.3 THE IMPACT OF THE PROGRESSIVE INCREASE IN WORKLOAD AND OPERATIONAL TEMPO

 WITHIN THE FINANCIAL MANAGEMENT OFFICE........................................................................................46

 4.4 POTENTIAL FOR IMPROVEMENT BY REENGINEERING WORKING PRACTICES AND

 INTRODUCING NEW TECHNOLOGY...............................................................................................................47

 4.4.1 Reengineering ways of working....................................................................................................................47

 4.4.2 Investing in technology.................................................................................................................................47

APPENDICES...................................................................................................................49

Appendix A: ONDCP Employees Interviewed...........................................................................................................49

Appendix B: The External Organizations Researched and/or Interviewed in the Public and Private Sector.............50

Appendix C: Three Original Versions of ONDCP Organization Charts....................................................................51

Appendix D: Summary Analysis of ONDCP Internal Financial Control Risk...........................................................52

Appendix E: U.S. Department of Justice Office of Legal Counsel – Memorandum for Agency Counsels; General

Guidance on the Federal Vacancies Reform Act of 1998...........................................................................................55

Appendix F: ONDCP’s Response Letter to a Preliminary Draft of the Report..........................................................56

Appendix G: Legislative Citations..............................................................................................................................57

Appendix H: ONDCP Mission Statements and Position Descriptions.......................................................................61

Appendix I: Excerpt from The Retired Officer Association (TROA) Magazine, June 2000, Vol. LVI. No. 6,

“Soldiering On: General Barry McCaffrey Talks with Tom Philpott”.......................................................................62

Appendix J: Full Breakdown of the Director’s Schedule...........................................................................................63
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EXECUTIVE SUMMARY

In consultation with Congress, the General Accounting Office (GAO) has contracted with

PricewaterhouseCoopers, L.L.P. to conduct a comprehensive evaluation of the

performance, efficiency, and effectiveness of the Office of National Drug Control Policy

(ONDCP). Referring to the contract Statement of Work, GAO specifically requires an

assessment of:

1. whether ONDCP performs its statutory and regulatory responsibilities in an efficient,

effective, and results-oriented manner;

2. whether ONDCP optimizes human resources in fulfilling its primary objectives of policy,

anti-drug program coordination, and compliance; and

3. whether ONDCP's internal control systems are strategically deployed to enhance business

processes throughout the organization.

The primary outcome of this assessment will appraise and identify opportunities for

enhancing ONDCP's effectiveness in executing its statutory responsibilities and its

current management structure's ability to achieve mission results. This will be

accomplished through improvements in human resource management, organizational

planning, management, and performance measures related to operational planning and

financial and human resource management.

OUR FINDINGS

1. With regard to whether ONDCP performs its statutory and regulatory responsibilities in

an efficient, effective, and results-oriented manner, it is our opinion that ONDCP is

results-oriented and effective in performing its responsibilities externally, but inefficient

with regard to internal operations.

In general, the project team found that ONDCP has a clearly defined external mission,

associated goals, specific impact targets, and a performance tracking method for Drug

Control Program agency performance. In their most recent publication of the 2000

Annual Report of the National Drug Control Strategy, ONDCP reports that drug use in

targeted impact areas has declined and that attitudes against drug use have increased,

according to Health and Human Services (HHS) and other relevant data sources.

ONDCP lacks, however, the same set of goals, targets, and measurements associated with

its internal operations. The framework that has been effectively used to develop goals,

targets, and performance tracking for the Drug Control Program agencies as a whole

could be used to develop internal metrics for how ONDCP achieves its unique objectives

of policy, coordination, and compliance. Documentation relevant to the internal

operations of the components and functional offices and performance of the organization

itself was not available. Recruitment and retention issues have also been problematic for
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ONDCP, and the efficient continuity of the organization beyond the current directorship

is an issue.

The organization could become more effective and results-oriented internally by

addressing the following performance management issues:

• develop goals, objectives, and performance measures of effectiveness for the internal

processes and objectives of ONDCP. It would make good business sense to establish

internal performance measures for the organization's primary objectives.1

The organization could become more efficient and effective by addressing the following

human resource management issues:

• ensure that the Office of Administration is allocated sufficient Full-Time Equivalents

(FTE) commensurate with its size and workload in order to address human resource

and retention issues;

• institute a formal exit interview practice;

• take measures to address retention issues;

• target individuals with appropriate skill sets and compatible work ethics during

recruiting;

• manage the expectations of potential employees during the recruiting process;

• institute career development practices within ONDCP for civilian employees;

• provide training opportunities for civilians and ensure that opportunities to apply the

training are made available within the organization;

• evaluate the ONDCP-specific guideline regarding GS-14 to GS-15 promotion for its

impact on the retention of GS-14 career civilians; and

• evaluate the practice of filling supervisory GS-15-equivalent positions with military

detailees for its impact on the promotion and retention of GS-14 career civilians.

These initiatives should contribute significantly to improvements in efficiency and

effectiveness internally, with recruitment, retention, and continuity being of primary

importance.

2. With regard to whether ONDCP optimizes human resources in fulfilling its primary

objectives of policy, anti-drug program coordination, and compliance, it is our opinion

that human resources are not being optimized toward accomplishing those objectives.

We determined, however, that ONDCP’s inability to sustain support for the primary

objectives is a result of increases in the workload associated with new program

requirements, the Director's priorities, and ONDCP’s inability to maintain its knowledge

 

1 In a response to a draft version of this report, ONDCP stated on page 9 of its letter dated June 7, 2000 (see

Appendix F) that the project team “erred in asserting that ONDCP lacks internal targets and measures.”

ONDCP stated that it had provided a GPRA-compliant Performance Report to OMB in calendar year 1999.

The project team requested a copy of the Performance Report but had not received it by the time this report

was released. The external Performance Measures of Effectiveness (PME) documents are on ONDCP’s

website, but the above referenced Performance Report is not available via the internet.
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base by retaining staff. The organization could make progress toward optimizing human

resources by addressing the following issues:

• address the human resource and retention issues previously discussed; and

• evaluate the pace of the Director’s Schedule in consideration of its impact on the

operational tempo of ONDCP, the retention of employees and the organization’s

capability to support its primary objectives of policy, coordination, and compliance.

3. With regard to whether ONDCP's internal control systems are strategically deployed to

enhance business processes throughout the organization, it is our opinion that there is an

overall low to medium risk that the organization is not adhering to sound and prudent

internal financial controls. There is, however, an area that should warrant further

attention. There is a potential internal control risk arising from inadequate matching of

increased responsibilities and workload with the required investment in the financial

management infrastructure. The significant implications of not mitigating the risk of a

breakdown in the management, supervisory, and personnel internal controls are:

• a lack of quality assurance over work products due to time pressures;

• inappropriate levels of authority, delegation, and decision-making, given underlying

roles, responsibilities, and competencies; and

• a decline in customer service from the Financial Management Office (FMO).

We would classify this as a medium risk. Should the investment not be made, however,

the result would be increased exposure and a greater likelihood of breakdown in this area

of internal control.

Although it was not explicitly requested in the Statement of Work, the project team

evaluated the organization for continuity and institutionalization beyond the tenure of the

current Administration. As an official of the United States Government, the Director of

ONDCP is a steward of the public trust. It is incumbent upon the Director, therefore, to

provide for the institutionalization and continuity of the organization beyond his or her

tenure. In the course of this evaluation, the project team identified issues that raise

concerns about the future continuity of ONDCP: 1) authority is centralized and a

significant amount of institutional knowledge resides with the current Director; 2) the

knowledge base has been eroded by recruitment and retention problems in recent years;

3) relative to its size, an inordinate number of leadership and professional staff positions

(up to 38%) may be vulnerable in calendar year 2000; and 4) ONDCP-specific written

guidance addressing the activities within the components and functional offices that

would contribute to the continuity of the organization appears to be largely absent.
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The organization could avoid continuity problems in the future by addressing the

following issues, in addition to those discussed previously:

• institute succession planning to ensure a smooth transition in the event that the

Director becomes incapacitated;

• clarify the authority, responsibility, and reporting structure with regard to the Deputy

Director and the Chief of Staff;

• address chain of command issues to be consistent with good organizational

management;

• fill the component Deputy Director positions; and

• develop written policy and procedures for component and functional office activities

to ensure continuity of the organization beyond the tenure of the current Directorship.

In summary, we have observed that although the organization is generally sophisticated,

there is a shortage of investment and staff resources to accomplish all of the activities and

objectives imposed by Congress, the Director, and the legislative charter. The shortage is

equally attributable to the increase in workload associated with new activities, supporting

the Director's priorities, and the inability of the organization to recruit and retain qualified

staff.

A draft version of this report was provided to ONDCP for comment prior to the formal

release of the document.

The ONDCP response letter is included in its entirety in Appendix F. Factual corrections

to text and clarifications were addressed in footnotes where appropriate throughout the

document.
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1.0 OUR APPROACH

The PricewaterhouseCoopers project team developed a high-level understanding of the

internal and external business processes at ONDCP. In doing so, the team conducted

approximately 25 structured interviews with key personnel2 and stakeholders, using a

broad-based interview guide. The guide was prepared after the team had extensively

reviewed GAO reports, Congressional hearings, ONDCP documents, and other reports.

We also conducted web-based research into departments and agencies relevant to the

drug control program processes. Based on this information, the team developed a

baseline of the existing internal and external processes and structures within ONDCP.

Structured

Interviews

Structured

Interviews

Desktop-Based

Research

Desktop-Based

Research

Business

 Practices

Study

Business

 Practices

Study

 Project-Based

Knowledge

 Project-Based

Knowledge

 Gathered

 Empirical Evidence

 Gathered

 Empirical Evidence

 Created Baseline

ONDCP Business

Process Chart

 Created Baseline

ONDCP Business

Process Chart

Applied

Public/Private Sector

Practices

Applied

Public/Private Sector

Practices

Identified

Differences

Identified

Differences

Second, we researched other business models in the private and public sectors. Our goal

was to identify organizations with similar characteristics or business processes for

comparison of practices.3 The team researched and benchmarked practices in both the

federal, commercial, non-governmental, and non-profit arenas. We interviewed

representatives from relevant external organizations such as America’s Promise, Office

of the United States Trade Representative (USTR), the American Heart Association, and

others. With external interviews completed, we sketched and mapped other business

practices and structures based on our findings.

Third, we evaluated the current ONDCP structure and business practices against other

structures and practices in order to identify and address differences. Our timeline for

conducting the interviews and delivering the final report is represented graphically

below:

 Developed Project

Work Plan

April 22 , 2000

 Completed Initial

 ONDCP Interviews

 Completed Business

 Practice Interviews

 Delivered Assessment

 Results

March 1, 2000 April 15, 2000 June 15, 2000

Our Timeline

 

2

 A list of ONDCP personnel interviewed is included in Appendix A.

3

 A list of organizations interviewed and researched during the business practices review is included in

Appendix B.
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2.0 WHAT WE HAVE OBSERVED

According to the FY98 reauthorization legislation, there is established in the Executive

Office of the President (EOP) an Office of National Drug Control Policy, which shall –

• develop national drug control policy;

• coordinate and oversee the implementation of that national drug control policy;

• assess and certify the adequacy of national drug control programs and the budget for

those programs; and

• evaluate the effectiveness of the national drug control programs.

Its primary objectives are policy, anti-drug program coordination, and compliance. For

the most part, the project team found that ONDCP is a sophisticated organization. It has

a clearly defined external mission and associated goals that are highly visible on walls

around the office. ONDCP operates as a sophisticated organization in that it is structured

in components according to its business processes and coordination responsibilities,

rather than according to responsibilities by function (personnel services, financial

services, etc.). It is organized as directed by the 1998 reauthorization legislation

according to the following business processes: Demand Reduction, Supply Reduction and

Domestic Law Enforcement (Bureau of State and Local Affairs). There is also a fourth

main component that handles the coordination of Drug Control Program agency

programs, budgets, and external performance metrics.4

 In addition, all of the activities

within the components and functional offices appear to be congruent with their respective

component or office mission and there appears to be significant commitment from the

leadership for activities and initiatives.

In order to evaluate whether ONDCP is results-oriented and effective, the project team

assessed whether the organization has a clear and targeted mission, a strategy, objectives,

requirements, performance measurements, and a method to assess performance. In order

to determine whether ONDCP is efficient, the project team assessed whether the

organization has sufficient capacity to meet its objectives and whether the resources have

been deployed appropriately.

External Mission

In terms of its external, mission-oriented performance, ONDCP has been successful in

developing goals, objectives, and performance impact targets and in tracking progress

against them. It has developed an annual National Drug Control Strategy that discusses

 

4

 The Counter-Drug Technology Assessment Center operates according to a legislative charter with its own

independent budget.

2.1 IN GENERAL, ONDCP IS A SOPHISTICATED ORGANIZATION

OPERATING FROM A PROCESS PERSPECTIVE....
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the overall goals of the Drug Control Program agencies over a ten-year time period. The

goals have been translated into objectives, which can be easily mapped onto the business

processes of the ONDCP organization. Moreover, the goals are visible on walls

throughout the office and all of the above information is available via their website. In

their most recent evaluation,5

 ONDCP reports that drug use in targeted impact areas has

declined and that attitudes against drug use have increased, according to Health and

Human Services (HHS) and other relevant data sources. An example of ONDCP’s

performance measurements for certain operations, such as the High Intensity Drug

Trafficking Areas (HIDTA) program, is presented below:6

Similar targets and performance measures are set for other ONDCP operational programs

such as the Media Campaign, Drug-Free Communities, and the Counter-Drug

Technology Assessment Center (CTAC).

 

5

 2000 Annual Report on the National Drug Control Strategy

6

 Excerpt taken from 1998 – 2007 Performance Measures of Effectiveness

GOAL 2, OBJECTIVE 2: IMPROVE THE ABILITY OF HIDTAS TO COUNTER DRUG-TRAFFICKING

TARGETS MEASURES

1. HIDTA Development -- Each HIDTA will 1. The percentage of HIDTAs that meet or

improve the scope and efficiency of the HIDTA exceed the established milestones for the

Program by the progressive adoption of National HIDTA Developmental Standards

the National HIDTA Developmental Standards as developed and distributed in the 1998

at the rate of at least 10 percent per annum, HIDTA Program guidance.

reaching the 90 percent level by 2007. 

 Reporting agencies: each HIDTA, Drug

 Enforcement Agency (DEA), FBI.

2. Drug trafficking organizations in HIDTAs -- 2. Proportion of identified drug trafficking

By 2002, increase the proportion of drug trafficking organizations disrupted or dismantled by or

organizations disrupted or dismantled as identified in within HIDTAs.

HIDTA threat assessments by 15 percent above the

proportion in the 1997 base year. By 2007, increase Reporting agencies: DEA, Defense, State

the proportion disrupted or dismantled to 30 percent FBI, U.S. Customs, Treasury.

above base year ratio.

3. Drug-related violent crime in HIDTAs -- By 2002, 3. Reported rate of homicides, robberies,

reduce by 20 percent the rate of drug related homicides, rapes, and assaults in HIDTAs that are

robberies, rapes, and assaults in HIDTAs as compared to associated with distribution, sale, or

the 1996 base year. By 2007 reduce specified drug-related consumption of illicit drugs as measured

crimes in HIDTAs by 40 percent. by available crime indicators.

 Reporting agencies: each HIDTA, DEA,

 Justice, FBI, Treasury.
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Internal Operations and Structure

While the staff members of ONDCP have been successful in measuring the performance

of external operations, they have not been as successful in terms of monitoring internal,

process-oriented performance measurements. Documentation relevant to the internal

performance of the organization was not available, and there are no set performance

measurements for internal primary objectives. Although ONDCP has mission statements

and position descriptions dated May 1996, few policy or procedural documents regarding

the operations of the components or functional offices were available.7 Those that were

available were created at the initiative of individual managers. Where basic ONDCP

documentation does exist, it is not current. The mission statement and position

description document for the organization has not been updated since May 1996 when the

organization had approximately 40 persons on the payroll (although abbreviated mission

descriptions for each office dated 1998 are on the website). In addition, the

organizational charts that were provided in March 2000 were still “proposed,” were

inconsistent with each other, and did not reflect the reality of current operations.

