U.S. ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

 Evaluation Report 

EPA’s Revised Hiring Process 

Needs Additional Improvements 

 Report No. 10-P-0177 

 August 9, 2010 
 

Report Contributors: Eric Lewis 

 Larry Dare 

 Dwayne Crawford 

 Chris Baughman 

 Ben Beeson 

 Allison Dutton 

 Christine El-Zoghbi 

 Tim Roach 

Abbreviations 

EPA U.S. Environmental Protection Agency 

HRACTS Human Resources Activity and Communication Tracking System 

HRMD Human Resources Management Division 

OARM Office of Administration and Resources Management 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

RTP Research Triangle Park 

SOP Standard Operating Procedure 
 

U.S. Environmental Protection Agency 10-P-0177 

August 9, 2010 Office of Inspector General 

At a Glance 

Catalyst for Improving the Environment 

Why We Did This Review 

We reviewed the U.S. 

Environmental Protection 

Agency’s (EPA’s) 

appointment process managed 

by its Office of Administration 

and Resources Management 

(OARM) to determine how the 

new process for filling 

vacancies can be more 

efficient and effective. 

Background 

OARM revised EPA hiring 

procedures in June 2008 when 

it consolidated the processing 

of personnel actions from 

15 locations across the country 

to 3 OARM service centers. 

These procedures must 

comply with pertinent 

requirements, including those 

imposed by the Office of 

Personnel Management 

(OPM). 

For further information, 

contact our Office of 

Congressional, Public Affairs 

and Management at 

(202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2010/ 

20100809-10-P-0177.pdf 

EPA’s Revised Hiring Process 

Needs Additional Improvements

 What We Found 

EPA had not implemented critical technology upgrades or obtained other 

resources necessary for the service center concept to succeed. EPA produced 

three reports, including its 2007 Business Case, which identified key factors for a 

successful transition to the service center concept. However, EPA management 

implemented the transition without obtaining some of these key capabilities, 

including electronic infrastructure. Proceeding without ensuring that key 

requirements were satisfied is a significant weakness in management control. As a 

result, the new process to fill vacant positions falls significantly short of OPM 

timeliness goals and does not consistently provide program managers with the best 

candidates. 

Service centers did not consistently provide program managers with the best 

candidates, and data quality and recruitment action processes need improvement. 

We also noted a lack of management attention to policies and inconsistencies in 

service center operations. As a result, the appointment process is not providing 

program offices with the right people, in the right place, at the right time, thus 

impacting EPA’s ability to effectively perform its mission. 

What We Recommend 

We recommend that EPA officials determine the scope of services to be obtained 

from a line-of-business provider, select the provider, and develop and implement a 

plan to migrate to the provider. In addition, we recommend that the appropriate 

EPA official help program offices standardize position descriptions and review 

EZ-Hire questions; increase subject matter expert involvement in evaluating 

applications; improve the reorganization policy and procedures; obtain feedback 

on inquiries about personnel actions being processed; and address various staffing, 

policy, and procedural issues. 

In response to Agency comments on the draft report, we changed the action 

official for five recommendations and slightly modified the wording for two. 

Agency officials agreed with most of our recommendations but disagreed with 

recommendation 2-3 and part of recommendation 3-4; these recommendations are 

undecided pending the Agency’s 90-day response. 
 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

August 9, 2010 

MEMORANDUM 

SUBJECT:	 EPA’s Revised Hiring Process Needs Additional Improvements 

 Report No. 10-P-0177 

FROM:	 Arthur A. Elkins, Jr. 

 Inspector General 

TO: Craig Hooks 

 Assistant Administrator for Administration and Resources Management 

Barbara Bennett 

Chief Financial Officer 

Malcolm D. Jackson 

Assistant Administrator for Environmental Information 

and Chief Information Officer 

This is a report on the subject evaluation conducted by the Office of Inspector General (OIG) of 

the U.S. Environmental Protection Agency (EPA). This report contains findings that describe the 

problems the OIG has identified and corrective actions the OIG recommends. This report represents 

the opinion of the OIG and does not necessarily represent the final EPA position. Final 

determinations on matters in this report will be made by EPA managers in accordance with 

established audit resolution procedures. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time plus travel costs – is $805,400. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this report 

within 90 calendar days. Your response will be posted on the OIG’s public Website, along with 

our comments on your response. Your response should be provided in an Adobe PDF file that 

complies with the accessibility requirements of section 508 of the Rehabilitation Act of 1973, as 

amended. If your response contains data that you do not want to be released to the public, you 
 

should identify the data for redaction. You should include a corrective actions plan for your 

actions, including milestone dates. We have no objections to the further release of this report to the 

public. This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Wade Najjum, 

Assistant Inspector General for Program Evaluation, at 202-566-0832 or najjum.wade@epa.gov; 

or Eric Lewis, Director, Special Reviews, Office of Program Evaluation, at 202-566-2664 or 

lewis.eric@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

EPA’s Revised Hiring Process Needs Additional Improvements 10-P-0177 

Table of Contents 

Chapters 

1 Introduction ....................................................................................................... 1 

Purpose ...................................................................................................... 1 

Background ................................................................................................ 1 

 Noteworthy Achievements........................................................................... 4 

 Scope and Methodology.............................................................................. 4 

2 Service Center Needs Identified But Not Implemented 

Before Transition................................................................................................ 6 

EPA Identified Key Factors for Successful Transition ................................. 6 

Technology Investment Was Not Successful .............................................. 6 

Service Centers Cannot Assess Performance Regarding 

Customer Service Standards.................................................................. 8 

Staffing Plan Was Not Adjusted .................................................................. 9 

Conclusion .................................................................................................. 9 

 Recommendations ..................................................................................... 10 

Agency Comments and OIG Evaluation ..................................................... 10 

3 Service Centers Not Meeting Expectations ..................................................... 12 

Service Centers Are Not Meeting Timeliness Goals ................................... 12 

Service Centers Have Not Consistently Provided Qualified Candidates..... 16 

Data Quality and Recruitment Action Processing Issues Noted.................. 17 

Conclusion .................................................................................................. 19 

 Recommendations ..................................................................................... 19 

Agency Comments and OIG Evaluation ..................................................... 20 

Status of Recommendations and Potential Monetary Benefits.............................. 22 

Appendices 

A Agency Response to Draft Report ................................................................... 24 

B Distribution ........................................................................................................ 31 
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Chapter 1

Introduction 

Purpose 

The U.S. Environmental Protection Agency (EPA) Office of Inspector General 

(OIG) reviewed EPA’s recently revised appointment process managed by its 

Office of Administration and Resources Management (OARM). Our objective 

was to determine how the new process for filling vacancies can be more efficient 

and effective. 