ONDCP does, however, operate within a sophisticated structure. In evaluating

management, an organizational analyst checks to see whether the organization is

structured to achieve the desired results. Most organizations have at least two

requirements. First, an organization will have an idea generation or consensus building

requirement. This is most effectively handled with a team-based structure. Second, an

organization will have a final decision making and arbitration requirement, which is most

effectively handled by a streamlined chain of command structure. In evaluating ONDCP

specifically, the project team found that both the command structure and the consensus

building team structure with relevant activities exists within the organization.

The project team also found that, according to the organizational charts, each process

component has a civilian leader at its head, rather than a team or committee of leaders.

It is important that final decision-making be consolidated into one position so that an

individual can be held appropriately accountable for results.

A graphical representation of our understanding of the structure of ONDCP is presented

in Figure 1. The shaded areas represent components that execute the core business

processes of the organization. The non-shaded areas represent the functional offices that

support the Director and the core components as needed. The boxes below each

component office show how each of the goals as outlined in the Strategic Plan lines up

with a specific process.

 

7

 Policy, procedure, and guidance documents exist within the Office of Administration regarding facilities

and maintenance, security, contracts, and other areas pertinent to office and facilities administration.

Policy, procedure and guidance documents regarding organizations within the Executive Office of the

President are available through the Office of Legal Counsel.
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Figure 1: Our Understanding of the Current ONDCP Structure

D ep D irector

O ffice of

D em and

R eduction

D ep D irector

B ureau of S tate

and L ocal 

A ffairs

D ep D irector

O ffice of

S upply

R eduction

D irector

Program s,

Budget

an d E valuation

D irector

C o unter-D rug 

T echnology

A ssess C tr

D irector

ONDCP

C hief 

of Staff

O ffice of 

L egal C ounsel

O ffice of 

L egislative A ffairs

D eputy 

D irector

O ffice of 

A dm inistration

F inancial 

M gm t O ffice

O ffice of 

S trategic P lannin g

O ffice of 

P ublic A ffairs

M edia C am paign

T reatm ent

P olicy 

C oordination

P revention

P olicy 

C oordination

D rug Free

C om m unities

D om estic 

L aw E nforcem ent P olicy

C oordination

H ID T A

Interdiction

G eographic 

A rea

G eographic

A rea

E valuation

Budget

Program s

• Goal 1: Reduce drug use by young people.

• Goal 2: Target domestic sources of illegal drugs and crime associated with criminal

enterprises.

• Goal 3: Make treatment available to chronic users.

• Goal 4: Interdict the flow of drugs at our borders.

• Goal 5: Target international sources of illegal drugs and crime associated with

criminal enterprises.

Over the last four years, ONDCP has acquired or experienced an increase in operational

program activities to include the National Youth Anti-Drug Media Campaign, the Drug

Free Communities program, and the HIDTA program. While it is logical to place new

initiatives and growing programs under the close purview of a strong and committed

leader, the addition of operational programs without an associated FTE allowance has

added a dimension of overload and complexity to the organization. Given that ONDCP's

operational programs call for individuals with a different set of skills, mindset, and

2.2 ...BUT THE INCREASING WORKLOAD AND INABILITY TO RETAIN

PERSONNEL IS SIGNIFICANTLY HINDERING PERFORMANCE.

Goal 1

Goal 3

Goal 2 Goal 4

Goal 5
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competencies than those required for coordination activities, ONDCP has attempted to

balance the mix of active, operational types with more passive, consensus builders.

The chart in Figure 2 highlights the offices or components that are conducting operational

activities and have experienced a significant increase in the scope of their operational

requirements. Those increases have resulted either from a redirection of effort based on

the priorities of the Director when he took over in 1996 or at the direction of Congress

from 1997 to the present.

Figure 2: ONDCP Offices Conducting Operational Activities

D ep D irector

O ffice of

D em and

R eductio n

D ep D irector

B ureau o f State

and L ocal 

A ffairs

D ep D irector

O ffice of

Supply

R eduction

D irector

Program s,

Budget

and E valuation

D irector

C ounter-D rug 

T echnology

A ssess C tr

D irector

ONDCP

C hief 

of Staff

O ffice of 

L egal C ounsel

O ffice of 

L egislative A ffairs

D eputy 

D irector

O ffice of 

A dm inistration

Financial 

M gm t O ffice

O ffice of 

Strategic Planning

O ffice of 

P ublic A ffairs

M edia C am paign

T reatm ent

P olicy 

C o ordination

Prevention

P olicy 

C o ordination

D rug Free

C om m unities

D om estic 

L aw E nforcem ent Policy

C oordination

H ID T A

Interdiction

G eographic 

A rea

G eographic

A rea

• High Intensity Drug Trafficking Areas (HIDTA) Program provides additional

Federal funds to areas within the United States which exhibit serious drug trafficking

problems and harmfully impact other areas of the country. Law enforcement

organizations within these areas assess drug trafficking problems and design specific

initiatives to reduce or eliminate the production, manufacture, transportation,

distribution, and chronic use of illegal drugs and money laundering. Since 1990, 31

areas within the United States have been designated as HIDTAs.

• National Youth Anti-Drug Media Campaign (Media Campaign) is an initiative to

encourage kids to stay drug-free. The Campaign targets youth ages 9 to18, especially

vulnerable middle-school adolescents, their parents, and other adults who influence

the choices that young people make. To get the word out across every economic and

cultural boundary, the Campaign uses a mix of modern communications techniques --

from advertising and public relations to interactive media -- and all possible venues --

from television programs to after-school activities -- to educate and empower young

people to reject illicit drugs.
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• Drug-Free Communities Grant Program is designed to strengthen communitybased coalition efforts to reduce youth substance abuse. The program enables these

coalitions to enhance collaboration and coordination in an effort to target the use of

illegal drugs, as well as the underage use of alcohol and tobacco. The program is

administered by the Justice Department's Office of Juvenile Justice and Delinquency

Prevention (OJJDP) with an interagency agreement with ONDCP. Through a

competitive review process, ONDCP and OJJDP select new grantees to receive

awards of up to $100,000 for a one-year period.

• Counter-Drug Technology Assessment Center (CTAC) is the central counter-drug

enforcement research and development organization of the U.S. Government. It

develops and implements the National Counter-Drug Enforcement Research and

Development Strategy, which identifies and defines the scientific and technological

needs of Federal, state, and local drug enforcement agencies. CTAC is also

responsible for conducting research and development activities related to drug abuse,

addiction, and rehabilitation.

• The Director's Schedule (Office of Strategic Planning and Office of Public

Affairs) is the calendar of events that documents the Director’s participation at all

policy-related meetings, event appearances, speeches, print interviews, television

appearances, general office responsibilities, personal appointments, and travel. In

1996, the Director structured ONDCP to handle its primary objectives of policy,

coordination, and compliance and to coordinate his external appearance schedule. At

the behest of the Administration, the Director created an internal apparatus so that he

could use the “bully pulpit” to raise the awareness of the American public to the

dangers of drug use.8

 The project team estimated that the Director’s schedule requires

the effort of up to 17 FTE9

 and draws on the staff resources of the policy and

coordination components.

 

8

 On page 1 of ONDCP’s response to a draft version of this document, ONDCP indicated that the project

team did not recognize “a major ONDCP responsibility” of “policy articulation” which was defined as “the

important ONDCP mission of explaining policy to other governments, elected officials at the federal, state,

and local level, opinion leaders, the private for-profit and non-profit sectors and the public.”

 ONDCP cited legislative citation 21 USC 1703, which outlines the 15 responsibilities of the Director,

ONDCP (See Appendix G for full text of legislation). Section (a) (11) states that the Director “may serve

as a spokesman for the Administration on drug issues.” Of the 15 responsibilities outlined in that section,

13 paragraphs direct that the Director “shall” conduct functions whereas 2 paragraphs indicate that the

Director “may” conduct functions. Consequently, the “shall” functions are probably of higher priority than

the “may” functions on the scale of a Director’s responsibilities.

 ONDCP also referenced 21 USC 1705, pertaining to the development and submission of the National

Drug Control Strategy (See Appendix G). Section (a)(3) states that the Director shall consult with, rather

than “explain to” (from the ONDCP text), heads of Drug Control Program agencies, Congress, state and

local officials, private citizens and organizations with expertise and experience in demand and supply

reduction and appropriate representatives of foreign governments. The legislation does not mandate the

Director to explain drug control policy to “opinion leaders” or to “the public.”

9

 The 17 FTE estimated for the Director’s Schedule include 1 FTE from the Office of the Director, 5 FTE

from the Office of Strategic Planning, 7 FTE from the Office of Public Affairs, 1⁄2 FTE handling travel from

the Office of Administration, 1⁄2 FTE from the Office of Legislative Affairs, and 3⁄4 FTE from each of the

four main components. Component support was based on the formula that one hour in the Director’s

Schedule requires approximately 8 hours of component staff support, as estimated by ONDCP leadership.
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Over the past three years, the program and operational workload at ONDCP has increased

substantially with Congress creating or increasing requirements associated with mandated

programs. For example, the HIDTA program has grown from 15 to 31 areas over the

past four years. These operational programs require a substantial number of FTE, leaving

fewer to handle the primary policy, coordination, and compliance responsibilities. The

project team isolated the number of existing FTE associated with each of the operational

programs and developed the following estimates:

Media Campaign 7 FTE from Demand Reduction

Drug Free Communities 2 FTE from Demand Reduction

HIDTA 5 FTE from State and Local Affairs

Director’s Schedule 17 FTE from various offices

We then backed out the number of existing FTE left to support the primary objectives

based on information from ONDCP organizational charts:

Office of Demand Reduction 16 FTE

Bureau of State and Local Affairs 9 FTE

Office of Supply Reduction 24 FTE

Programs, Budget and Evaluation 22 FTE

ONDCP employees indicated in the interviews that although policy, coordination, and

compliance activities do occur, staff members generally do not have an appropriate

amount of time to properly plan and execute efficient and successful meetings.10 This is

particularly apparent in the Bureau of State and Local Affairs which has 50% of the staff

resources of other components, but has a most challenging coordination objective of

encouraging private sector and local community initiatives. Staff resources across

ONDCP have been stretched thin, and the workload and operational tempo of the

organization is exceedingly high in all areas. In our opinion, most of the offices within

ONDCP operate in the face of the following trade-off: either the policy, coordination, and

compliance activities do not get adequately planned for or the staff is burdened by the

fast pace and exceedingly long working hours. Many times, they operate under both

conditions.

In summary, we have observed that although the organization is sophisticated and

accomplished, there is a shortage of investment and staff resources resulting in an

inability to meet all of the objectives and priorities of the Congress, the Director, and the

 

On page 10 of ONDCP’s response, ONDCP states that “the conclusion that 20 FTEs support the Director’s

schedule is wrong.” The project team has reviewed the activities of the Office of Strategic Planning and

has revised the number of FTE dedicated from that office to supporting the Director’s Schedule from 7 to 5

FTE. Upon revision, the total number supporting the Director’s Schedule should be 17 FTE.

10 On page 4 of ONDCP’s response, ONDCP indicated that “the failure to reflect our agency’s extensive

consensus building activities creates the erroneous impression that this essential business practice is not

followed by ONDCP.” The project team agrees that the consensus building activities are extensive and

essential and we re-iterate the need for an appropriate allocation of time for planning and executing

efficient and successful consensus building meetings.
Management Review

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legislative charter. This inability can be attributed to the increase in workload associated

with supporting the Director's priorities, new activities, and the inability of the

organization to recruit and retain qualified staff.

3.0 THE INSTITUTIONALIZATION OF ONDCP

In the course of this evaluation, the project team encountered issues that raised concern

about the future continuity of ONDCP, which will be discussed throughout the remainder

of this report. There were four main findings that caused us to raise the issue of the

adequate institutionalization of the ONDCP organization: 1) authority is centralized and

a significant amount of institutional knowledge resides with the current Director; 2)

turnover has been high and the knowledge base has been eroded by recruitment and

retention problems in recent years; 3) relative to its size, an inordinate number of

leadership and professional staff positions, up to 38%, may be vulnerable during calendar

year 2000;11 and 4) ONDCP-specific written guidance regarding the operations of the

components and functional offices that would contribute to the continuity of the

organization appears to be largely absent.

3.1.1 (a) Authority has been centralized in the Office of the Director

While it is within the purview of the Director to consolidate and centralize authority

within ONDCP, it is an unusual business practice for Presidentially-appointed and

Senate-confirmed (PAS) Deputies to serve without some measure of autonomy. In many

organizations, it is common practice that Deputy, Under, and Assistant Secretaries have

some autonomous authority and responsibility, subject to the advice and consent of the

Secretary or equivalent, for specific areas and objectives.12

 

11 The 38% noted above equates to 59 FTE divided by the base number 154 FTE. The 59 FTE include: 6

civilian employees and 6 military detailees who have already turned over this calendar year as of April

2000, the 17 PAS and Schedule C employees who are vulnerable in the 2000 election cycle, and the 30

military detailee positions whose retention is subject to the consent of the next Director, ONDCP. On page

2 of the ONDCP response, ONDCP indicated that “the report’s discussion of a ‘vulnerability of leadership’

misses key aspects of the nature of federal executive leadership.” The project team respects the breadth of

expertise of the career professionals who may continue to serve within ONDCP beyond the current

Directorship. It is our opinion, however, that the erosion of depth within the knowledge base resulting

from turnover in the past few years has placed ONDCP in a relatively weak knowledge position. It is also

our opinion that the potential loss to the depth of the knowledge base during calendar year 2000 would not

be adequately offset, from an efficiency perspective, by the breadth of knowledge retained by the eight key

professional staff employees mentioned in the ONDCP response.

12 Source: Interview with Dr. Archie D. Barrett, lead negotiator for the House of Representatives on the

Goldwater-Nichols Department of Defense Reorganization Act of 1986.

3.1 AUTHORITY IS CENTRALIZED AND THE LINES OF AUTHORITY ARE

UNCLEAR
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PricewaterhouseCoopers requested the most recent mission and position descriptions for

each component, office, bureau and branch within ONDCP. Careful reading of these

documents indicates that the primary function of the staff, from Deputy Director to policy

analyst, is to assist and advise the Director in carrying out the responsibilities and

objectives required of ONDCP (See Appendix H).

During the interviews with ONDCP staff, we confirmed that management authority for

all ONDCP responsibilities and objectives resides with the Director and that he exercises

direct oversight over, and decision-making for, the vast majority of personnel actions and

day-to-day activities. The Director oversees the organization with the day-to-day

assistance of the Chief of Staff (See Figure 3).13 The Deputy Director of ONDCP, a

physician, works primarily with the Office of Demand Reduction and conducts outreach

and coordination activities with members of the scientific and medical communities.

 Dep Director

Office of

Demand

 Reduction

Director

 Programs,

Budget

 and Evaluation

Director

 Counter-Drug

 Technology

 Assessment Ctr

PAS Position, Confirmed

Career Civil Service Position

Figure 3: Organizational Structure

 Deputy Director Positions Not Confirmed

 (Actual State of ONDCP 2000)

PAS Nominee, Unconfirmed

 Director

 ONDCP

PAS Position, Acting Civil Service

 Dep Director

 Bureau of

 State and

 Local Affairs

 Dep Director

Office of

Supply

Reduction

 Deputy

 Director

 Chief

 of Staff

Authority centralization at ONDCP is further compounded by the fact that the Deputy

Director positions have remained largely vacant during the current Director’s four-year

tenure. As of May 1, 2000, the component Deputy Director positions have been vacant

for 112 out of a total of 153 months, a 73% vacancy rate. The Deputy Director for

Demand Reduction has never been filled during this Directorship and ONDCP leadership

does not expect any of the vacancies to be filled during the remaining months of the

current Administration.

 

13 On page 5 of the ONDCP response, ONDCP indicated that because the Director’s Schedule shows that

the Director spends only 8% of his time on internal matters, he is not the internal manager of the

organization. Our interviews indicated that according to the views of the majority of ONDCP staff

members, the Director, with assistance from the Chief of Staff, has significant direct oversight of internal

matters. It is our opinion that internal matters as a whole are not being adequately attended to (i.e., the

hours represented by the 8% may also represent a large part of the total time spent handling internal

matters). This assertion would be supported by the fact that many of the project team’s human resource

suggestions have been endorsed by ONDCP.
Management Review

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The implication associated with the above findings is that, as a result of the consolidation

of authority, a significant amount of institutional knowledge resides with the current

Director. Unless that knowledge is transferred to documentation and managed within the

organization, the Director will take that knowledge out of the organization when he

concludes his term.

3.1.1 (b) The chain of command can be confusing14

In reviewing the current ONDCP organization and comparing it with the FY98

legislation, we found that the structure that has been implemented is a modified version

of the structure as described in the FY98 legislation.15 The implemented structure is

generally inconsistent with accepted practices of good organizational management.

Management science identifies important practices in order to ensure clarity, consistency,

and continuity of management operations regardless of changing variables, conditions or

personalities. Organizational design emphasizes those management principles that favor

clarity with regard to authority, responsibility, accountability, and capacity for duties and

functions performed by individuals.

Other Business Practices—Roles and Lines of Authority

During the course of our research, we found that the leadership of the other federal

departments and organizations tends to operate within a structure illustrated in the

graphic image in Figure 4. The Secretary or equivalent focuses “upwards and outwards”

in line with negotiating policy, maintaining a public image, or delivering a specific

message.

 Secretary

Under

 Secretary

 (or equivalent)

Under

 Secretary

 (or equivalent)

Under

 Secretary

 (or equivalent)

PAS Position, Confirmed

Career Civil Service Position

Figure 4: Standard Structure

 Federal Business Practices

 Deputy Secretary

 (or equivalent)

 External

Internal

 

14 This heading was clarified in response to ONDCP’s comment (page 4) regarding the clarity of this

section.

15 The Constitution gives the Congress the authority and responsibility to organize the Executive Branch,

including the Departments and Officers thereof. United States Constitution-Article 1, Section 8, Clause 18.
Management Review

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In order to handle the external schedule, to keep the organization operating effectively,

and to maintain an appropriate chain of command, the Secretary or equivalent has a

designated PAS position or equivalent as the “internal manager” responsible for the dayto-day decision making on operational issues. Several organizations such as the

Department of Health and Human Services (HHS), the Department of Agriculture, and

the Department of Defense (DoD) have this management structure in place (See related

textbox to follow). Table 1 below outlines the organizations we spoke with, the

leadership positions, and their respective roles:

Table 1: Organizations Researched for Leadership Characteristics

Organization Internal Manager External Manager

Department of Health and Human Services Deputy Secretary Secretary

Department of Agriculture Deputy Secretary Secretary

Bureau of Alcohol, Tobacco, and Firearms Deputy Director Director

Department of Defense Deputy Secretary Secretary

UK Anti-Drug Coordinator Unit Director Coordinator

Office of National Drug Control Policy Director Director

Leading the Department of Health and Human Services:

A Conversation with Secretary Donna Shalala and Deputy Secretary Kevin Thurm

The Deputy Secretary of HHS, Kevin Thurm explained his roles and responsibilities this way:

“In doing the job that I have now, I had the great advantage of having served as the chief of staff of the department.

First, the Deputy Secretary must be in line with what the Secretary wants in that role. While there are some standard

things that Deputy Secretaries do, it becomes pretty clear that the position is to fill the role the Secretary wants. The

two of you must be able to communicate effectively with each other about what the role is.

Second, as I think is the case in most departments, the Deputy Secretary is the chief operating officer and is essentially

in charge of day-to-day decision making on management issues. The job is also to work closely on policy issues

through the Department and to work closely with the chief of staff and executive secretary on these issues. My

colleagues and I decide when these policy issues need to come to the Secretary’s attention.

Third, based on the priorities that have been identified by the President, Vice President, and the Secretary, the Deputy

Secretary has to make sure these priorities are focused on and develop processes for making sure that progress happens.

I also run quarterly meetings on the Secretary’s initiatives that cross-cut the department.

Finally, I want to stress that continuity matters and Secretary’s Shalala’s staying power has mattered a lot in the

effective management of the department. The Secretary has recruited excellent people and insisted that we work

together and that there would be consequences for people who didn’t play by the rules. This is really important, and I

think that my colleagues within the department have really stepped up to the tone set by the Secretary’s leadership.”

PwC Endowment for the Business of Government Seminar, Fall 1999.
Management Review

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Based on our interviews at ONDCP, we determined that the current implementation is

inconsistent with other federal business practices. The Chief of Staff, rather than the

Deputy Director of ONDCP, serves as the chief operating officer of ONDCP (See Figure

6). The Chief of Staff has been inserted into the chain of command as a conduit between

the Director and the component Deputy Directors and has oversight responsibility for the

Director

ONDCP

Dep Director

Office of

Demand

Reduction

Dep Director

Bureau of State

and Local

Affairs

Dep Director

Office of

Supply

Reduction

Director

Programs,

Budget

and Evaluation

Director

Counter-Drug

Technology

AssessCtr

PAS Position, Confirmed

Career Civil Service Position

Figure 5: Standard

Organizational Structure

Deputy

Director

Dep Director

Office of

Demand

Reduction

Dep Director

Bureau of State

and Local

Affairs

Dep Director

Office of

Supply

Reduction

Director

Programs,

Budget

and Evaluation

Director

Counter-Drug

Technology

AssessCtr

PAS Position, Confirmed

Career Civil Service Position

Figure 6: Current Implementation of

the ONDCP Structure

Director

ONDCP

Chief

of Staff

Deputy

Director

rest of the staff members. The Chief of Staff is operating in that position at the behest of

the Director and serves as the day-to-day internal officer of the organization. During

interviews, several ONDCP staff members responded affirmatively to a direct inquiry

regarding whether they perceived that the Chief of Staff exercised significant influence

over the confirmed Deputy Directors.

With the existing ONDCP structure, as in Figure 6, the chain of command down from the

Director is divided and, as a result, can become complicated and confusing. In 1998, for

example, ONDCP had two confirmed component Deputy Directors reporting through the

Chief of Staff, an SES position, to the Director (see Figure 7). The organization also had

 Dep Director

Office of

Demand

 Reduction

 Dep Director

 Bureau of State

& Local

Affairs

 Dep Director

Office of

Supply

 Reduction

 Director

 Programs,

Budget

 and Evaluation

 Deputy

 Director

Director

 Counter-Drug

 Technology

 Assessment Ctr

PAS Position, Confirmed

Career Civil Service Position

Figure 7: Organizational Structure

with Two PAS Positions Confirmed

(Actual State of ONDCP 1998)

PAS Nominee, Unconfirmed

 Chief

 of Staff

 Director

 ONDCP

PAS Position, Acting Civil Service
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an unconfirmed Deputy Director of ONDCP. Under this scenario, it was confusing to

other agency counterparts, and to ONDCP employees, as to who officially could

represent and negotiate on behalf of the organization: the unconfirmed Deputy Director,

the confirmed component Deputy Directors, or the Chief of Staff.

3.1.1 (c) The managerial role of the Deputy Director of ONDCP is

unclear

We were unable to clearly determine the managerial role of the Deputy Director of

ONDCP.16 The ONDCP mission and position descriptions have not been updated since

May 1996 and do not address the PAS Deputy Director of ONDCP position. It has been

an evolving role for the current acting occupant, a physician, as his management skills

and knowledge base have developed.17 We understand that the Deputy Director serves as

the external intermediary with the medical community on demand reduction-related

issues and has been assigned special projects where his medical expertise and skill set are

required. We also understand that lately he has taken on more of an intermediary role

between the Office of Demand Reduction and the Director.18 (The Deputy Director has

significantly fewer interactions with the Bureau of State and Local Affairs and the Office

of Supply Reduction.) ONDCP has compensated for the absence of a Deputy Director

for Demand Reduction by having the Deputy Director of ONDCP take on some of the

demand reduction-related activities.

The absence of a clearly defined managerial role and area of responsibility for the Deputy

Director of ONDCP has contributed to the confusing chain of command that exists today.

Because the Acting Deputy Director of ONDCP is on detail from the National Institute of

Health and not confirmed, it is unclear who would take over the current Director’s

authority were he to become incapacitated. Succession is not clear, which does not bode

well for the institutionalization or continuity of the organization.

 

16 On page 6 of the ONDCP response, ONDCP indicates that the statement “that the Deputy Director

position lacks ‘a clearly defined role and area of responsibility’ is not borne out.” In the response,

however, ONDCP does not clearly define a managerial role or area of responsibility for the Deputy

Director of ONDCP. ONDCP states that the Deputy Director’s role is to fill the role the Director wants and

to work closely on issues with the Chief of Staff, executive secretary and with others throughout ONDCP

(consistent with the text box description of the Deputy Secretary’s role at HHS). The HHS text box goes

on in the following paragraph, however, to quote the Deputy Secretary of HHS explaining his role more

explicitly as the chief operating officer of the organization: “...as I think is the case in most departments,

the Deputy Secretary is the chief operating officer and is essentially in charge of day-to-day decision

making on management issues.”

17 On page 5 of the ONDCP response, ONDCP states that “this statement does not accurately reflect the

history and role of the Deputy Director.” The original text is based on information gathered in interviews

conducted during the course of the review.

18 On page 6 of the ONDCP response, ONDCP indicated that the Deputy Director of ONDCP has not been

delegated an intermediary oversight role between the Office of Demand Reduction and the Director. The

project team acknowledges the contradiction. The project team has rephrased this sentence to more

accurately reflect what was conveyed to us during our interviews.
Management Review

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The organization could avoid continuity problems in the future by addressing the

following issues:

• institute succession planning to ensure a smooth transition in the event that the

Director becomes incapacitated;

• clarify the authority, responsibility and reporting structure with regard to the Deputy

Director and the Chief of Staff;

• address chain of command issues so as to be consistent with good organizational

management; and

• fill the component Deputy Director positions.

3.1.1 (d) ONDCP has had difficulty recruiting and retaining component

Deputy Directors

ONDCP has been less than effective at recruiting and retaining individuals in the

component Deputy Directorships. In order to understand why, the project team attempted

to identify possible disincentives for individuals in those positions.

3.1.1 (e) What are the explanations for the difficulty in recruiting and

retaining component Deputy Directors?

During interviews, ONDCP leadership suggested that there were two reasons why the

PAS positions remained vacant for extended periods. First, Congress had not acted to

confirm the PAS position nominees that had been put forth. Second, physicians were

unlikely to serve in policy-making positions, as suggested in the FY98 legislation for the

Deputy Director for Demand Reduction, for compensation reasons.

We gathered information on confirmation statistics from other relevant sources in an

effort to verify these reasons. We researched previous ONDCP Directorships to see if it

had been particularly difficult as a rule to recruit and retain within ONDCP. If previous

Directors had had difficulty filling positions, then we could establish that there may be

something inherent in the nature of the mission or the organization that tends to affect

recruitment and retention of Deputy Directors.
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Table 2: ONDCP History of Filled Deputy Director Positions

Director Number of component Deputy PAS

positions

Number of filled PAS

positions Time Frame Filled at End ofTerm

Bennett Three Three 2 years Three

Martinez Three Two 2 years Two

Brown Three Two 2 years Two

McCaffrey Three Two 4 years Zero*

* Projected

Since previous Directors were able to recruit and retain component Deputy Directors and

since the mission and fundamental structure of the organization has remained constant,

we concluded that it is improbable that there is something inherent in the nature of

ONDCP that is causing problems in this area.

We also researched the current Office of the United States Trade Representative (USTR)

to see if an EOP agency of similar size has had trouble getting PAS positions confirmed

with the current political constitution of the Executive and Legislative branches. If the

USTR was also found to have had difficulty confirming PAS nominees, we could

establish that the inherently political nature of the confirmation process, with the

Executive and Legislative branches headed by different political parties, could have

contributed to the inability of ONDCP to confirm PAS nominees. Our interviews with

USTR indicated that they have not had the same difficulty confirming PAS nominees.

USTR has all three of their PAS deputy positions confirmed and currently filled.

Table 3: USTR Filled PAS Positions

Organization Number of component

Deputy PAS positions

Number of filled

PAS positions Currently Filled

Office of U.S. Trade Representative (USTR) Three Three Three

Finally, we researched other health-related organizations to see if it has been difficult to

attract and retain physicians in policy-oriented positions. If other health-related

organizations have had difficulty recruiting physicians for PAS and/or policy-making

positions, then we could establish that physicians as a whole are unlikely to be attracted

to policy-oriented positions.

Table 4: Health Organizations with PAS Positions

Organization Number of component

Deputy PAS positions

Number of filled

PAS positions Currently Filled

Food and Drug Administration (FDA) Four Three Three

 US Surgeon General At Least Two At Least Two At Least Two

Our research indicated that physicians have been confirmed in the Office of the U.S.

Surgeon General and the Food and Drug Administration. These medical physicians

provide scientific and medically-based health policy analysis. Many of the other

organizations we researched and interviewed, such as the American Heart Association,
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rely on medical and scientific experts when making policy decisions. The following

chart presents a list of policy organizations and how they employ medical physicians.

Table 5: Health and Policy Organizations with Medical Physicians

Organization Medical Physicians

U.S. Surgeon General Employs medical physicians throughout the

organization

Department of Health and Human Services 33% (20,345 medical physicians in a 61,654

employee organization)

Food and Drug Administration Agency 3.3% (300 medical physicians in a 9,000 employee

organization)

American Heart Association The majority of the organization consists of medical

physicians in policy and upper level positions

Office of National Drug Control Policy Employs one medical physician

In sum, we were unable to verify ONDCP’s explanations for the absence of confirmed

Deputy Directors. Information gathered from interviews indicated that the lack of

autonomy and confusing chain of command issues may have contributed.

3.1.1 (f) How would the presence of component Deputy Directors affect

ONDCP?

The project team considered how the presence of Deputy Directors would impact

ONDCP. Acting Deputy Directors serve at the pleasure of the Director, but confirmed

Deputy Directors can only be dismissed by the President or impeached by Congress.

Consequently, the authorities of confirmed Deputy Directors would serve as “checks and

balances” with regard to the authority of the Director. With official representatives

acting on behalf of the organization and accountable to Congress and to the President, the

Director would probably have to engage in more consensus building activities and more

debate in order to get “buy-in” for his or her objectives. This would also help to ensure

that the message being delivered by ONDCP was the fully discussed message

representing the fully vetted opinion of the Drug Control Program community.

The existence of confirmed Deputy Directors would also offset the centralization of the

knowledge base. With several confirmed Deputies working toward the objectives of the

organization, the “portfolio” of procedural and historical knowledge of the organization

would be diversified among several individuals and there would be less risk to the overall

continuity and long-term benefit of the organization.

3.1.1 (g) Other Relevant Business Practices – Senior Advisory Steering

Group

We researched and interviewed individuals at other organizations that are involved in a

social mission in order to gain insights as to how they conduct their operations. Most had

some type of established senior advisory steering group to assist in policy formulation
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and implementation.19 This type of forum provides for teaming and consensus building,

which is important when developing policy so that all areas of expertise and knowledge

are considered. Although ONDCP relies heavily on advisory groups for policy

development at the senior management level, the project team did not find evidence of a

senior advisory steering group that regularly meets with the Director. Examples of this

senior advisory steering group function exist in the American Heart Association,

American Medical Association, Food and Drug Administration, America’s Promise, and

the United Kingdom Anti-Drug Coordinator Unit. These groups generally consist of a

committee of CEO/Director level peers from other government agencies, area experts and

professionals, process managers, and other interested stakeholders. The senior advisory

steering group meets according to a set schedule in order to conduct professional debate

on issues. Once a consensus is developed, the designated Director or CEO makes a final

decision. The diagram in Figure 8 illustrates the characteristics of the senior advisory

steering group and the persons involved in the process.

Figure 8: Typical Advisory Steering Group

CEO/Director

Vice President/

Deputy Director

Process

Manager/Vice

President

Process

Manager/Vice

President

Process

Manager/Vice

President

Advisory Steering

Group

Government agency reps

Area experts and professionals

Process managers/Vice Presidents

Other interested stakeholders

Meeting regularly

One specific example of this advisory group function is implemented at the United

Kingdom Anti-Drug Coordinator Unit, where a Strategic Steering Group meets regularly

to help the Coordinator assess overall progress in implementing the strategy. This group

includes senior officials from within the government, individuals from independent

bodies, professional drug agencies, local governments, businesses, and Drug Action

Teams. By working through policy issues with an advisory group, the organization

maximizes its chances of obtaining a fully vetted and consensus-based policy.