Background 

EPA’s goal is to have people with the right skills, in the right place, at the right 

time to protect human health and the environment. Under authority provided by 

the Office of Personnel Management (OPM), EPA is responsible for managing its 

personnel services, which includes appointing staff to vacant positions. In April 

2008, to improve the human resources function, EPA consolidated the services 

previously spread across 15 locations nationwide into 3 service centers. Each 

center is a Human Resources Management Division (HRMD) within OARM. 

The service centers are located in: 

• Research Triangle Park (RTP), North Carolina 

• Cincinnati, Ohio 

• Las Vegas, Nevada 

The first of EPA’s 23 major organizations to be serviced by one of the service 

centers transferred in June 2008. As of December 2009, all major organizations 

had transitioned to the service centers. Political and Senior Executive Service 

appointments are still processed by EPA’s Executive Resources Division in the 

OARM Office of Human Resources. 

Agencies Must Have Internal Controls 

Office of Management and Budget (OMB) Circular A-123, Management’s 

Responsibility for Internal Control, states that internal control is an integral 

component of an organization’s management, providing reasonable assurance that 

the following objectives are being achieved: effective and efficient operations, 

reliable financial reporting, and compliance with applicable laws and regulations. 

Management is responsible for developing and maintaining internal control 

activities that comply with the following standards: control environment, risk 

assessment, control activities, information and communications, and monitoring. 

The risk assessment standard states that management should identify internal and 

external risks that may prevent the organization from meeting its objectives. 

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EPA Policy and Guidance Address Reorganizations 

EPA Order 1110.8A5, EPA Reorganization Policy, requires OARM to provide 

centralized oversight of the reorganization process. Specific guidance is in the 

July 2003 Final Reorganization Toolkit. The toolkit includes guidance on issues 

ranging from how to plan a reorganization to evaluating the reorganization’s 

effectiveness. Neither the policy nor the toolkit addresses information system 

changes or a risk assessment as part of the process. 

Filling Vacancies Requires Collaboration 

Filling a vacant position is a three-phase collaborative process. The primary 

participants include the program office1

 with the vacant position, the service 

center responsible for processing the action (the HRMD), and the applicants. 

Other key participants include OARM’s Personnel Security Branch and those who 

provide new employee orientation. 

The three phases of the hiring process are summarized below. The process starts 

when the program office officially makes a request to fill a vacancy and approves 

the form requesting a personnel action. It ends on the date the employee begins 

work. According to OPM’s September 2008 end-to-end initiative, the goal for 

completing this process is 80 calendar days, or 58 work days. 

Initial Phase: This period is from when the program office decides to fill the 

vacancy to the close of the vacancy announcement. The OPM goal for this 

phase is 20 calendar days. 

Middle Phase: This period is from when the vacancy announcement closes 

to when the initial job offer is made. The OPM goal for completing this phase 

was 45 work days, but under the end-to-end initiative, it is 25 work days, or 

34 calendar days. 

Final Phase: This period is from when the initial job offer is made (and 

accepted) to the candidate entering on duty at EPA. The OPM goal for this 

phase is 26 calendar days. 

As shown in Figure 1-1, the HRMD directors each report to a different office 

director, all of whom report to the OARM Assistant Administrator. The director 

of the OARM Office of Human Resources is the national program manager for 

human resources but does not directly supervise the HRMDs in Cincinnati and 

RTP. 

1

 In this report, the term “program office” represents the organizations within EPA (program offices, regional 

offices, and the Office of Inspector General). 

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Figure 1-1: Reporting Chain for HRMDs 

Source: OIG analysis. 

As of December 2009, the three service centers were almost fully staffed. RTP 

had 2 vacancies (51 of 53), Las Vegas had 1 vacancy (22 of 23), and Cincinnati 

had 2 vacancies (31 of 33). 

OARM requires each service center to use the same standard operating 

procedures (SOPs). The first nine procedures were approved on June 30, 2008, 

and covered classifying positions and filling vacant positions using delegated 

examining or merit promotion announcements. 

The service centers use the Human Resources Activity and Communication 

Tracking System (HRACTS) to monitor the status of personnel actions. Directors 

also use the system to manage workload. The system was originally used only by 

the RTP HRMD to track the middle phase of the process; OARM has adapted it to 

provide information about all three phases. 

In July 2008, EPA established customer service standards for processing 

personnel actions. The standards, which are discussed in Chapter 2, included 

qualitative and quantitative (e.g., timeliness) standards and related goals for Fiscal 

Years 2009, 2010, and 2011. 

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OPM Wants Agencies to Use Certified Providers; EPA Is Uncertain 

What Services It Will Obtain 

OPM, at the direction of OMB, is managing a government-wide effort to improve 

service and reduce costs for information technology systems and supporting 

processes associated with human resources. Under this human resources line-ofbusiness, OPM certified selected Federal Government entities and private-sector 

companies to provide services to federal agencies. In July 2009, EPA completed 

a study of providers to update a previous June 2007 analysis of government 

providers and to also evaluate private-sector companies. When additional 

analysis is completed in July 2010, EPA will decide what services it will obtain 

from which line-of-business provider. EPA is uncertain when it will move to a 

line-of-business provider; the move may not occur for 2 years. 