 

19 In a response to a draft version of this report, ONDCP indicated that “the report does not reflect

ONDCP’s reliance on policy advisory groups.” The project team acknowledges that ONDCP has several

advisory groups with which it consults on various issues. The example discussed in this section pertains to

an established senior policy advisory group or steering committee that would meet regularly to consult with

and to advise the Director, ONDCP on the overall priorities and strategies committed to by ONDCP.
Management Review

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ONDCP has experienced high turnover during the current directorship. Our review has

revealed several situations that have characterized the current Director’s tenure. First,

ONDCP has not been able to meet its 154 FTE ceiling (124 FTE + 30 military detailee

positions).20 Second, the agency has been unsuccessful in hiring and retaining staff

resources. And third, Congress has not supported requests for additional FTE funding.

As a result, ONDCP has performed its duties with a number of unfilled positions,

vacancies, and high turnover. In our opinion, the Director’s leadership style, the heavy

workload associated with increasing program area responsibilities, the lack of an

adequate number of personnel to handle ONDCP’s responsibilities, and the lack of

attention to human resource practices has resulted in personnel turnover. ONDCP's

aggregate and yearly turnover statistics are presented in the sections that follow.

3.2.1 Turnover Rates

Table 6: ONDCP Civilian Turnover Aggregate Statistics

ONDCP Civilian Turnover Statistics Aggregate Results

104 of 154 positions 68% turnover

2 of 5 authorized PAS positions, 40% turnover

11 of 15 authorized Career SES and Non-Career SES positions 73% turnover

61 of 104 authorized Career Status, Schedule A's and Schedule C's 59% turnover

Table 7: ONDCP Military Turnover Aggregate Statistics

ONDCP Military Turnover Statistics Aggregate Results

30 of 30 authorized military detailee positions (as per DoD arrangement) 100% turnover

Using ONDCP personnel data and internal organizational charts, our project team

determined the effects on the agency of the actual turnover from calendar year 1998 to

the present and of the potential calendar year 2000 turnover. The turnover has occurred

in both civilian and military detailee positions of significant influence. As a result, the

actual turnover that ONDCP has experienced from 1998 to 1999 combined with this

year’s potential turnover from the 2000 election raises the issue of the knowledge base

and knowledge retention in light of the coming period of transition.

 

20 The project team included the 30 military detailees in our analysis because these individuals are in

positions of significant influence and authority and their recruitment and retention has a direct impact on

the knowledge base and continuity of the organization. They perform duties and functions essential to the

operations of ONDCP. Most of the military detailees are colonel and lieutenant colonel level and are

nestled within the leadership of many of the components and offices.

3.2 ONDCP’S TURNOVER HAS BEEN VERY HIGH
Management Review

Office of National Drug Control Policy 

Page 24

3.2.1 (a) ONDCP Calendar Year 1998 Turnover

22 civilian and 10 military detailee positions turned over in calendar year 1998. Based

on the number of authorized 154 positions, ONDCP experienced a turnover rate of 21%.

ONDCP did not meet its authorized FTE ceiling in 1998.

Table 8: 1998 Turnover Positions

Component Office Turnover Positions Total Office Positions21 Turnover Rate

Public Affairs Office 5 7 71%

Office of Legislative Affairs 4 6 67%

Office of Programs, Budget,

Research & Evaluation 7 23 30%

3.2.1 (b) ONDCP Calendar Year 1999 Turnover

31 civilian and 10 military detailee positions turned over in calendar year 1999. Based

on the number of authorized 154 positions, ONDCP experienced a turnover rate of 27%.

Still, ONDCP did not meet its authorized FTE ceiling in 1999. The areas of overall high

impact in 1999 included the following:

Table 9: 1999 Turnover Positions

Component Office Turnover Positions Total Office Positions22 Turnover Rate

Director's Office 5 7 71%

Office of Legislative Affairs 4 6 67%

Public Affairs Office 4 7 57%

Office of Legal Counsel 4 7 57%

Office of Programs, Budget,

Research & Evaluation 9 23 39%

Office of Supply Reduction 9 23 36%

3.2.1 (c) ONDCP Calendar Year 2000 Actual Turnover and Potential

Turnover Associated with the 2000 Election

As of April 20, 2000, 6 civilian and 6 military detailee positions turned over in this

calendar year. In addition, 17 filled political positions are vulnerable in this year's

election. Political positions that are vulnerable in a change of administration include all

Presidential Appointee Schedules (PAS), Non-Career Senior Executive Service (NC

SES), and Schedule C's (SC).

 

21 The total number of component office positions was determined from ONDCP’s organizational chart

dated 3/3/2000. If the number of component office positions changed in this year, the overall turnover rates

could be adjusted.

22 Ibid.
Management Review

Office of National Drug Control Policy 

Page 25

With a change of administration, ONDCP's next director could decide to eliminate the 30

authorized military detailee positions. Thus, 30 filled military detailee positions23 may

be vulnerable in the coming election year as well. Because the military detailees are in

positions of significant influence, their loss would be detrimental to the organization's

knowledge base. Based on the ceiling of 154 authorized FTE, ONDCP could potentially

experience a combined (actual and potential) turnover rate of 38% in this calendar year.

As of April 20, 2000, ONDCP had not met its authorized FTE ceiling.

The areas of potentially high impact (combined actual and potential turnover based on

154 FTE capacity) are graphically presented below:

Figure 9: ONDCP Actual and Potential Turnover for Calendar Year 2000

Percentage Impact on Component Offices,24 Based on 154 FTE Full Capacity

21-100% Potential Component/Office Turnover

0-20% Potential Component/Office Turnover

On the next several pages, we have provided charts that show which positions turned

over in calendar years 1998 and 1999, and the actual and potential turnover for calendar

year 2000. The summary chart of the 1999 and 2000 data demonstrates that the

knowledge bases for most of the offices within ONDCP have been seriously weakened or

are vulnerable with the coming election.

 

23 The total number of component office positions was based on ONDCP’s organizational chart dated

3/3/2000. If the number of component office positions changed in this year, the overall turnover rates

could be adjusted.

24 Ibid.

Director

86%

Chief of Staff

100%

Office of Strategic Planning

63%

Deputy Director

100%

Public Affairs Office

43%

Office of Administration

44%

Counter-Drug

Technology

Assessment Center

0%

Office of

Demand Reduction

23%

Bureau of State and

Local Affairs

13%

Office of

Supply Reduction

52%

Office of Programs,

Budget, Research, &

Evaluation

30%

Executive

Secretariat

0%

FInancial Management

Office

0%

Office of Legal Counsel

17%

Office of Legislative Affairs

17%

%

%
Management Review

Office of National Drug Control Policy 

Page 26

CHIEF OF STAFF OFFICE

Chief of Staff, SES-6

Exec. Assistant, GS-12

Deputy Chief of Staff, ES-3

Staff Assistant, GS-7

Staff Assistant, GS-9

STRATEGIC PLANNING

Director, SES-1

Assistant Director, GS-15

Secretary, GS-9

Events Assistant, PMI GS-9

Strategic Planner, LTC

Deputy Events Manager, GS-12

Strategic Planner, GS-13

Research Assistant, GS-4

LEGAL COUNSEL

General Counsel, SES-3

Secretary, GS-9

Deputy Counsel, GS-15

Asst. Gen Counsel, COL

Associate Counsel, GS-14

Attorney-Advisor, GS-14

Attorney-Advisor, GS-14

DIRECTOR'S OFFICE

Director, PAS

Personal Secretary, GS-7

Executive Assistant, COL

Asst. Exec. Assistant, LTC

Special Assistant, GS-12

Speech Writer, GS-14

Staff Assistant, GS-7

Scheduler, GS-7

LEGISLATIVE AFFAIRS

Director, SES-1

Director, SES-1

Secretary, GS-9

Assistant Director, GS-15

Legislative Analyst - OSR, GS-14

Legislative Analyst - ODR, GS-14

Admin. Support Asst., GS-8

PUBLIC AFFAIRS

Director, SES-1

Assistant Director, COL

Chief, Press Relations, GS-15

Public Affairs Specialist, GS-14

Public Affairs Specialist, GS-11

Public Affairs Specialist, GS-9

Secretary, GS-9

Admin. Assistant, GS-7

Press Relations Assistant, GS-5

DEPUTY DIRECTOR'S OFFICE

Deputy Director, SES-6

Policy Advisor, GS-13

Confidential Secretary, GS-10

EXECUTIVE SECRETARIAT

Correspondence Manager, GS-12

Correspondence Specialist, GS-10

Correspondence Assistant, GS-6

ADMINISTRATION

Director, GS-15

Travel Management Spec., GS-9

Support Services Asst., GS-7

Secretary, GS-6

COMMUNICATIONS

Asst. for Info Sys, LTC

SUPPORT SERVICES

Assistant for Support, GS-14

Support Specialist, GS-11

PERSONNEL

Assistant for Personnel, GS-13

Special Assistant, LTC

Personnel Specialist, GS-11

TECHNOLOGY

Director, SES-5

Secretary, GS-9

Program Analyst, GS-15

Program Engineer, GS-14

FINANCIAL MANAGEMENT

Director, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-11/12/13

Financial Support Spec., GS-11

DEMAND REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-2

Staff Director, COL

Grants Administrator, GS-15

Senior Policy Analyst, GS-15

Program Supt. Spec., GS-12

EDUCATION

Senior Advisor and Chief, SES-3

Bus/Med/Ent. Analyst, GS-14

Mgmt & Contracts Spec., GS-14

Management Analyst, GS-13

Special Assistant, GS-13

Policy Analyst, PMI GS-9

Admin Supt. Asst., GS-8

PREVENTION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, PMI GS-9

Policy Analyst, GS-14

TREATMENT

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-15

Cocaine Analyst, LTC

SPECIFIC DRUGS

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-14

Heroin Analyst, LTC

STATE & LOCAL

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-1

Staff Director, COL

JUSTICE & LAW ENFORCEMENT

Branch Chief, GS-15

Law Enforcement Analyst, LTC

Policy Analyst, PMI GS-9

HIDTA

Director, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-14

Policy Analyst, GS-13

Secretary, GS-8

REGIONS

Branch Chief, GS-15

South West/Border Analyst, GS-14

Policy Analyst - East, GS-14

SUPPLY REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-1

Staff Director, CDR

Advisor, COL

Staff Assistant, GS-7

SOURCE COUNTRY SUPPORT

Branch Chief, GS-15

Program Supt. Spec., GS-12

Colombia Analyst, GS-14

Mexico Analyst, GS-13

Mexico Analyst, PMI GS-9

Policy Analyst, GS-9

SWA/Africa/Europe Analyst, GS-14

Peru/Bolivia Analyst, GS-14

Burma/Thai/SEA Analyst, LTC

PRODUCTION & TRAFFICKING

Branch Chief, GS-15

Int'l Law Enf. Analyst, GS-14

Policy Analyst, LTC

Policy Analyst, CDR

Policy Analyst, LTC

Policy Analyst, MAJ

INTELLIGENCE

Director, SES-3

Intel Research Analyst, GS-14

Intel Sharing Analyst, LTC

Intel Sharing Analyst, LTC

Researcher, CPT

PROGRAMS, BUDGET,

RESEARCH, & EVALUATION

Director, SES

Secretary, GS-7

Assistant Director, SES-1

Economist, GS-9

Policy Analyst, GS-9

PROGRAMS

Branch Chief, GS-15

Drug Policy Analyst, GS-14

Demographer, GS-14

Policy Analyst, GS-14

Data/Survey Analyst, GS-15

Policy Analyst - Int'l Supply, LT

Policy Analyst - Demand, CDR

BUDGET

Branch Chief, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-12

Budget Analyst, LTC

EVALUATION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, MAJ

ONDCP CALENDAR YEAR 1998 TURNOVER

Turnover positions are presented in red text.

1998 Turnover

22 civilians

10 military detailees

21% turnover rate
Management Review

Office of National Drug Control Policy 

Page 27

ONDCP CALENDAR YEAR 1999 TURNOVER

Turnover positions are presented in red text.

SOURCE COUNTRY SUPPORT

Branch Chief, GS-15

Program Supt. Spec., GS-12

Colombia Analyst, GS-14

Mexico Analyst, GS-14

Mexico Analyst, LTC

Mexico Analyst, PMI GS-9

SWA/Africa/Europe Analyst, GS-14

Peru/Bolivia Analyst, GS-14

Burma/Thai/SEA Analyst, LTC

PRODUCTION & TRAFFICKING

Branch Chief, GS-15

Int'l Law Enf. Analyst, GS-13

Policy Analyst, LTC

Policy Analyst, CDR

Policy Analyst, LTC

Policy Analyst, MAJ

INTELLIGENCE

Director, SES-3

Intel Research Analyst, GS-14

Intel Sharing Analyst, LTC

Intel Sharing Analyst, LTC

Researcher, CPT

STRATEGIC PLANNING

Director, SES-1

Assistant Director, GS-15

Secretary, GS-9

Events Assistant, PMI GS-9

Strategic Planner, LT

Strategic Planner, LTC

Deputy Events Manager, GS-12

Strategic Planner, GS-13

Research Assistant, GS-4

CHIEF OF STAFF OFFICE

Chief of Staff, SES-6

Secretary, GS-10

Deputy Chief of Staff

Staff Assistant, GS-7

Staff Assistant, GS-9

LEGAL COUNSEL

General Counsel, SES-3

Secretary, GS-9

Dep. Gen. Counsel, GS-15

Associate Counsel, GS-14

Attorney-Advisor, GS-14

Attorney-Advisor, GS-13

DIRECTOR'S OFFICE

Director, PAS

Personal Secretary, GS-7

Executive Assistant, COL

Strategic Planner, COL

Confidential Assistant, GS-13

Confidential Assistant, GS-11

Speech Writer, GS-14

Scheduler, GS-11

Staff Assistant, GS-7

Scheduler, GS-8

LEGISLATIVE AFFAIRS

Director, SES-1

Secretary, GS-9

Assistant Director, GS-15

Legislative Analyst - OSR, GS-14

Legislative Analyst - ODR, GS-14

Legislative Assistant, GS-13

Legislative Specialist, GS-9

Admin. Support Asst., GS-8

PUBLIC AFFAIRS

Director, SES-1

Secretary, GS-9

Assistant Director, COL

Chief, Press Relations, GS-15

Public Affairs Specialist, GS-14

Public Affairs Specialist, GS-12

Public Affairs Specialist, GS-12

Public Affairs Specialist, GS-9

Press Relations Asst., GS-5

Admin. Assistant, GS-7

DEPUTY DIRECTOR'S OFFICE

Deputy Director, SES-6

Policy Advisor, GS-13

Confidential Secretary, GS-10

EXECUTIVE SECRETARIAT

Correspondence Manager, GS-12

Correspondence Specialist, GS-10

Correspondence Assistant, GS-6

ADMINISTRATION

Director, GS-15

Travel Management Spec., GS-9

Support Services Asst., GS-7

COMMUNICATIONS

Asst. for Info Sys, LTC

SUPPORT SERVICES

Assistant for Support, GS-14

Support Specialist, GS-11

PERSONNEL

Assistant for Personnel, GS-13

Special Assistant, LTC

Personnel Specialist, GS-11

TECHNOLOGY

Director, SES-5

Secretary, GS-9

Program Analyst, GS-15

Program Engineer, GS-14

FINANCIAL MANAGEMENT

Director, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-11/12/13

Financial Support Spec., GS-11

DEMAND REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-2

Staff Director, COL

Grants Administrator, GS-15

Senior Policy Analyst, GS-15

Program Supt. Spec., GS-12

EDUCATION

Senior Advisor and Chief, SES-3

Bus/Med/Ent. Analyst, GS-14

Mgmt & Contract Spec., GS-14

Management Analyst, GS-13

Special Assistant, GS-13

Policy Analyst, PMI GS-9

Secretary, GS-8

PREVENTION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, PMI GS-9

Policy Analyst, GS-14

TREATMENT

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-15

Cocaine Analyst, LTC

SPECIFIC DRUGS

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-14

Heroin Analyst, LTC

STATE & LOCAL

Deputy Director, PAS EX-III

Secretary, GS-8

Asst. Deputy Director, SES-2

Prog. Mgmt Coordinator, GS-15

Acting Staff Director

JUSTICE & LAW ENFORCEMENT

Branch Chief, GS-15

Law Enforcement Analyst, LTC

Policy Analyst, PMI GS-9

HIDTA

Director, ES-1

Policy Analyst, GS-14

Policy Analyst, GS-14

Policy Analyst, GS-13

Secretary, GS-8

REGIONS

Branch Chief, GS-15

South West/Border Analyst, GS-14

Policy Analyst - East, GS-14

SUPPLY REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Secretary, GS-8

Asst. Deputy Director, SES-1

Staff Director, CDR

Advisor, COL

Staff Assistant, GS-7

PROGRAM, BUDGET, RES, EVAL

Director, SES

Secretary, GS-9

Secretary, GS-9

Secretary, GS-8

Assistant Director, SES-1

Economist, GS-11

PROGRAMS

Branch Chief, GS-15

Drug Policy Analyst, GS-14

Demographer, GS-14

Policy Analyst, GS-14

Data/Survey Analyst, GS-15

Policy Analyst - Int'l Supply, LT

Policy Analyst - Demand, CDR

BUDGET

Branch Chief, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, LTC

Budget Analyst, GS-13

Budget Analyst, GS-9

Budget Analyst, MAJ

EVALUATION

Branch Chief, GS-15

Policy Analyst, GS-14

Evaluation Analyst, COL

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, GS-9

1999 Turnover

31 civilians

10 military detailees

27% turnover rate
Management Review

Office of National Drug Control Policy 

Page 28

ONDCP CALENDAR YEAR 2000

ACTUAL AND POTENTIAL TURNOVER

Turnover positions are presented in red text.

DIRECTOR'S OFFICE

Director, PAS

Personal Secretary, GS-7

Executive Assistant, COL

Special Assistant, GS-12

Speech Writer, GS-14

Staff Assistant, GS-7

Scheduler, GS-7

Vulnerable Positions Under

Next Administration

PAS

Non-Career SES

Schedule C

Military Detailees

CHIEF OF STAFF OFFICE

Chief of Staff, SES-6

Secretary, GS-10

Deputy Chief of Staff, COL

Staff Assistant, GS-7

Staff Assistant, GS-9

STRATEGIC PLANNING

Director, SES-1

Assistant Director, GS-15

Secretary, GS-9

Events Assistant, PMI GS-9

Strategic Planner, LTC

Deputy Events Manager, GS-12

Strategic Planner, GS-13

Research Assistant, GS-4

LEGAL COUNSEL

General Counsel, SES-3

Secretary, GS-9

Deputy Counsel, GS-15

Asst. Gen. Counsel, COL

Associate Counsel, GS-14

Attorney-Advisor, GS-14

Attorney-Advisor, GS-14

LEGISLATIVE AFFAIRS

Director, SES-1

Secretary, GS-9

Assistant Director, GS-15

Legislative Analyst - OSR, GS-14

Legislative Analyst - ODR, GS-14

Admin. Support Asst., GS-8

PUBLIC AFFAIRS

Director, SES-1

Assistant Director, COL

Chief, Press Relations, GS-15

Public Affairs Specialist, GS-14

Public Affairs Specialist, GS-11

Public Affairs Specialist, GS-9

Admin. Assistant, GS-7

DEPUTY DIRECTOR'S OFFICE

Deputy Director, SES-6

Policy Advisor, GS-13

Confidential Secretary, GS-10

EXECUTIVE SECRETARIAT

Correspondence Manager, GS-12

Correspondence Specialist, GS-10

Correspondence Assistant, GS-6

ADMINISTRATION

Director, GS-15

Travel Management Spec., GS-9

Support Services Asst., GS-7

COMMUNICATIONS

Asst. for Info Systems, LTC

SUPPORT SERVICES

Assistant for Support, GS-14

Support Specialist, GS-11

PERSONNEL

Assistant for Personnel, GS-13

Special Assistant, LTC

Personnel Specialist, GS-11

TECHNOLOGY

Director, SES-5

Secretary, GS-9

Program Analyst, GS-15

Program Engineer, GS-14

FINANCIAL MANAGEMENT

Director, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-11/12/13

Financial Support Spec., GS-11

DEMAND REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-2

Staff Director, COL

Grants Administrator, GS-15

Senior Policy Analyst, GS-15

Program Support Specialist, GS-12

EDUCATION

Senior Advisor and Chief, SES-3

Bus/Med/Ent. Analyst, GS-14

Mgmt & Contracts Spec., GS-14

Management Analyst, GS-13

Special Assistant, GS-13

Policy Analyst, PMI GS-9

Admin. Support Assistant, GS-8

PREVENTION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, PMI GS-9

Policy Analyst, GS-14

TREATMENT

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-15

Cocaine Analyst, LTC

SPECIFIC DRUGS

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-14

Heroin Analyst, LTC

STATE & LOCAL

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-1

Acting Staff Director

JUSTICE & LAW ENFORCEMENT

Branch Chief, GS-15

Law Enforcement Analyst, LTC

Policy Analyst, PMI GS-9

HIDTA

Director, ES-1

Policy Analyst, GS-14

Policy Analyst, GS-14

Policy Analyst, GS-13

Secretary, GS-8

REGIONS

Branch Chief, GS-15

South West/Border Analyst, GS-14

Policy Analyst - East, GS-14

SUPPLY REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-1

Staff Director, CDR

Advisor, COL

Staff Assistant, GS-7

SOURCE COUNTRY SUPPORT

Branch Chief, GS-15

Program Support Specialist, GS-12

Colombia Analyst, GS-14

Mexico Analyst, GS-13

Mexico Analyst, PMI GS-9

Policy Analyst, GS-9

SWA/Africa/Europe Analyst, GS-14

Peru/Bolivia Analyst, GS-14

Burma/Thai/SEA Analyst, LTC

PRODUCTION & TRAFFICKING

Branch Chief, GS-15

Int'l Law Enf. Analyst, GS-13

Policy Analyst, LTC

Policy Analyst, CDR

Policy Analyst, LTC

Policy Analyst, MAJ

INTELLIGENCE

Director, SES-3

Intel Research Analyst, GS-14

Intel Sharing Analyst, LTC

Intel Sharing Analyst, LTC

Researcher, CPT

PROGRAMS, BUDGET,

RESEARCH, & EVALUATION

Director, SES-4

Secretary, GS-9

Assistant Director, SES-1

Economist, GS-11

Policy Analyst, GS-9

PROGRAMS

Branch Chief, GS-15

Drug Policy Analyst, GS-14

Demographer, GS-14

Policy Analyst, GS-14

Data/Survey Analyst, GS-15

Policy Analyst - Int'l Supply, LT

Policy Analyst - Demand, CDR

BUDGET

Branch Chief, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-13

Budget Analyst, MAJ

EVALUATION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, LTC

2000 Actual Turnover*

6 civilian

6 military detailees

2000 Potential Turnover

17 filled political

30 military detailees

38% combined turnover rate

* During the time of this review
Management Review

Office of National Drug Control Policy 

Page 29

ONDCP COMBINED CALENDAR YEARS 1999 AND 2000

ACTUAL AND POTENTIAL TURNOVER

Turnover positions are presented in red text.

SOURCE COUNTRY SUPPORT

Branch Chief, GS-15

Program Support Specialist, GS-12

Colombia Analyst, GS-14

Mexico Analyst, GS-14

Mexico Analyst, LTC

Mexico Analyst, PMI GS-9

Policy Analyst, GS-9

SWA/Africa/Europe Analyst, GS-14

Peru/Bolivia Analyst, GS-14

Burma/Thai/SEA Analyst, LTC

PRODUCTION & TRAFFICKING

Branch Chief, GS-15

Int'l Law Enf. Analyst, GS-13

Policy Analyst, LTC

Policy Analyst, CDR

Policy Analyst, LTC

Policy Analyst, MAJ

INTELLIGENCE

Director, SES-3

Intel Research Analyst, GS-14

Intel Sharing Analyst, LTC

Intel Sharing Analyst, LTC

Researcher, CPT

STRATEGIC PLANNING

Director, SES-1

Assistant Director, GS-15

Secretary, GS-9

Events Assistant, PMI GS-9

Strategic Planner, LT

Strategic Planner, LTC

Deputy Events Manager, GS-12

Strategic Planner, GS-13

Research Assistant, GS-4

CHIEF OF STAFF OFFICE

Chief of Staff, SES-6

Secretary, GS-10

Deputy Chief of Staff

Staff Assistant, GS-7

Staff Assistant, GS-9

LEGAL COUNSEL

General Counsel, SES-3

Secretary, GS-9

Dep. Gen. Counsel, GS-15

Asst. Gen. Counsel, COL

Associate Counsel, GS-14

Attorney-Advisor, GS-14

Attorney-Advisor, GS-13

DIRECTOR'S OFFICE

Director, PAS

Personal Secretary, GS-7

Executive Assistant, COL

Special Assistant, GS-12

Strategic Planner, COL

Confidential Assistant, GS-13

Confidential Assistant, GS-11

Speech Writer, GS-14

Scheduler, GS-11

Staff Assistant, GS-7

Scheduler, GS-8

LEGISLATIVE AFFAIRS

Director, SES-1

Secretary, GS-9

Assistant Director, GS-15

Legislative Analyst - OSR, GS-14

Legislative Analyst - ODR, GS-14

Legislative Assistant, GS-13

Legislative Specialist, GS-9

Admin. Support Asst., GS-8

PUBLIC AFFAIRS

Director, SES-1

Secretary, GS-9

Assistant Director, COL

Chief, Press Relations, GS-15

Public Affairs Specialist, GS-14

Public Affairs Specialist, GS-12

Public Affairs Specialist, GS-12

Public Affairs Specialist, GS-9

Press Relations Asst., GS-5

Admin. Assistant, GS-7

DEPUTY DIRECTOR'S OFFICE

Deputy Director, SES-6

Policy Advisor, GS-13

Confidential Secretary, GS-10

EXECUTIVE SECRETARIAT

Correspondence Manager, GS-12

Correspondence Specialist, GS-10

Correspondence Assistant, GS-6

ADMINISTRATION

Director, GS-15

Travel Management Spec., GS-9

Support Services Asst., GS-7

COMMUNICATIONS

Asst. for Info Systems, LTC

SUPPORT SERVICES

Assistant for Support, GS-14

Support Specialist, GS-11

PERSONNEL

Assistant for Personnel, GS-13

Special Assistant, LTC

Personnel Specialist, GS-11

TECHNOLOGY

Director, SES-5

Secretary, GS-9

Program Analyst, GS-15

Program Engineer, GS-14

FINANCIAL MANAGEMENT

Director, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-13

Budget Analyst, GS-11/12/13

Financial Support Spec., GS-11

DEMAND REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Asst. Deputy Director, SES-2

Staff Director, COL

Grants Administrator, GS-15

Senior Policy Analyst, GS-15

Program Support Specialist, GS-12

EDUCATION

Senior Advisor and Chief, SES-3

Bus/Med/Ent. Analyst, GS-14

Mgmt & Contract Spec., GS-14

Management Analyst, GS-13

Special Assistant, GS-13

Policy Analyst, PMI GS-9

Secretary, GS-8

PREVENTION

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, PMI GS-9

Policy Analyst, GS-14

TREATMENT

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-15

Cocaine Analyst, LTC

SPECIFIC DRUGS

Branch Chief, GS-15

Policy Analyst, GS-14

Policy Analyst, GS-14

Heroin Analyst, LTC

STATE & LOCAL

Deputy Director, PAS EX-III

Secretary, GS-8

Asst. Deputy Director, SES-2

Program Mgmt. Coordnatr, GS-15

Acting Staff Director

JUSTICE & LAW ENFORCEMENT

Branch Chief, GS-15

Law Enforcement Analyst, LTC

Policy Analyst, PMI GS-9

HIDTA

Director, ES-1

Policy Analyst, GS-14

Policy Analyst, GS-14

Policy Analyst, GS-13

Secretary, GS-8

REGIONS

Branch Chief, GS-15

South West/Border Analyst, GS-14

Policy Analyst - East, GS-14

SUPPLY REDUCTION

Deputy Director, PAS EX-III

Secretary, GS-9

Secretary, GS-8

Asst. Deputy Director, SES-1

Staff Director, CDR

Advisor, COL

Staff Assistant, GS-7

PROGRAMS, BUDGET,

RESEARCH, & EVALUATION

Director, SES

Secretary, GS-9

Secretary, GS-9

Secretary, GS-8

Assistant Director, SES-1

Economist, GS-11

PROGRAMS

Branch Chief, GS-15

Drug Policy Analyst, GS-14

Demographer, GS-14

Policy Analyst, GS-14

Data/Survey Analyst, GS-15

Policy Analyst - Int'l Supply, LT

Policy Analyst - Demand, CDR

BUDGET

Branch Chief, GS-15

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, GS-14

Budget Analyst, LTC

Budget Analyst, GS-13

Budget Analyst, GS-9

Budget Analyst, MAJ

EVALUATION

Branch Chief, GS-15

Policy Analyst, GS-14

Evaluation Analyst, COL

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, LTC

Policy Analyst, GS-9

Vulnerable Positions Under

Next Administration

PAS

Non-Career SES

Schedule C

Military Detailees
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3.2.1 (d) Reasons for Turnover

ONDCP, as a federal agency governed by the procedures and practices of the EOP, is

expected to experience normal turnover of approximately 21%.25 Some turnover is

expected due to the political nature of some of the higher level positions. Given

ONDCP’s high actual turnover rates across all status positions, however, the project team

attempted to identify issues of concern that should be addressed.

ONDCP does not conduct formal exit interviews with departing staff. When staff

members leave the agency, they complete a checklist of administrative procedures. No

formal documentation is made concerning their experiences, reasons for leaving, or

future endeavors. Assuming that departing staff would candidly discuss issues or

concerns, ONDCP cannot effectively evaluate its internal performance without a formal

record of exit interviews. Assumptions can be made, but without formal interviews,

ONDCP cannot identify or directly address the retention and turnover issues that impact

its knowledge base.

Our research indicates that exit interviews are commonplace within the private sector,

nonprofit, and social mission organizations. Particularly in the private sector, exit

interviews are one of the primary vehicles by which an organization can assess its

employee satisfaction and make necessary adjustments. In most private sector

organizations, human resources staff members collect exit interview data to determine

consistent themes to address. Unique, isolated issues are also considered, as required.

Thus, exit interviews are highly recommended for any place of employment. Employees

often discuss the issues that influence their decision to leave. Some common themes are

listed below.

• Inadequate career development

• Promotion ceilings

• Inadequate training

• Lack of staff appreciation

• Difficult work environment

• Non-competitive compensation

• Excessive workload

• Unpleasant working relationships with management and/or peers

• Pursuit of better opportunities

Human resources subject matter experts use exit interviews as issue-identifiers.

Ultimately, exit interview data that leads to organizational improvements often positively

influences retention and turnover rates.

 

25 Attrition data collected from Office of Personnel Management’s Employment Trend Report dated

November 1998.
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Our interviews with ONDCP staff suggested three primary reasons for the agency's

turnover: (1) leadership style, (2) heavy workload, and (3) career development and

promotion issues for civilians. The interviews yielded the following:

Leadership Style: “He’s difficult to work for”26

• The current Director’s leadership style has been described as aggressive, highpressure, and military-oriented. Under the current directorship, a military structure

has been imposed on a previously civilian culture. As incompatibilities have

developed, people have made the decision to leave.

• The Director drives himself, the organization, and its people to meet his exceedingly

high expectations. Consequently, the pace is relentless, high-pressured, and

expedient in nature.

• The professional debate among ONDCP experts is primarily paper-based and,

according to some staff members, can be somewhat restrictive. Individuals expressed

concern that a substantial reliance on written communication poses a disincentive to

freely debating contentious issues since written information can be attributed directly.

It may also be time consuming. The primarily paper-based system could make for an

intellectually restricted environment for credentialed professionals who are

accustomed to free and open oral debate of the issues.27

• The leadership is focused on “the mission and the budget,”28 with little attention

given directly to the organization's people. According to the Director’s schedule, he

spends approximately 8% of his non-office time on internal matters.29

Our general finding is that work-style conflicts, high stress levels, and demanding

conditions have yielded a difficult work environment.