Noteworthy Achievements 

Positive Impacts Resulting from EPA’s Transition to the Service Centers. 

OARM managers stated that before transitioning to the service centers, each of 

the 15 human resources offices could establish their own SOPs, resulting in little 

or no consistency in how work was accomplished. The three service centers have 

implemented 16 SOPs ranging from recruitment procedures to reassignments and 

leave-without-pay procedures, and more are being drafted. We believe that SOPs 

promote better performance. 

Human Resources Activity and Communication Tracking System. Although 

there are issues regarding the accuracy and completeness of data in HRACTS, 

OARM stated that it is the first EPA-wide system to track how long it takes to fill 

vacancies. OARM stated that previously, much of the information regarding 

recruitment timeliness was anecdotal. We believe an accurate tracking system 

will help provide reliable status information for process managers and customers. 

Scope and Methodology 

We conducted our audit work from August 2008 to May 2010. We conducted our 

work in accordance with generally accepted government auditing standards issued 

by the Comptroller General of the United States. Those standards require that we 

plan and perform the review to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our objectives. We 

believe the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our objectives. We assessed internal controls over the new 

hiring process used by the service centers. We did not review EPA’s previous 

practices. 

We interviewed EPA employees involved in the new process, including staff in 

selected program offices, the three service centers, and OARM, including the 

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Personnel Security Branch. We also interviewed the employees who were 

recently appointed to the positions in our sample. 

Our sample included initial actions that used the new procedures. The actions 

originated in the 10 EPA program offices that transitioned to a service center 

during 2008. We further limited our review to those appointment actions 

identified in HRACTS that used either delegated examining announcements 

(to recruit applicants who do not have federal status) or merit promotion 

announcements (to recruit applicants who have current or prior competitive 

federal status or special appointment eligibility). Our sampled actions were 

received at one of the three service centers between August 17 (or when the 

program office transitioned to the service center if it was later) and December 31, 

2008. Further, the service center must have made the initial job offer before 

January 16, 2009. In addition to talking to those involved in processing the 

actions, we reviewed the related case files kept by the service center and 

compared the steps performed to the applicable SOPs. The universe and sampled 

actions are summarized by service center in Table 1-1. 

Table 1-1: Recruitment Actions Started and Sampled, by Service Center 

Service Center Started Sampled 

Las Vegas 104 13 

RTP 133 9 

Cincinnati 38 6 

Total 275 28 

Source: Information on actions started came from HRACTS as of January 15, 2009. 

We adjusted the sample size to 28 due to inaccurate HRACTS information, discussed 

later in this report. 

Although our review did not directly address EPA’s actions regarding the human 

resources line-of-business, we do address the impact of not obtaining necessary 

information system upgrades on the appointment process. In addition, another 

recent OIG report also addressed information systems related to human resources: 

EPA’s Human Resources Management System Did Not Deliver Anticipated 

Efficiencies to the Shared Service Centers, Report No. 09-P-0206, issued 

August 11, 2009. 

5 
 

10-P-0177 

Chapter 2

Service Center Needs Identified 

But Not Implemented Before Transition 

EPA has not implemented critical technology upgrades or obtained other 

resources necessary for the service center concept to succeed. EPA produced 

three reports that identified key capabilities for a successful transition to the 

service center concept. However, EPA management implemented the 

reorganization without obtaining some of these key capabilities, including 

electronic infrastructure. Proceeding without ensuring that key requirements were 

satisfied is a significant management control weakness. As a result, the new 

process to fill vacant positions (i.e., the appointment process), which included 

EPA’s reorganizing to just three service centers, falls significantly short of OPM 

timeliness goals and does not consistently provide program managers with the 

best candidates. These effects are discussed in Chapter 3. 

EPA Identified Key Factors for Successful Transition 

EPA identified critical technology upgrades and resources for the service centers 

in three documents. Both the June 2007 document, Human Resources Line of 

Business Shared Service Center Analysis, and the 2008 reorganization plan 

contained important information pertinent to transitioning to service centers. 

However, the May 2007 report, Business Case Study: Shared Service Centers for 

Human Resources, identified “factors that are critical to the success of any 

consolidation.” It recommended two or three service centers, with each center 

providing identical transactional services to designated EPA offices. Among 

other factors necessary to improve the appointment process, the 2007 Business 

Case identified: 

• Investing in information technology infrastructure, 

• Developing and meeting customer service standards, and 

• Developing a realistic staffing plan. 

Technology Investment Was Not Successful 

EPA did not implement necessary information technology improvements before 

transitioning to the service centers and using the new processes. EPA’s toolkit 

does not require obtaining necessary information systems and performing a risk 

assessment before implementing reorganizations. According to the 2007 Business 

Case, to realize the efficiencies underpinning the service centers’ success, EPA 

would need to significantly upgrade its information technology infrastructure and 

human resource information systems. Necessary improvements included (1) an 

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automated Standard Form-52 feature, referred to as “workflow” in PeoplePlus, 

which is EPA’s integrated human resources, benefits, payroll, and time and labor 

system; (2) a system to track staffing actions; and (3) a system to develop and 

catalog position descriptions. 

•	 Electronic Workflow: The PeoplePlus workflow function was supposed 

to provide a paperless system with electronic signatures to process the 

Standard Form-52, which is the “Request for Personnel Action” used to 

initiate a recruitment action. It would eliminate some of the current 

manual, paper-intensive steps. Workflow was tested for some personnel 

actions, such as giving awards to employees, but failed. Consequently, 

OARM stopped efforts to implement the workflow function. OARM 

officials recently said they now intend to obtain the workflow 

functionality from a line-of-business provider. 

•	 Tracking System: Service centers use an electronic system, HRACTS, to 

track the status of recruitment actions. However, as discussed in more 

detail in Chapter 3, some HRACTS data are inaccurate or incomplete. 