Operational tempo/workload is extremely high

ONDCP's workload has increased substantially, with the addition and/or growth of the

HIDTA, Media Campaign, and Drug Free Communities programs. ONDCP was

expected to staff these programs by recruiting within the authorized 124 FTE civilian

ceiling. The workload situation has become problematic, given the unfilled positions

associated with the recruitment and retention problems.30

 

26 General comment from ONDCP staff members. 27 On page 1 of the ONDCP response, ONDCP indicated that the report displays a misunderstanding of the

requirement for transparency in government. The project team recognizes that ONDCP is required to

comply with the Administrative Procedures Act and the Records Management by Federal Agencies Act. It

is our opinion, however, that the primary reliance on written communication with few forums for verbal

debate “could” contribute to a restricted environment, particularly with staff members under pressures of

expediency and aware of confidentiality issues and subpoenas at the highest levels of government.

28 Barry McCaffrey, Director, ONDCP during interview at ONDCP.

29 Scheduling meetings, senior staff meetings, and personnel interviews (see Table 11).

30 On page 8 of the ONDCP response, ONDCP states that “recruitment has not been problematic for

ONDCP” and that the assertion is unsubstantiated. The project team supports the original statement that

recruitment and retention have been issues for ONDCP. Identifying and recruiting appropriate candidates
Management Review

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• The HIDTA program has grown from 15 to 31 programs in the last four years and has

been staffed with 5 FTE (originally from the Bureau of State and Local Affairs) and 2

Budget Analysts. The budget analysts have been required to handle the 100%

increase in HIDTA budget activities.

• The Media Campaign, ONDCP's multi-million dollar operational program, has been

staffed with 7 FTE (originally in Demand Reduction) to execute the agency's largest

program.

• The Director's Schedule utilizes up to 17 FTE for development, strategy, planning,

and execution of activities. The Director's Schedule involves FTE drawn from the

component and policy offices, causing additional workload for those components that

are responsible for ONDCP’s primary objectives.

ONDCP has requested additional FTE to support the increase in operational program

requirements in an effort to maintain its ability to meet coordination and compliance

objectives and to support the Director’s Schedule. Out of concern that the authorized 124

civilian FTE ceiling has never been met and given the agency's recruitment and retention

problems, Congress has rejected the FTE requests. ONDCP has absorbed the increase in

operational activities with the existing FTE, without changing the level of effort

dedicated to supporting the Director's priorities. Thus, the general operational tempo and

per capita workload of the organization is very high as the employees take on additional

responsibilities.

Career development, organizational development, promotion, and

training opportunities are limited

Career Development: There is no standard career development strategy or program for

ONDCP civilian staff to advance within the federal system. Although we found that

there are some individual efforts by well-intentioned managers to create staff

development opportunities, there is no consistent, centralized career development

strategy within the agency. Few component or office heads have been able to provide

federal career-related incentives, such as training, to their staff. Monetary incentives are

distributed for excellent performance, but the awards are relatively small.

Organizational Development: Our interviews also revealed that there is no current

documentation of component office mission statements and position descriptions,31

leading to the conclusion that there may be little formal organizational development

planning taking place. Without a formal development plan for the overall internal

organization, it would be impossible for individual staff members to visualize, let alone

achieve, career development objectives. And because there is little attention from the

leadership, organizational planning and career development practices are being sidelined.

 

who will remain in positions for a significant period of time is an important part of the retention strategy of

an organization.

31 The only documents made available in this review were position descriptions and office mission

statements last updated in May 1996.
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Promotion Opportunities: Because ONDCP is a small, specialized agency with specific

areas of expertise, there are relatively few promotion opportunities.32 It is difficult for

staff members to move within the agency, due to the specialized nature of the work. But

there are also other internal promotion impediments, such as the ONDCP-specific GS-14

policy that does not allow a GS-15 promotion unless the position involves a supervisory

role. Thus, ONDCP has lost civilian staff to other federal agencies offering GS-15

opportunities that do not require supervisory roles. Further complicating the situation

and limiting promotion opportunities for GS-14 individuals may be the fact that many of

the GS-15 equivalent supervisory duties and functions are currently being carried out by

Lieutenant Colonel and Colonel level military detailees (See also Appendix I, reference

to interview with Director McCaffrey in the June 2000 issue of The Reserve Officer

Magazine).33

ONDCP's policy and program coordination work also requires individuals with advanced

training and experience. The size and structure of the agency creates another promotion

ceiling for GS-15 individuals due to the limited number of SES positions available.

Training: There are also very limited training opportunities for career civilian staff. The

FY 1996 training budget was approximately $30,000, and has not increased significantly

over the past four years with the increase from 40 to 124 FTE. The training budget

allocation is devoted primarily to educational programs for senior leadership, such as the

$7,000 senior executive course at Harvard University. The remaining budget pool does

not provide adequate training funds for ONDCP's support staff, analysts, and managers.

Without training opportunities in management or relevant areas of specialization, career

civilian staff have limited opportunities to advance toward personal and professional

development objectives.

These issues of career development, organizational development, promotions and training

do not affect the military detailees. The Department of Defense handles standard human

resource management practices such as career development, personal development, and

training for all military members.

 

32 On page 8 of ONDCP’s response, ONDCP states that “the report erroneously states that ‘there are

relatively few promotion opportunities’ within the agency.” In the following paragraph of ONDCP’s

response, ONDCP also states that as a small agency of 124 FTE, ONDCP cannot offer the same diversity

of professional opportunities that larger federal agencies and departments do. The project team supports

the original statement, consistent with ONDCP’s response, that because ONDCP is a small, specialized

agency with specific areas of expertise, there are “relatively” few promotion opportunities.

33 On page 8 of ONDCP’s response, ONDCP states that “the report inaccurately characterizes military

detailees as impediments to promotion” since military detailees do not occupy civilian FTE positions. The

project team supports the original statement based on interviews and on information gathered from

extensive research into the Director McCaffrey’s public record (See Appendix I, reference to an interview

with Director McCaffrey in the June 2000 issue of The Reserve Officer Magazine). Military detailees

perform important supervisory functions and other significant duties that contribute to the ongoing

operations of ONDCP. The majority of these supervisory functions and duties would be performed by

civilian employees, either through increased operational tempo or increased staff resources, were the

arrangement for 30 military detailees to be terminated. If the civilian employees were performing the

supervisory functions, then there would be more opportunities for civilians to be promoted into supervisory

positions under the existing policy.
Management Review

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3.2.1 (e) Human Resource Business Practices

The ONDCP personnel group is currently staffed with one FTE responsible for all of the

agency's human resources activities.34 Although there are shared responsibilities with the

Executive Office of the President,35 this single individual must attend to all ONDCPspecific areas of human resource management including the hiring strategy, payroll,

security clearances and work authorization, organizational planning, and employee

relations. Those areas require significant time and resources. Consequently, other proactive human resource management areas such as career development, retention strategy,

etc. have been neglected.

Human resource management is commonly organized around five process areas:

recruiting, HR information systems, career development, compensation and benefits

(operations), and training/organizational development. A graphical illustration is

presented in Figure 10. Each of these process areas are staffed with sufficient resources

to develop, coordinate, and execute personnel issues, policies, and programs that support

an organization's people.

Figure 10: Typical Human Resources Organizational Chart

Organizations of 100 to 150 employees generally have an HR staff of between 2 to 4

people. In those organizations with few resources, there are several HR processes that

can be outsourced, such as recruiting, HR information systems, and compensation and

benefits (operations). According to HR subject matter experts, the two key areas that

 

34 On page 7 of the ONDCP response, ONDCP indicated that the personnel office has currently assigned

two FTE to the agency’s civilian personnel activities. Although ONDCP may have assigned two FTE to

the office, ONDCP had only one individual serving in the office during the term of this review.

35 On page 7 of the ONDCP response, ONDCP asserts that the review team had failed to note that the

Executive Office of the President (EOP) supports ONDCP in certain human resource practices. The project

team acknowledges that ONDCP has, on a case by case basis, outsourced certain human resource activities

associated with recruiting and HR systems to EOP. The project team supports the original statement,

acknowledging a partnership with EOP. This statement also highlights the fact that human resource

activities that should remain resident within ONDCP were being handled by one individual during the

period of this review. As a result, the more pro-active HR activities, such as Career and Organizational

Development, were not being attended to because there was not enough staff support.

Human Resources

Director

Recruiting HR Information

Systems

Career

Development

Compensation &

Benefits

Training &

Organizational

Development

HUMAN RESOURCES

ORGANIZATIONAL CHART
Management Review

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must remain resident are career development and training and organizational

development. HR experts indicate that these areas are organization-specific, and require

an organization's internal leadership and management to make decisions regarding its

planning and execution, and the resulting overall retention strategy.

Recruitment, training and career development, and compensation/benefits are seen as key

contributors to staff retention and succession planning. Business practices indicate that

the relationship between recruiting, training, and compensation/promotion must be

consistent and effective.

Recruiting is a joint effort among human resources and business units. Expectations

management is important for both the organization and the recruiting candidates. The

identification of specific skill sets based on the organization's planning and development

is also vital to the success of recruiting and retention strategies.

Training serves as an incentive for people to stay in an organization, particularly if the

training is connected to an individual's career and personal interests and addresses

internal promotion opportunities. Organizations must ensure that opportunities are given

to staff to use the training. Investing resources into training must be coupled with a

strategy for retaining and recruiting staff and with career development strategies.

Subject matter experts also indicate that compensation and benefits are very important.

Among the social mission organizations, compensation is a minor influence on turnover

because individuals are primarily attracted to the nature of the work. However, other

benefits and incentives such as monetary and personal recognition, training, forms of

staff appreciation, vacation, management awards, and challenging assignments are

important to the organization's retention strategy. If all of these areas are addressed, then

organizations usually experience low turnover and high-quality employee satisfaction.

A graphical illustration that compares ONDCP's human resources practices to other

organizations’ business practices is presented below:

Table 10: Human Resource Practices in Organizations Interviewed

ONDCP GE PwC AMA AHA AP

Training ••• •

Career Development •••••

Recruiting Success •••••

Organizational Planning •••••

Retention Strategy •••••

Compensation/Benefits ••••••

ONDCP = Office of National Drug Control Policy

GE = General Electric

PwC = PricewaterhouseCoopers

AMA = American Medical Association

AHA = American Heart Association

AP = America's Promise
Management Review

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3.2.1 (f) Other Relevant Business Practices – Leadership Style

We found that leadership style and personality are key influences on overall culture,

particularly in organizations with a social mission. In a general sense, the leader sets the

“tone” for the workplace through his or her interaction with staff and the development of

internal policy. Over time, staff tend to align themselves with the beliefs and actions of

the leader, effectively shifting the culture of the organization to mirror the strong

characteristics of its leader. Those individuals with beliefs or behaviors at odds with the

leadership tend to seek other opportunities.

Organizations with a social or vocational mission, like America’s Promise, Office of

National AIDS Policy, and the Food and Drug Administration are often led by a public

“personality” or strong figure. Other successful organizations, like General Electric,

have well-known, charismatic leaders. In researching these organizations, we identified

several consistent characteristics:

• At America’s Promise, General Colin Powell has created a culture that mirrors many

private sector firms. There are no military detailees in the organization and few

individuals that have recently separated from the Armed Forces. At America’s

Promise, members of the leadership are in continuous verbal dialogue with staff to

enhance the performance of the organization. The entire leadership of America’s

Promise, including General Powell, tends to be hands-on and interactive with staff,

but does not micromanage individuals who have been delegated some form of

autonomy in carrying out their respective responsibilities.

• The AIDS Czar Director, Sandra Thurman has a small office of five staff members,

so a rather informal organizational and leadership style is in place. This office does

not have authority over any of the departments or agencies it works with.

Consequently, Director Thurman relies solely on her ability to foster positive working

relationships with departments and agencies involved in the AIDS prevention

initiative.

• At General Electric (GE), CEO Jack Welch emphasizes decentralization of power and

the creation of autonomy for manager level staff. His belief is that this practice

encourages professional debate and discussion within the organization, and provides

the latitude for managers to proactively search for solutions to client needs. An

example of this is a program called the “Workout Process.” This program consists of

hundreds of employees bringing up issues with senior leadership in the attempt to

identify and eliminate unneeded processes and tasks remaining from previous years,

when management had more layers. The workout team meets outside of its normal

work environment to discuss the issues and develop recommendations. Team

recommendations are presented to responsible managers, who must accept or reject

the proposal on the spot.
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3.2.1 (g) The Director's Schedule

ONDCP's operational tempo and workload are largely influenced by the leadership's

activity level, commonly referred to as "The Director's Schedule." The Director's

Schedule documents trips, events, media affairs, congressional testimony, office time,

other appointments, and meetings with drug, community relations, law enforcement, and

government experts.

As stated earlier in this report, the current Director secured an FTE authorization of 124

positions plus 30 military detailees when he took over in 1996. The Director structured

the organization to handle ONDCP’s primary objectives of policy, coordination, and

compliance and to coordinate his external schedule. At the behest of the Administration,

the Director created a process within ONDCP to handle his external schedule so that he

could use the “bully pulpit” to raise the awareness of the American public to the dangers

of drug use.

ONDCP is the fourth most often mentioned Cabinet office in the news media36 and the

current Director is a well-known figure internationally. Our purpose in presenting the

information in this section is only to create transparency with regard to the existence of

this event-based apparatus and to clarify the number of resources that a media presence of

this nature and magnitude requires.

The Director's Schedule involves up to 17 FTE,37 including effort from several of the

component groups. The FTE assist in areas of policy and product (message)

development, strategy and long range planning, internal and external coordination, event

planning and advance work, communications with Congressional district offices and

news affiliates, correspondence with the local print media, and general administration

(travel, security, etc).

Using the Director's calendar, we analyzed the activities to examine the amount of time

allocated to specific activities on his schedule. Although the information is not

conclusive, it provides a useful indicator of how the Director spends his time and how

much effort must be devoted to creating a sustained media presence. We recognized

during our review that the Director spends a significant amount of time in his office

reviewing and studying material. We focused the analysis, however, on activities with

external stakeholders such as the media, physicians and medical experts, law enforcement

experts, and federal, state, local, and international government officials. Using data from

six randomly selected months between November 1998 and November 1999, we

extrapolated to one year of time and evaluated the following: activity type, number of

activity occurrences, activity's total hours, average time (in minutes) per activity

occurrence, activity 's percent of total work time, and activity's percent of total non-office

time.

 

36 According to ONDCP’s Office of Public Affairs, the ONDCP ranks fourth behind the Department of

Defense, the Department of State, and the Department of Justice.

37 See Footnote 10.
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Based on the results of our analysis, we estimated that the Director spends an average of

54% of his non-office time involved in Media/Event affairs,38 8% in meetings with

medical/drug experts and on drug issues,39 14% in meetings with government leaders, 3%

in meetings regarding community relations, and 6% in meetings with law enforcement

experts.40

Annually, the Director spends approximately:

• 560 hrs. at approximately 650 Media Events, Appearances, Speeches, or on Media Issues;41

• 110 hrs. at approximately 160 meetings with Medical/Drug Experts or on Drug Issues;

• 35 hrs. at approximately 45 meetings for Community Relations; and

• 60 hrs. at approximately 50 meetings with Law Enforcement.

A representative table of our analysis is presented below with the full detail available in

Appendix J.

Table 11: Director’s Activity Time

Scheduling Category

(Activity Type)

Number of

Activities

(Blocks of

Time)

Estimated

Hours

Average

Time (Min)

Per

Activity

Percentage

of Total

Work Time

Percentage of

Non-Office

Time

Office Time+ 644 569 53 35% ----

Scheduling Meetings 26 28 65 2% 3%

Senior Staff Time/Meetings 72 64 53 4% 6%

Budget Meetings 18 10 32 1% 1%

Personnel Interviews 34 27 48 2% 3%

IPR*- Drug Issues 42 25 35 2% 2%

IPR- Media/Events 206 147 43 9% 14%

Media Affairs/Events/Trips 434 413 57 26% 40%

Meetings: Government Leaders 164 144 53 9% 14%

Meetings: Community Relations 42 36 52 2% 3%

Meetings: Medical/Drug Experts 118 87 44 5% 8%

Meetings: Law Enforcement Experts 48 61 76 4% 6%

Total 1611 100% 100%

+ Time spent reviewing and studying material.

*

Interim Progress Review – military term, ONDCP interviews.

 

38 This number represents media interviews, speeches and appearances that do not involve dialogue with

event representatives or experts (40%), and preparation for Media/Events (14%). On page 11 of the

ONDCP response, ONDCP states that “the assertion that 54 percent of the Director’s non-office activities

are media events is absurd.” The project team emphasizes that the original text refers to “Media/Events,”

rather than “media events.” The project team also supports its original statement based on the minute by

minute analysis of the Director’s Schedule calendar.

39 This number is the sum of "IPR-Drug Issues" and "Meetings: Medical/Drug Experts" (see Table 11).

40 This analysis does not include travel time to and from events, which is also significant.

41 Appearances and speaking engagements that did not involve dialogue with event representatives or

experts were included in this category.
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Analysis of Media/Events and Policy Affairs

Using the Director's calendar, we categorized and charted the Media/Events activities to

examine the average time allocated to specific Media/Event categories on the schedule:

type of activity, number of occurrences, activity's total hours, and average number of

minutes per occurrence (see Table 12).

Based on our analysis, the Director makes an estimated 386 public appearances per year,

via addresses/remarks/speeches and media interviews/tapings/videos. He spends an

estimated 290 hours at these public appearances.42 The Director also attends

approximately 90 media-related meetings/briefings/working meals, spending an

additional 120 hours per year.

Table 12: Director’s Media/Event Schedule

Media Affairs Category

(Activity Type)

Number of

Events/Activities

Estimated

Hours

Percent of

Time/Category

Average Time

(Min/Event)

Address/Remarks/Speech 118 162 29% 82

Interviews/Tapings/Videos 268 129 23% 29

Sub-Total 386 290 ----- -----

Meetings/Briefings/Working Meals 70 93 16% 80

Attends/Visits 20 28 5% 85

Sub-Total 90 121 ----- -----

IPR* - Media/Events 206 147 26% 43

Total—Media Affairs 682 560 100% -----

 Percentage of Total Time 54%

*

Interim Progress Review – military term, ONDCP interviews

The Director also attends approximately 250 drug-related (medical/drug, IPR’s,

community relations, law enforcement) meetings, at approximately 210 hours per year.

We understand that the Acting Deputy Director of ONDCP handles many medicallyoriented and scientifically-oriented meetings and public appearances as well.43

 

42 This does not include travel time to and from events.

43 The Deputy Director’s schedule, which is significant but not listed here, is also supported by the staff.
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A representative table of our analysis is presented below.

Table 13: Policy-Related Affairs

Policy-Related Affairs Category

(Activity Type)

Number of

Activities

Estimated

Hours

Percent of

Time/Category

Average Time

(Min/Activity)

Senior Staff Time/Meetings 72 64 15% 53

Budget Meetings 18 10 2% 31

Meetings: Government Leaders 164 144 34% 52

IPR*- Drug Issues 42 25 6% 35

Meetings: Community Relations 42 36 8% 51

Meetings: Medical/Drug Experts 118 87 20% 44

Meetings: Law Enforcement Experts 48 61 14% 76

Subtotal 250 209 ----- -----

Total—Policy Related 504 427 100% -----

Percentage of Total Time 43%

* Interim Progress Review – military term, ONDCP interviews

The activities that support the Director’s Schedule constitute an operational business

process with a level of effort that may not have been readily transparent to external

stakeholders. With significant resources dedicated to supporting this schedule and with

the addition of programmatic charges by Congress in recent years, there has been an

erosion in ONDCP’s ability to efficiently conduct its primary objectives of policy,

coordination, and compliance.

Given that authority and institutional knowledge are concentrated centrally with the

current Director and that the depth of the knowledge base appears to be weakened and

vulnerable, the project team attempted to address the issue of the continuity of ONDCP

beyond the current Directorship. As an official of the United States Government, the

Director of ONDCP is a steward of the public trust. It is incumbent upon the Director,

therefore, to provide for the institutionalization and continuity of the organization beyond

his or her tenure. We requested formal documentation that would give guidance on the

operations and activities of the components and functional offices of the organization

beyond its current term.

3.3 FORMAL GUIDANCE TO GOVERN THE COMPONENTS AND OFFICES

BEYOND THE CURRENT ONDCP DIRECTORSHIP WAS NOT AVAILABLE
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3.3.1 ONDCP-Specific written policies and procedures were not

available

The project team requested ONDCP-specific written policies and procedures that would

give guidance on component and functional office activities. These documents would

provide guidance in order to avoid conflicts of interest and would serve to govern the

organization beyond the current Directorship. In response to the original request, we

were informed that specific policies and procedures for these areas are not available.44 (In

ONDCP’s response to this report, ONDCP clarified that they do have ethics materials and

that they closely follow EOP guidance.) The main document that outlines the missions,

position descriptions, and responsibilities of the entities within ONDCP has not been

formally updated since May 1996 when ONDCP had approximately 40 individuals on the

payroll.

It is essential for organizations to have standardized policy and procedure documents to

ensure the integrity, viability, and continuity of the organization. These documents

include, for example, staff and process manuals, position descriptions, office

descriptions, office codes of conduct, and regulation documents. Without written policies

and procedures that would preserve and manage the knowledge of the organization, an

effective transition under the next Directorship is not assured.

3.3.2 The Organization Charts provided are temporary and in conflict

with each other

The purpose of organizational structure in business operations is to create an environment

that supports the staff members’ efficient execution of the mission and of the core

business processes. Without a rigorous understanding of how misalignments in an

organization’s structure can produce unintended disincentives to achieving desired

behaviors, agency and department heads could inadvertently sabotage their own efforts

toward efficiently executing the mission. If, for example, an individual has a confusing

chain of command that causes her to have burdensome reporting requirements, she may

become disgruntled or may not be able to complete all of her other responsibilities.

Establishing the correct organizational setting becomes very important to the optimal

execution of service delivery.

Organizations use charts to clearly communicate authorities, responsibilities, and

reporting structures to internal and external stakeholders. We requested a copy of

ONDCP’s organizational chart. We were provided with three distinct versions of the

ONDCP “Proposed” Organization Chart that were dated within weeks of each other:

February and March 2000.45 All three charts conflict with reality and with each other.

 

44 On page 9 of the ONDCP response, ONDCP states that the conclusion referenced above “is wrong.” The

project team formally requested access to ONDCP-specific policies and procedures governing the

organization during the week of April 17, 2000. The project team was informed that ONDCP-specific

procedures and policies do not exist.

45 Original versions of ONDCP Organization Charts are included in Appendix C.
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The existence of several conflicting charts communicates confusion to all stakeholders.

Inconsistent communication tools are likely indicators that there are situations where

resources are not being fully optimized.

3.3.3 Other Relevant Business Practices - Policies and Procedures.

All the organizations we interviewed had some type of internal policy and procedure

document. Examples of staff manuals and regulation documents can be found at the

FDA and at America’s Promise. The staff manual guides describe the business processes

of the organization and the specific offices. FDA’s regulation guides, for example,

include a Compliance Policy Guide which standardizes the way FDA issues regulatory

guidance across the agency and a Good Practice Policy which gives the inspectors a

checklist of instructions they should follow when inspecting food and drug organizations.

These internal policies must be consistent with the external policy guidance that they

hand over to their inspectors and inspected companies so that regulations are completed

according to policy.

3.4 SUMMARY OF HR AND ORGANIZATIONAL ANALYSIS

In summary we have observed that although the organization is generally sophisticated

and accomplished, there is a shortage of investment and staff resources to accomplish all

of the activities and objectives imposed upon it by the Congress, the Director, and the

legislative charter. The shortage is equally attributable to the increase in workload

associated with new activities, supporting the Director's priorities, and the inability of the

organization to recruit and retain qualified staff.

In the course of this evaluation, the project team identified the following issues that raise

a concern about the future continuity of ONDCP: 1) authority is centralized and a

significant amount of institutional knowledge resides with the current Director; 2) the

knowledge base has been eroded by recruitment and retention problems in recent years;

3) relative to its size, an inordinate number of leadership and professional staff positions

(up to 38%) may be vulnerable in calendar year 2000; and 4) ONDCP-specific written

guidance addressing the activities within the components and functional offices that

would contribute to the continuity of the organization appears to be largely absent.
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4.0 BUDGETING, ACCOUNTING, AND FINANCIAL

REPORTING SYSTEMS AND INTERNAL CONTROLS

As part of this review, the project team was asked to provide organizational solutions and

recommendations for improving the performance, efficiency, and effectiveness of

ONDCP’s internal controls. In the course of our review, the project team conducted a

number of interviews with key financial management personnel and also with key

stakeholders. We complemented the interviews with general and web-based research.

The combination of interviews and research provided a foundation for the determination

of our findings. In addition, we also developed our approach based on the findings,

recommendations, and conclusions drawn from other areas of the management review.

In looking at internal financial controls, we focused on the following areas:

• the risk of a breakdown in internal financial controls within ONDCP;

• levels of discretionary and non-discretionary operational budgetary funding;

• impact of the progressive increase in workload and operational tempo on the

Financial Management Office (FMO); and

• potential for improvement through reengineering working practices and introducing

new technology.

To evaluate the risk of a breakdown in internal financial controls within ONDCP the

project team challenged the roles, responsibilities, and ways of working against an

internal controls framework. This framework consists of six key internal controls that we

would expect to be in place in the financial office of any organization. The framework

and our findings are presented in the Summary Analysis of ONDCP Internal Financial

Control Risks in Appendix D.

ONDCP outsources many of its financial operational activities, such as procurement and

payment of vendors, contract management, and payroll. ONDCP employs the

Administration Office of the EOP (AOEOP) for reviewing and processing financial

transactions. In addition, ONDCP uses the contracting capabilities of the Department of

Health and Human Services (HHS) for large and complex Media Campaign contracts.46

 

46 Please note that a review of internal financial controls of AOEOP or HHS has not been undertaken as it is

outside of the scope of this management review.

4.1 INTERNAL CONTROL RISK
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ONDCP still has approval authority over these contracts because the Director approves

every initiative. In addition, there is a management and contract specialist who acts as a

liaison between HHS and other contractors involved in the Media Campaign. Therefore,

ONDCP has oversight control over the actual execution of these contracts. ONDCP

recognizes the limitations of its own organization and the capabilities of others, and by

outsourcing these activities, ONDCP brings inherent strength in internal financial

controls.

As can be seen from the review of internal controls, on the whole ONDCP appears to be

at a low to medium risk of any breach in confidence that the organization is not adhering

to sound and prudent internal financial controls. We believe, however, that there is an

area that should warrant further attention. There is a potential internal control risk arising

from not adequately matching the increased responsibilities and workload with the

required investment in the financial management infrastructure. The potential

implications of not mitigating the risk of a breakdown in the management, supervisory,

and personnel internal controls are:

• Lack of quality assurance over work products due to time pressures;

• Inappropriate levels of authority, delegation, and decision-making, given underlying

roles, responsibilities, and competencies; and

• A decline in customer service from the FMO.

We classified this as a medium risk. Should the investment not be made, however, there

would be increased exposure and a greater likelihood of a breakdown in this area.
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We have provided an analysis of the discretionary funding available to the Director and

his senior management team. This analysis is detailed in Table 14 below.

Table 14: Analysis of Discretionary and Non-discretionary Funding47

Budget Line Item Discretionary NonDiscretionaryNotes

$million $million

Personal Services 10.40 $0.5 million was reprogrammed to Other Services

because not able to fill all 124 FTE positions

Travel and Transportation

of Things

0.72

Rents, Comm., & Utilities 2.54

Printing & Reproduction 0.45

Other Services 4.71 Used $0.5 million for contractual services procured

from HHS

Supplies, Materials and

Equipment

0.30

Model State Drug Law 1.00

Policy Research 1.10

CTAC 29.00 Mandated by Congress, and “passed though” by

ONDCP

HIDTA program 186.50 Mandated by Congress, and “passed through” by

ONDCP

Special Forfeiture Fund

(Media Campaign funds)

216.50 Mandated by Congress, and “passed though” by

ONDCP

1999 Total Budget* 5.88 447.34

Re-programming Total 0.50 (0.50)

Percentage of Total

Budget

1.4% 98.6%

*

Budget numbers in table may be rounded.

 

47 Based upon the FY 1999 Budget Submission.

4.2 DISCRETIONARY AND NON-DISCRETIONARY FUNDING AVAILABLE TO THE

DIRECTOR AND ONDCP SENIOR MANAGEMENT
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Table 14 show that less than 2% of the current funding is discretionary. In addition, the

absolute monetary value is nominal at $6.4 million per annum -- miniscule against the

annual cost of the entire federal government. The low dollar value of discretionary funds,

combined with our analysis indicating that there is a low to medium risk of a breach in

financial internal controls provided us with enough evidence to support our findings. The

project team then redirected the focus of the review to the assessment of other areas of

management.

The HIDTA program has received additional funding over the last several years through

the approval of Congress. This increase in funding generated additional workload. The

increase in program workload has not been matched with an investment in the FMO

infrastructure; thus, the workload has been handled through an increase in the

“operational tempo” of the organization in order to gain more results from existing

resources.

As can be seen from the graph in

Figure 11, the level of funding

for the HIDTA program has

increased significantly since the

appointment of the current

Director. The number of

HIDTAs has more than doubled

from 15 in 1996 to 31 in 2000,

with funding rising from

$102.9m to $191.2m in the same

period.

Significantly, the number of

FMO staff assigned to manage

the program has remained

constant at two people.

Figure 11: Graph Showing the HIDTA Funding

Levels and Number of Programs Over Time

0

50

100

150

200

250

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000

HIDTA Funding ($m)

0

5

10

15

20

25

30

35

Number of HIDTA Programs

HIDTA Funding ($m) Number of HIDTA programs

Over the last four years, two staff members have been managing approximately 1,400

individual HIDTA budgets, requiring preparation and validation, maintenance,

reprogramming, and financial reporting. Their only functional support comes from the

Florida HIDTA Center, which submits invoices for all HIDTA purchases. One FMO

staff member at ONDCP must still review the purchase invoices and send them to the

EOP Office of Administration for payment processing. The workload associated with the

manual processes has increased by a significant factor, with the more than doubling of

the number of HIDTAs. ONDCP has not recruited additional staff or developed enabling

technologies to support the increase in workload.

4.3 THE IMPACT OF THE PROGRESSIVE INCREASE IN WORKLOAD AND

OPERATIONAL TEMPO WITHIN THE FINANCIAL MANAGEMENT OFFICE
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In our review the project team identified potential weaknesses in internal controls,

generally centered on a lack of investment in the FMO infrastructure to meet the increase

in workload. To address these weaknesses, and to mitigate further risk, ONDCP could

reengineer working practices and introduce new technology. The HIDTA program can

be used as an example to illustrate these opportunities.

4.4.1 Reengineering ways of working

The FMO is required to assist the HIDTA funding recipients in preparing detailed

budgets. The FMO is also required to monitor any subsequent reprogramming of these

budgets. Any simple reprogramming which merely moves funds from one object class to

another within that individual HIDTA is approved by the appropriate HIDTA Director.

The approved reprogramming is then submitted for the ONDCP HIDTA Program Office

to review and for the FMO staff to process the reprogramming transaction. A more

complex reprogramming involving movement of funds between initiatives and/or

agencies (to include reprogramming of funds from federal budgets to grants, from grants

to grants, or from federal budgets to federal budgets) requires approval of the appropriate

HIDTA Director and/or HIDTA Executive Committee, the ONDCP HIDTA Director,

and the FMO staff, who in turn must process the reprogramming transaction. To date,

there have been a total of 2,000 reprogramming transactions.

The constant reprogramming of funds drives the workload through the maintenance and

update of the budget. The success and growth of the HIDTA program requires

complementing growth of business practices and adequate oversight. Reengineering ways

of working could relieve unnecessary workload for the FMO. For example, devolving

control and delegating processing for simple reprogramming within the HIDTAs to the

HIDTA Directors and regional staff could result in a potential reduction in the workload

burden of the FMO, and could also make the HIDTA Directors more accountable and

empowered in applying their funds, measuring outcomes, and reporting budget

adjustments.

4.4.2 Investing in technology

Accounting and budgeting for the growing number of geographically dispersed HIDTAs

are supported by a Microsoft Access database. The characteristics and attributes of user

requirements for fiscal control, program management, and information reporting lend

themselves to improvement through new technology. For example, a web-based

budgeting system could support real-time HIDTA program management, providing

improved inherent internal financial controls, and providing the visibility of program

information for users and management alike.