HRACTS has no controls to ensure data quality. Also, HRACTS is not 

available to all program office staff; some program offices can use the 

system to view the status of recruitment actions on a pilot basis. 

•	 Electronic Position Description Library: EPA managers must prepare 

position descriptions that accurately reflect the major duties and 

responsibilities assigned to their employees. Currently, the position 

descriptions are paper based and kept in binders by program office. 

According to the service center directors, OARM hired summer students 

to convert paper position descriptions to an editable, electronic format to 

be stored in an EPA position description library that program offices can 

use when filling vacancies. The service centers selected position 

descriptions that met certain quality criteria to be converted to this 

electronic format. However, this effort does not satisfy the 2007 Business 

Case because the library does not also develop position descriptions. 

OARM abandoned some unsuccessful efforts and did not completely implement 

other necessary improvements. In a June 30, 2009, memorandum to EPA’s top 

managers, the then-Acting OARM Assistant Administrator acknowledged that 

EPA’s information technology efforts had been unsuccessful. OARM officials 

noted that electronic workflow capability would be one of the criteria for selecting 

a provider. EPA has not determined whether a tracking system and the electronic 

position description library will be part of its contracted services. 

OARM implemented the service centers without obtaining crucial information 

systems or performing a risk assessment as required by OMB Circular A-123. 

The circular requires documenting the risk of proceeding without first obtaining 

the systems. In the previously mentioned OIG Report No. 09-P-0206, we 

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concluded that EPA pursued updates to human resources systems without 

documented approval from OMB. EPA responded that it would no longer pursue 

any upgrades to its existing system but would acquire services from an OPMapproved line-of-business provider. 

Service Centers Cannot Assess Performance Regarding Customer 

Service Standards 

Some aspects of service centers’ work could not be measured when the centers 

began operating. According to the 2007 Business Case, developing customer 

service standards and performance metrics is one of the most important factors 

contributing to service centers’ success. To measure the service centers’ 

performance, a feedback mechanism is necessary to ensure customers receive 

timely, high-quality services. The toolkit states that EPA should develop 

evaluation criteria before implementing the reorganization and then evaluate the 

effectiveness of the reorganization. This evaluation is to include monitoring the 

implementation process, reviewing how well the new structure is performing, and 

using performance indicators to measure the effectiveness of the new design. 

Customer service standards for the service centers were developed in July 2008, 

but when the standards became effective in October 2008, there were no methods 

to measure some of the standards and thus determine whether the standards were 

met. As a result, program offices and service centers did not have information 

useful for improving the process. 

Some standards could not be measured in July 2008 because: 

•	 Service centers had not established customer feedback tools to determine 

whether the program offices were satisfied with their performance. 

•	 Service centers had no method to identify customer inquiries about actions 

being processed. 

•	 There was no method in place to measure how long it took to respond to 

customer inquiries. 

In July 2009, service centers began sending questionnaires to the program office 

staff about the actions they processed. As part of our review, we interviewed 

54 EPA program office staff members and 25 recently appointed staff associated 

with the sampled actions. Program office staff members were most dissatisfied 

with how long it took to fill a vacancy, the quality and timeliness of assistance 

from the service center during the evaluation process, and service center advice 

about how to best fill a vacancy. Some program office staff members were 

dissatisfied with their overall dealings with the service center staff. Recently 

appointed staff members were mostly dissatisfied with orientation activities, their 

overall dealings with the service center, and the service center’s level of effort to 

keep them informed. 

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The customer service standards established timeliness goals for service centers’ 

response to customer inquiries, but service center staff do not have information 

necessary to measure performance against that standard. In addition, as discussed 

elsewhere, HRACTS data is unreliable. Even though EPA’s toolkit recommends 

developing a plan to ensure the effectiveness of the reorganization, OARM has 

not done so. 

Staffing Plan Was Not Adjusted 

The staffing levels proposed for the service centers were neither adequately 

supported nor adjusted to reflect actual conditions. According to the toolkit, EPA 

can conduct benchmarking studies of comparable organizations, as well as a 

workforce assessment, to determine appropriate staffing and grade levels for the 

new organization. OARM managers said they could not benchmark other 

organizations because of the differences in the other organizations they reviewed. 

However, benchmarking studies, even though not of identical organizations, may 

have helped EPA identify proper staffing levels for service centers, streamline the 

new process, and provide criteria to evaluate the reorganization’s effectiveness. 

EPA could use benchmarking information in selecting a line-of-business provider 

by identifying the necessary services to obtain and those services EPA will still 

have to provide. 

For optimal performance of transactional work, the 2007 Business Case 

concluded that the ratio of service center staff to customers should be 1:180, or 

about 100 human resources staff for the approximately 18,000 EPA employees. 

However, the 2007 Business Case did not provide rationale or support for that 

number. This rationale should have been explained as part of the toolkit’s detail 

design process. EPA’s reorganization policy states that all pertinent comments 

must be resolved with the affected offices before the reorganization proposal can 

be approved. In a June 2007 joint memorandum to the OARM Assistant 

Administrator, the Deputy Chief of Staff and 10 Deputy Assistant Administrators 

questioned the support for the human resources servicing ratio. OARM 

responded that the ratio used was based on several key assumptions, including the 

implementation of electronic processing and a tracking system – both needed to 

improve timeliness. EPA had neither system before it implemented the service 

centers. Therefore, the comments about the staffing ratio from the Deputy Chief 

of Staff and 10 Deputy Assistant Administrators were not resolved prior to 

transitioning to the service centers. 

Conclusion 

OARM established a reorganization plan with an analysis based on assumptions 

and new capabilities. OARM did not reevaluate its reorganization plan when it 

became apparent the plan lacked the capabilities identified as critical to the 

success of the service centers. Consequently, OARM cannot provide assurance 

that the plan will succeed in meeting EPA and OPM hiring goals. 

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Recommendations 

We recommend that the Assistant Administrator for Administration and 

Resources Management, the Chief Financial Officer, and the Assistant 

Administrator for Environmental Information: 

2-1	 Determine the scope of services to be provided under a human 

resources line-of-business provider contract. Among the services 

considered should be an automated workflow process, a tracking 

system with responsive in-process metrics that will be provided to 

EPA, and a system to develop and catalog position descriptions. 

2-2	 Based on the above considerations, select a line-of-business provider 

and develop and implement a plan to migrate to the selected provider. 

We recommend that the Assistant Administrator for Administration and 

Resources Management: 

2-3	 Change EPA Order 1110.8A5, EPA Reorganization Policy, and the 

related toolkit to require that infrastructure requirements (including 

information systems) are considered and addressed, and risks are 

assessed in accordance with OMB Circular A-123 before 

implementing reorganizations. 

2-4	 As specified in the 2008 Customer Service Standards, design and 

implement methods to: 

(a) identify customer inquiries and how long it took to respond to 

those inquiries, and 

(b) measure performance toward establishing timeliness goals for 

service centers’ responses to customer inquiries. 

Agency Comments and OIG Evaluation 

In a memorandum dated June 11, 2010, the Deputy Assistant Administrator for 

Administration and Resources Management (signing for the Assistant 

Administrator) offered comments on the OIG draft report dated May 4, 2010. 

Appendix A is this memorandum. Regarding Chapter 2, the Deputy Assistant 

Administrator agreed with the two recommended actions related to the line-ofbusiness provider (2-1 and 2-2), but suggested different action officials instead of 

the Deputy Administrator. The Deputy Assistant Administrator stated they expect 

to select the line-of-business provider by September 30, 2010, and have the new 

systems implemented and operational by September 30, 2013. The Deputy 

Assistant Administrator also suggested different corrective actions for the other 

two recommendations. For example, regarding recommendation 2-3, the Deputy 

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Assistant Administrator proposed reviewing the order and changing it as 

appropriate; the Deputy Assistant Administrator did not address changing the 

related toolkit. Other corrective actions were also suggested at a meeting with 

OARM officials on June 24, 2010; regarding customer inquiries (2-4), they said 

they plan to revise the survey of service center customers to obtain customer 

feedback on the service centers’ timeliness in responding to inquiries. 

We changed the action officials for the first two recommendations (2-1 and 2-2). 

We did not revise recommendation 2-3, which was to change the guidance related 

to reorganizations. We believe the order and toolkit should be changed; until 

resolved, this recommendation is classified as undecided. Although we did not 

change recommendation 2-4, the proposed alternative of adding a related question 

to the customer survey is acceptable to the OIG; we believe it meets the intent of 

obtaining feedback on the timeliness of responses to inquiries. 

11 
 

 

 

 

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Chapter 3

Service Centers Not Meeting Expectations 

EPA’s service center implementation was not meeting organizational or customer 

expectations. EPA was taking an average of 141 days2 to fill vacant positions for 

the sample actions when the OPM goal was 80 days; thus, EPA exceeded the 

OPM timeliness goal by 61 days. In addition, service centers did not consistently 

provide program managers with the best candidates. Further, data quality and 

recruitment action processes need improvement. Some of these problems 

occurred due to the issues noted in Chapter 2. We also noted a lack of 

management attention to policies and inconsistencies in service center operations. 

As a result, the appointment process is not providing program offices with the 

right people, in the right place, at the right time, thus impacting EPA’s ability to 

effectively perform its mission. 

Service Centers Are Not Meeting Timeliness Goals 

EPA service centers did not have the necessary information technology and mix 

of knowledgeable human resources staff to hire people in a timely manner. Only 

1 of the 28 sampled actions was completed within OPM’s 80-day goal. Figure 

3-1 shows the average time spent in each phase for the three service centers. 

Overall, it took all three service centers an average of 141 days to fill the 

vacancies we sampled – 61 days in excess of the 80-day goal. The breakdown by 

service center was an average of 140 days for Cincinnati, 112 days for RTP, and 

162 days for Las Vegas. 

2

 For the purposes of this report, we have calculated calendar days as the days that pass between two given dates. 

By common practice, calendar days are measured from midnight to midnight. The formula for this calculation is 

[later date] – [earlier date]. With this approach, if two or more activities occur on a single day, the time between 

these activities does not count as a calendar day; thus a zero would be entered as the elapsed calendar days for this 

event. For example, if the classifier completes the classification on the same day he/she received it, this day would 

not count as a calendar day in the overall calculation of days expended during this hiring action. The net effect of 

this approach is that our calculations may understate the total number of days required to complete a given hiring 

action. 

12 
Figure 3-1 

Average Time Spent in 

Three Phases of Recruitment Process 

Cincinnati 

Initial Phase
 

Middle Phase
 RTP 

Final Phase
 

Las Vegas 

0 20 40 60 80 100 120 140 160 180 

Calendar Days 

Source: OIG analysis of sample items. 

10-P-0177 

In a memorandum dated June 30, 2009, the then-Acting OARM Assistant 

Administrator acknowledged that challenges remain in meeting the OPM 

timeframes. He went on to state that OARM is leading an ongoing collaborative 

effort among the three centers to identify and share best practices to increase the 

overall efficiencies to support performance. 

For the sampled actions in Figure 3-1, the initial phase of the recruitment process 

consumed most or all of the 80 days (an average of 115 days for Cincinnati, 

69 days for RTP, and 78 days for Las Vegas). We identified several factors that 

contributed to the lengthy staff appointment period, as follows. 

Position Classification Is Time Consuming 

EPA did not consistently use standard or previously classified position descriptions 

and conducted a full classification review even when using previously classified 

descriptions. It took the service centers an overall average of 12 days to classify 

the sampled actions. EPA’s goal is 2 days according to the SOP on position 

descriptions. OPM’s goal is 1 day, but assumes agencies are using automated 

systems and standard or previously classified position descriptions. A standard 

position description can be used to describe a number of positions and provides a 

single position description covering two or more positions within an organization 

that are substantially the same. 