Little effort is needed to discover opportunities for improvement through reengineering

working practices and introducing new technology. It must be stressed that these

4.4 POTENTIAL FOR IMPROVEMENT BY REENGINEERING WORKING

PRACTICES AND INTRODUCING NEW TECHNOLOGY.
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opportunities have also been recognized by the FMO. The ability of the FMO to

capitalize on these opportunities, however, is being hindered by the day-to-day

operational tempo and the lack of investment funding.
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Appendix A: ONDCP Employees Interviewed*

Title, Office

Director

Deputy Director

Chief of Staff

Deputy Chief of Staff

Assistant for Personnel

Asst. Deputy Director, Bureau of State and Local Affairs

Acting Deputy Director, Supply Reduction

Asst. Deputy Director, Demand Reduction

General Counsel, Office of Legal Counsel

Acting Director, Office of Programs, Budget, Research & Evaluation

Director, Financial Management Office

Director, Counter-Drug Technology Assessment Center

Director, Office of Legislative Affairs

Director, Office of Intelligence

Senior Advisor & Chief, Media Campaign

Director, Office of Administration

Acting Director, Office of Public Affairs

Director, Office of Strategic Planning

Asst. Director, Office of Public Affairs

Executive Assistant to the Director

Budget Analyst, Financial Management Office

Budget Analyst, Financial Management Office

Budget Analyst, Financial Management Office

Budget Analyst, Financial Management Office

Branch Chief, Production & Trafficking

 

*

 Participation in the interview phase of the project does not indicate knowledge or concurrence with the

information presented in this report.
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Appendix B: The External Organizations Researched and/or Interviewed in the Public

and Private Sector*

 

*

 Participation in the interview phase of the project does not indicate knowledge or concurrence with the

information presented in this report.

Senior manager interviews with the

following organizations:

United Kingdom Anti-Drug Coordinator Unit

Office of National AIDS Policy

America’s Promise

American Heart Association

American Medical Association

Food and Drug Administration

Bureau of Alcohol, Tobacco, and Firearms

General Electric

PwC Human Resources

Office of U.S. Trade Representatives

Research on the following organizations:

Business Software Alliance

Immigration and Naturalization Service

US Conference of Mayors

US Surgeon General

Department of Defense - Legislative Affairs

Health and Human Services
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Appendix C: Three Original Versions of ONDCP Organization Charts

Please see the pages to follow



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ry Analysis of ONDCP Internal Financial Control Risk

Internal control description What we observed Evaluation of risk

Clear segregation of duties for all areas of thefinancial management cycle; for example,procurement and vendor payment authority areseparate within the organization.

 There are clear segregation of duties within

the Financial Management Office (FMO) andalso within the infrastructure of ONDCP,particularly between the Office ofAdministration and the FMO.

Very Low

Clear roles and responsibilities within theorganization, with segregated organizationalduties; for example, financial management ofprograms is separate from program management.

 Within ONDCP, the FMO is a separate

organizational entity, reporting directly to theDirector.

 In addition, as ONDCP is an EOP agency,

there is an additional reporting requirement toEOP financial management staff.

 EOP Financial Management staff ensure that

financial and contractual transactions are notconsidered improper or unethical, and thatthey will pass “the Washington Post test.”

 The recent centralization of FMO staff has

removed staff from the day-to-day contactwith the management of the programs. Whilethis may improve segregation of duty internalcontrol, it otherwise decreases organizationaloversight.

Low to medium, butsee observations onPersonnel controls
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Internal control description What we observed Evaluation of risk

All transactions are subject to the correct andproper level of authorization; for example,procurement approval limits are in place andadhered to.

 All financial transactions, including budget

preparation and execution, and procurementand payment of suppliers are authorized bothinternally within ONDCP and also by EOPstaff members.

 Budget preparation, major contracts, and other

significant financial transactions by size orcontent are all subject to sign-off by theDirector.

Very low

Accounting controls are in place; for example,general ledger and cash accounts are reconciled ona timely and periodic basis.

 EOP maintains the financial systems. Internal budgeting and accounting systems for

the HIDTA program, for example, are reliantupon either manual processes orunsophisticated automation through Accessdatabases.

 While the Access databases may be

considered “fit for purpose,” the FMO has notreceived the required investment inInformation Technology for custom systemsto support program delivery, or for the use ofweb-based solutions that would improveoperations and customer service of theHIDTA program.

Medium
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Internal control description What we observed Evaluation of risk

ory,

Competent and experienced staff members areperforming financial management activities. Staffmembers are subject to appropriate levels ofmanagement and supervision; for example,managers are providing quality assurance overfinancial management work products.

 The staff members in the FMO are

experienced and competent to perform theirduties, based on their length of service andqualifications.

 The HIDTA Program has received an increase

in funding, through the approval by Congress.This increase in funding generates additionalworkload.

 Increased program workload has not been

matched with an investment in the FMOinfrastructure, rather the workload has beenabsorbed by an increased “operational tempo”in order to gain more results from existingresources.

Medium

All assets are protected securely  Not applicable Not applicable
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Appendix E: U.S. Department of Justice Office of Legal Counsel

Memorandum for Agency General Counsels

Re: General Guidance on the Federal Vacancies Reform Act of 1998

March 22, 1999

Please see the pages to follow














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Appendix F: ONDCP’s Response Letter to a Preliminary Draft of the Report

Please see the pages to follow












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Appendix G: Legislative Citations

21 USC SEC. 1703. APPOINTMENT AND DUTIES OF DIRECTOR AND

DEPUTY DIRECTORS

(b) Responsibilities

The Director -

(1) shall assist the President in the establishment of

policies, goals, objectives, and priorities for the National Drug

Control Program;

(2) shall promulgate the National Drug Control Strategy under

section 1705(a) of this title and each report under section

1705(b) of this title in accordance with section 1705 of this

title;

(3) shall coordinate and oversee the implementation by the

National Drug Control Program agencies of the policies, goals,

objectives, and priorities established under paragraph (1) and

the fulfillment of the responsibilities of such agencies under

the National Drug Control Strategy and make recommendations to

National Drug Control Program agency heads with respect to

implementation of Federal counter-drug programs;

(4) shall make such recommendations to the President as the

Director determines are appropriate regarding changes in the

organization, management, and budgets of Federal departments and

agencies engaged in drug enforcement, and changes in the

allocation of personnel to and within those departments and

agencies, to implement the policies, goals, priorities, and

objectives established under paragraph (1) and the National Drug

Control Strategy;

(5) shall consult with and assist State and local governments

with respect to the formulation and implementation of National

Drug Control Policy and their relations with the National Drug

Control Program agencies;

(6) shall appear before duly constituted committees and

subcommittees of the House of Representatives and of the Senate

to represent the drug policies of the executive branch;

(7) shall notify any National Drug Control Program agency if

its policies are not in compliance with the responsibilities of

the agency under the National Drug Control Strategy, transmit a

copy of each such notification to the President, and maintain a

copy of each such notification;

(8) shall provide, by July 1 of each year, budget

recommendations, including requests for specific initiatives that

are consistent with the priorities of the President under the

National Drug Control Strategy, to the heads of departments and

agencies with responsibilities under the National Drug Control

Program, which recommendations shall -

(A) apply to the next budget year scheduled for formulation

under chapter 11 of title 31, and each of the 4 subsequent

fiscal years; and

(B) address funding priorities developed in the National Drug

Control Strategy;
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(9) may serve as representative of the President in appearing

before Congress on all issues relating to the National Drug

Control Program;

(10) shall, in any matter affecting national security

interests, work in conjunction with the Assistant to the

President for National Security Affairs;

(11) may serve as spokesperson of the Administration on drug

issues;

(12) shall ensure that no Federal funds appropriated to the

Office of National Drug Control Policy shall be expended for any

study or contract relating to the legalization (for a medical use

or any other use) of a substance listed in schedule I of section

812 of this title and take such actions as necessary to oppose

any attempt to legalize the use of a substance (in any form) that-

(A) is listed in schedule I of section 812 of this title; and

(B) has not been approved for use for medical purposes by the

Food and Drug Administration;

(13) shall require each National Drug Control Program agency to

submit to the Director on an annual basis (beginning in 1999) an

evaluation of progress by the agency with respect to drug control

program goals using the performance measures for the agency

developed under section 1705(c) of this title, including progress

with respect to -

(A) success in reducing domestic and foreign sources of

illegal drugs;

(B) success in protecting the borders of the United States

(and in particular the Southwestern border of the United

States) from penetration by illegal narcotics;

(C) success in reducing violent crime associated with drug

use in the United States;

(D) success in reducing the negative health and social

consequences of drug use in the United States; and

(E) implementation of drug treatment and prevention programs

in the United States and improvements in the adequacy and

effectiveness of such programs;

(14) shall submit to the Appropriations committees and the

authorizing committees of jurisdiction of the House of

Representatives and the Senate on an annual basis, not later than

60 days after the date of the last day of the applicable period,

a summary of -

(A) each of the evaluations received by the Director under

paragraph (13); and

(B) the progress of each National Drug Control Program agency

toward the drug control program goals of the agency using the

performance measures for the agency developed under section

1705(c) of this title; and

(15) shall ensure that drug prevention and drug treatment

research and information is effectively disseminated by National

Drug Control Program agencies to State and local governments and

non-governmental entities involved in demand reduction by -

(A) encouraging formal consultation between any such agency

that conducts or sponsors research, and any such agency that

disseminates information in developing research and information

product development agendas;
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(B) encouraging such agencies (as appropriate) to develop and

implement dissemination plans that specifically target State

and local governments and nongovernmental entities involved in

demand reduction; and

(C) developing a single interagency clearinghouse for the

dissemination of research and information by such agencies to

State and local governments and nongovernmental agencies

involved in demand reduction.

21 USC SEC. 1705. DEVELOPMENT, SUBMISSION, IMPLEMENTATION, AND

ASSESSMENT OF NATIONAL DRUG CONTROL STRATEGY

(a) Timing, contents, and process for development and submission of

National Drug Control Strategy

(3) Process for development and submission

(A) Consultation

In developing and effectively implementing the National Drug

Control Strategy, the Director -

(i) shall consult with -

(I) the heads of the National Drug Control Program

agencies;

(II) Congress;

(III) State and local officials;

(IV) private citizens and organizations with experience

and expertise in demand reduction;

(V) private citizens and organizations with experience

and expertise in supply reduction; and

(VI) appropriate representatives of foreign governments;

(ii) with the concurrence of the Attorney General, may

require the El Paso Intelligence Center to undertake specific

tasks or projects to implement the National Drug Control

Strategy; and

(iii) with the concurrence of the Director of Central

Intelligence and the Attorney General, may request that the

National Drug Intelligence Center undertake specific tasks or

projects to implement the National Drug Control Strategy.

5 CFR Sec. 304.102 PERSONNEL CHAPTER I--OFFICE OF PERSONNEL

MANAGEMENT PART 304--EXPERT AND CONSULTANT APPOINTMENTS

Table of Contents

Definitions. For purposes of this part:

(a) An agency is an executive department, a military department, or an independent agency.

(b) A consultant is a person who can provide valuable and pertinent advice generally drawn from a high

degree of broad administrative, professional, or technical knowledge or experience. When an agency

requires public advisory participation, a consultant also may be a person who is affected by a particular

program and can provide useful views from personal experience.

(c) A consultant position is one that requires providing advice, views, opinions, alternatives, or

recommendations on a temporary and/or intermittent basis on issues, problems, or questions presented

by a Federal official.
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(d) An expert is a person who is specially qualified by education and experience to perform difficult and

challenging tasks in a particular field beyond the usual range of achievement of competent persons in

that field. An expert is regarded by other persons in the field as an authority or practitioner of unusual

competence and skill in a professional, scientific, technical or other activity.

(e) An expert position is one that requires the services of a specialist with skills superior to those of others

in the same profession, occupation, or activity to perform work on a temporary and/or intermittent

basis assigned by a Federal official. For example, a microbial contamination specialist may apply new

test methods to identify bacteria on products, a computer scientist may adapt advanced methods to

develop a complex software system, or a plate maker may engrave a novel design.

(f) Intermittent employment, as defined in part 340, subpart D, of this chapter, means employment without

a regularly scheduled tour of duty.

(g) Temporary employment means employment not to exceed 1 year. An expert or consultant serving

under a temporary appointment may have a full-time, part-time, seasonal, or intermittent work

schedule.

(h) Employment without compensation means unpaid service that is provided at the agency's request and

is to perform duties that are unclassified. It is not volunteer service.
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Appendix H: ONDCP Mission Statements and Position Descriptions

• Office of the Director, ONDCP Mission Statement, May 1996: The Director of the Office of National

Drug Control Policy is charged with formulating, evaluating, coordinating, and overseeing both

international and domestic anti-drug abuse functions by all Executive Branch agencies, and ensuring

that such functions sustain and complement State and local anti-drug abuse efforts.

• Director, ONDCP Position Description, May 1996: The Director of ONDCP is a member of the

President’s Cabinet, the National Security Council, and is the principal Administration and national

spokesperson on illicit drug use and related issues. The Director’s role is to create a national

understanding of the nature of the threat from illicit drug use and the importance of resisting drug

abuse and its consequences at all levels of society. The Director also serves as the “drug issues

advocate” within the Federal government, developing collaborative, bipartisan relationships with the

Cabinet, members of Congress, and Washington interagency community. Additionally, the Director

coordinates and oversees other national drug control program agencies, reviews and certifies agencies’

drug control budgets, and serves as Chair of ONDCP’s Research, Data, and Evaluation Advisory

Committee.

• Office of Demand Reduction, ONDCP Mission Statement, May 1996: The Office of Demand

Reduction, ONDCP, is responsible for advising the Director of ONDCP on policies and programs to

reduce the demand for drugs and ensuring the implementation of the demand-related portions of the

National Drug Control Strategy. In carrying out this responsibility, the office advises the Director,

ONDCP, on policies, objectives, and priorities pertaining to demand reduction...

• Deputy Director of Demand Reduction, ONDCP Position Description, May 1996: As Deputy Director

of Demand Reduction, ONDCP, the incumbent is a principal assistant to the Director, ONDCP,

responsible for overseeing the demand policy requirements and analysis and the formulation of

demand reduction issues in the government-wide National Drug Control Strategy... The incumbent is

charged with assisting the Director, ONDCP with providing the executive direction required for

organizing and overseeing the activities of the Office of Demand Reduction.
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Appendix I: Excerpt from The Retired Officer Association (TROA) Magazine, June

2000, Vol. LVI. No. 6, “Soldiering On: General Barry McCaffrey Talks with Tom

Philpott”

(TROA:) Was there a national drug strategy before you took over?

(Director McCaffrey:) Interesting question. One thing I bring to this job is planning. I was the Army’s

strategic planner, the joint strategic planner, Gen. [Colin] Powell’s National Security Council guy. So I had

intellectual tools you get from DoD where you organize one of the world’s largest activities. I knew I had

to have a strategy. Turns out there was one, but I’d never heard of it even as a cinc. It was an annual

document, a throwaway. We said, “No, we’ve got to have a strategy.” We also demanded, and got written

into law, a requirement for me to produce each year a five-year budget estimate for programs. And we had

the law rewritten to demand that I create performance measures of effectiveness. Now we’re building a

database to measure how programs are achieving their purpose.

(TROA:) You also beefed up the staff.

(Director McCaffrey:) I said to the secretary of Defense, “I’m not going over there if you don’t give me

30 military detailees.” I needed some planners. Now, the staff directors of the four major subcomponents of

the [ONDCP] are all full colonels. My deputy chief of staff was a full colonel. The intelligence officer and

some planners are military. This tiny number of military officers gave a very different tempo and discipline

[to] what was essentially a dispirited, undermanned, confused group of civilians.

(TROA:) Will that military element be perpetuated?

(Director McCaffrey:) It darn sure better be. There’s a billion dollars of DoD money involved, out of

$19.2 billion overall. There are national security aspects to it. The National Guard, the Air Force and Navy,

Army Special Forces, our intelligence system are all part of this effort. So there’s certainly room for the

small number of very talented, dedicated military officers.
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Appendix J: Full Breakdown of the Director’s Schedule

Please see the page to follow