EPA Order 3150.1, Position Classification, encourages using standard position 

descriptions. These standard position descriptions could be classified in advance. 

They may also have their risk designation determined in advance, which would 

eliminate the need for EPA’s Personnel Security Branch to review them. Service 

center directors agreed that using standard position descriptions saves time, but 

indicated that using previously classified position descriptions may not save time 

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because some previously classified position descriptions are out of date and 

require a thorough classification review. However, using position descriptions 

classified within the last 5 years would allow a specialist to perform an 

abbreviated review. 

Improved Mix and Training of Specialists Needed 

Staff for the centers was not as experienced as expected. The three service center 

locations were selected in part because OARM said it could attract experienced 

personnel at those locations. However, no analysis supported this assumption. 

The service center directors have found it difficult to hire experienced personnel 

and it will take time for the recently hired specialists to become fully productive. 

Some recently hired specialists needed additional training to perform certain 

duties. In a June 30, 2009, memorandum, the then-Acting OARM Assistant 

Administrator noted that the service centers have increased training. 

As noted, it took EPA an average of 12 days to classify a position. According to 

service center staff, knowledgeable specialists were not always available to 

promptly classify positions, and all three centers have supplemented their 

classification expertise with contractor resources. Las Vegas has two contract 

classifiers available to help with classifying; RTP and Cincinnati use the same 

contractor and have about $1.4 million available for contracted services. 

However, EPA still did not meet the EPA or OPM performance standards. 

Mix of Paper and Electronic Documents Can Lead to Delays, Errors 

EPA has not obtained the electronic workflow capability it identified as necessary 

for successful implementation of the service center model. Consequently, it 

continues to fill vacancies using a mixture of electronic systems and manual, paperintensive steps. Each shift between paper and electronic steps increases the 

likelihood of a delay and the opportunity for error. For example, one subjectmatter expert noted a page on qualification questions was missing, and several 

e-mail exchanges were needed over a 27-day period to resolve all the problems. In 

another instance, a recently hired person indicated her transcripts were initially lost 

and the person had to FedEx another copy, which the person believed delayed her 

entry on duty by about 3 weeks. Although a version of EZ-Hire can handle 

electronic transcripts, EPA’s version cannot. Table 3-1 identifies the many 

documents in the recruitment process that are mailed, faxed, or e-mailed to the 

service centers and must be integrated into the electronic-based parts of the system. 

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Table 3-1: Nonelectronic Portions of Recruitment Process 

Initial Phase 

• Recruitment documents from the program office (including signed documents such 

as the SF-52, position description, extramural resources management duties 

checklist, staffing requisition, travel determination forms, and justification for term 

position) are sent to the service center by mail or FedEx. 

• The Job Analysis Report, prepared by the specialist and subject-matter expert, 

must be printed and signed by both individuals. This report identifies questions for 

the announcement selected by the expert from the EZ-Hire question library, but the 

expert cannot electronically transfer the questions to the announcement. 

• The Weights and Screenout Report that is generated by EZ-Hire must be printed 

and signed by the program expert. 

• The vacancy announcement that is generated by EZ-Hire must be printed and 

signed by someone in the program office. 

Middle Phase 

• Paper copies of applicants’ supplemental documentation, such as proof of military 

service and college transcripts, must be mailed, e-mailed, or faxed to the service 

center and filed. 

Final Phase 

• Documents such as the OF-306, Declaration for Federal Employment, must be 

signed by the selected candidate and sent to the service center. 

• During orientation, some documents must be signed by the new employee and 

sent to the service center, such as the Form I-9 Employment Eligibility Verification. 

Source: SOPs and participant interviews. 

EPA should be able to fill vacancies quicker and accurately by obtaining an 

electronic workflow process such as that identified in the 2007 Business Case. 

EPA intends to make electronic workflow a criterion for selecting a line-ofbusiness provider. 

EZ-Hire Question Library Difficult to Use 

Subject-matter experts select questions from EPA’s EZ-Hire electronic question 

library to develop vacancy announcements. OARM maintains the library, which 

contains approximately 38,000 questions. For over 50 percent (15 of 28) of the 

sampled actions, either the selecting official or subject-matter expert interviewed 

was dissatisfied with the usability and quality of the library. Specialists needed 

help from subject-matter experts to (1) analyze the job, (2) select appropriate 

questions, and (3) determine the relative importance of the questions. Subjectmatter experts and selecting officials told us that the library questions were poorly 

organized, searching for questions was difficult, questions were duplicated, and 

some questions had spelling and grammar errors. As a result, those not familiar 

with the library need more time to select questions; one subject-matter expert 

using the library for the first time reported spending about 40 hours doing so. 

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Service Centers Have Not Consistently Provided Qualified Candidates 

An important part of the appointment process is providing program offices with a 

list of the most qualified candidates, but the service centers did not consistently 

provide the desired quantity and quality of candidates. For three of the nine 

delegated examining actions sampled, the selecting official and/or subject-matter 

expert from the program office reported not receiving certificates with qualified 

candidates. We noted the following issues. 

Policy Unnecessarily Limits Choices 

For delegated examining announcements, the SOP unnecessarily limits the list of 

names sent to the selecting official. The SOP provides that the certificate will 

consist of the top three candidates if there is one vacancy, plus one additional 

candidate for each additional vacancy. According to the service center directors, 

the list was limited because Title 5 Code of Federal Regulations 332.404 requires 

selecting officials to select from the three highest-ranked candidates. The 

regulations state that an appointing officer will select someone “from the highest 

three eligibles on the certificate who are available for appointment.” This is 

commonly known as the “rule of three.” 

Some program offices were not satisfied with receiving only three candidates. 

Title 5 Code of Federal Regulations 332.402 provides that selecting officials will 

receive sufficient names, when available, to allow them to consider at least three 

candidates for each vacancy (emphasis added). Therefore, three is the minimum 

for the certificate, not the maximum. Selecting officials may object to a candidate 

to reach another applicant if they believe one of the top three candidates is not 

qualified or there are suitability issues. However, objecting can be time 

consuming and involve an OPM review. Until the objection is resolved, the 

selecting official cannot pick anyone else. The program office can also cancel the 

announcement and readvertise the position, which also requires significant time. 

EPA Should Use Category Rating to Identify Best Candidates 

For competitive appointments from delegated examining announcements, category 

rating is an alternate process to the rule of three that can provide additional qualified 

candidates for consideration. Instead of using numerical scores, a category-based 

method assesses, rates, and ranks applicants, taking into account veterans preference. 

The selecting official may pick any of the candidates in the highest quality category. 

Category rating may be used for merit promotion announcements. 

According to OPM’s Delegated Examining Operations Handbook, agencies wishing 

to use category rating must have a policy to do so. EPA has had a draft category 

rating policy since 2007 and has recently taken steps to issue it. The Human 

Resources Policy Division director said that the policy was not a priority, and if it 

became a priority, it would take about 2 years to issue due to staff shortages. This 

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director noted that issuing the policy would take that long because they would have 

to research the issue, obtain input from stakeholders, ensure related systems can 

incorporate the categories, usher the proposal through the clearance process, and 

train users. The draft policy has already been tested against EZ-Hire to ensure that 

system could incorporate the categories. Using category rating should be 

reconsidered. 

Subject-Matter Experts Should Perform More Initial Reviews 

Service center specialists do not typically request help from subject-matter experts 

in program offices when evaluating applicants. Early input by subject-matter 

experts would improve the quality of the candidates, although it would require 

more effort by the expert. SOPs provide that specialists may involve subjectmatter experts in reviewing applications. According to OMB in Memo M-09-20, 

issued June 11, 2009, involving the hiring managers in all critical parts of the 

hiring process, including the initial review of applications, is necessary to 

improve the hiring process. In EPA’s case, SOPs should state that program 

offices should determine who performs the initial reviews, subject-matter experts 

or specialists. This determination would help ensure that quality candidates are 

selected because, for certain positions, specialists may not have the expertise to 

evaluate applicants’ qualifications. We noted instances in which the selecting 

offices were not satisfied with initial names provided, and earlier involvement by 

the subject-matter experts could have prevented that from occurring. 

Data Quality and Recruitment Action Processing Issues Noted 

HRACTS, the database used to track recruitment actions, had inaccurate and 

incomplete entries for most of the actions we reviewed. In addition, we noted 

various other processing issues. These issues made it more difficult to accurately 

track the status of recruitment actions and caused confusion for new employees. 

HRACTS Database Contains Errors and Is Incomplete 

Information in the HRACTS tracking system was not always accurate and 

complete. HRACTS provides workload and performance information to the 

service centers and program offices. Each specialist adds information to the 

system and has authority to edit existing data. HRACTS mostly consists of 

activity dates related to processing recruitment actions, such as when the service 

center received the recruitment package and the effective date when the selected 

candidate reported for duty. EPA uses these dates in HRACTS to generate reports 

on the 80-day goal for OPM. The HRACTS database generates monthly status 

reports that the service centers send to program offices. Some program offices are 

also given access to view HRACTS data on a test basis. 

At the time of our review, there was no method to ensure the accuracy or 

completeness of the HRACTS data. According to EPA procedures on the life 

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cycle of information systems (System Life Cycle Management Procedures, OEI 

2121-P-01.0), data must be continually checked for accuracy and completeness. 

If HRACTS does not contain accurate and complete data, including an entry for 

each action, information from HRACTS will be unreliable. We noted the 

following problems with the quality of the data: 

•	 Not every action had a record in HRACTS. Two actions in our sample did 

not have a separate record in the system; one of these was combined with 

another action in a single record, and the other had no record at all. 

•	 Some fields that should contain information were blank. For 23 fields 

within the 27 HRACTS records for the sampled actions, 7 records were 

complete and 20 records were missing information in one or more fields. 

•	 Data in the fields were not always accurate. Of the 27 sampled actions 

with a HRACTS record, comparison of the case file to the HRACTS 

record indicated that 5 records had accurate information and 22 records 

contained incorrect information in one or more fields. 

Inaccurate and incomplete HRACTS data will adversely affect the quality of 

timeliness measures and managers’ decisions on workload and processing. Of the 

27 sampled actions with information in HRACTS, the data needed to measure the 

80-day goal were incomplete for 8 actions. For the 19 actions with the necessary 

HRACTS data, the dates in HRACTS indicated processing the actions took an 

average of 132 days, while our comparison against case file documentation 

showed it actually took 141 days. Fixing HRACTS deficiencies in the short term 

and determining whether to replace HRACTS with another tracking system in the 

long term would improve the documentation of management decisions on 

workload and processing. 

Service Center Processing Issues Noted 

Service centers did not follow all SOPs to ensure consistent and efficient operations 

among the three centers. We noted the following: 

Erroneous/Missing Offer Letters. Nearly half of the recently appointed 

employees in our sample indicated they did not receive a formal offer letter or the 

letter they received was incorrect. According to SOPs, service centers are 

required to send formal job offer letters to selected candidates once their entrance 

dates have been established. Of the 25 recently appointed employees interviewed, 

8 whose appointments were processed by RTP or Cincinnati said they did not 

receive a formal offer letter, while 3 processed by Las Vegas reported receiving 

letters with inaccuracies, such as errors in pay grade or steps. 

Center Did Not Use Case File Checklist. For the actions in our sample, staff at 

Las Vegas did not use a case file checklist as required by SOPs. SOPs require a 

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checklist to ensure that the case file contains the appropriate documents and to 

document that certain activities in the process were performed. The Las Vegas 

director told us that the service center began using checklists in March 2009. 

Procedures Do Not Address the Role of the Personnel Security Branch. 

Although not identified in SOPs, the Personnel Security Branch, which is part of 

OARM, determines the risk level of positions to be filled and is responsible for 

security clearances. Both the service centers and the Personnel Security Branch 

track when SF-52 documentation is submitted and/or released to one another. The 

Personnel Security Branch uses a system that automatically enters dates; the service 

centers enter information manually. We found date discrepancies between the two 

systems, which adversely affect analysis of timeliness. 

Center Does Not Allow Staff to Develop Expertise with Program Offices. 

Unlike the RTP and Cincinnati service centers, where staff consistently work on 

recruitment actions for a specific program office, the Las Vegas center assigns staff 

to work on recruitment actions on a first-in, first-out basis. Working consistently 

with the same program office would allow a specialist to gain expertise in the type 

of positions used by that office and be better able to evaluate applicants for those 

positions. It would also improve communication, which some program office staff 

identified as a problem with Las Vegas. Knowing the point of contact for 

recruitment actions reduces confusion and facilitates question resolution. 

Conclusion 

OARM implemented and operated the service centers without all the necessary 

tools needed to succeed and could not reach OPM’s 80-day timeliness goal. 

Procedural and policy changes, along with information systems improvements, 

are needed to assure efficient operation of the appointment process by the service 

centers in the near term, and by the line-of-business provider when selected. 

Recommendations 

We recommend that the Assistant Administrator for Administration and 

Resources Management: 

3-1	 Help the Assistant Administrators and Regional Administrators 

develop and use standard position descriptions where practicable. 

These position descriptions should be included in the electronic 

position description library and made available to all offices. 

3-2	 Work with the Assistant Administrators and Regional Administrators 

to review questions in the EZ-Hire question library and, if needed, 

correct erroneous or out-of-date questions. 

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3-3	 Increase the involvement of the subject-matter experts in reviewing 

applications to determine who should be on the candidate list sent to 

the selecting official. 

3-4 Address staffing, policy, and procedural needs for processing 

appointment actions until EPA migrates to a line-of-business provider. 

Specifically: 

(a) Ensure there are sufficient, qualified personnel to operate the 

service centers; 

(b) Expeditiously issue the category rating policy; 

(c) Establish standard operating procedures to address (1) how 

recruitment actions are assigned to specialists, (2) the role of the 

Personnel Security Branch, and (3) how improvements suggested 

by feedback from the program office staff will be addressed; 

(d) Ensure that the service centers follow the standard operating 

procedures; and 

(e) Establish sufficient internal controls on data quality to ensure the 

Human Resources Activity and Communication Tracking System 

information is complete and accurate. 

Agency Comments and OIG Evaluation 

With two exceptions, in the memorandum dated June 11, 2010, the Deputy 

Assistant Administrator for Administration and Resources Management agreed 

with the recommendations in Chapter 3. However, the Deputy Assistant 

Administrator suggested a different action official for the first three 

recommendations (3-1, 3-2, and 3-3). In several cases, the Deputy Assistant 

Administrator identified actions already taken to correct the problems identified. 

For example, regarding recommendation 3-1, a workgroup that included staff 

from the RTP HRMD and a program office were developing standard position 

descriptions. The two exceptions concerned changes to SOPs under 

recommendation 3-4(c). Regarding how recruitment actions would be assigned to 

specialists (3-4(c)(1)), the Deputy Assistant Administrator disagreed. The Deputy 

Assistant Administrator’s comments indicated managers would assign work based 

on timeliness and quality of delivered services. Regarding improvements 

suggested by the program offices (3-4(c)(3)), the Deputy Assistant Administrator 

did not commit to incorporating into the SOP how suggested improvements 

would be addressed. 

As suggested, we changed the action official for the first three recommendations 

and revised recommendations 3-1 and 3-2 slightly to accommodate the change. 

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The effort described by the Deputy Assistant Administrator to standardize 

position descriptions is acceptable to the OIG if the Assistant Administrator 

approves and implements a plan to standardize position descriptions and makes 

the standard position descriptions available to all. Similarly, the actions proposed 

to improve the EZ-Hire Library are acceptable if the program offices are properly 

involved. Recommendations resolved by completed actions are identified in the 

Status of Recommendations and Potential Monetary Benefits table that follows, 

and need not be addressed in the 90-day reply. Regarding the two changes to 

SOPs with which the Deputy Assistant Administrator either disagreed or did not 

endorse, we believe in both cases that the SOPs should be revised to ensure 

consistency in operating the service centers. Until resolved, these items are 

classified as undecided. 

21 
 

 

 

 

 

 

 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 

2-2 

10 

10 

Determine the scope of services to be provided 

under a human resources line-of-business provider 

contract. Among the services considered should 

be an automated workflow process, a tracking 

system with responsive in-process metrics that will 

be provided to EPA, and a system to develop and 

catalog position descriptions. 

Based on the above considerations, select a lineof-business provider and develop and implement a 

plan to migrate to the selected provider. 

O 

O 

Assistant Administrator for 

Administration and 

Resources Management, 

Chief Financial Officer, and 

Assistant Administrator for 

Environmental Information 

Assistant Administrator for 

Administration and 

Resources Management, 

Chief Financial Officer, and 

Assistant Administrator for 

Environmental Information 

9/30/2010 

9/30/2013 

2-3 

2-4 

3-1 

10 

10 

19 

Change EPA Order 1110.8A5, EPA Reorganization 

Policy, and the related toolkit to require that 

infrastructure requirements (including information 

systems) are considered and addressed, and risks 

are assessed in accordance with OMB Circular 

A-123 before implementing reorganizations. 

As specified in the 2008 Customer Service 

Standards, design and implement methods to: 

(a) identify customer inquiries and how long it 

took to respond to those inquiries, and 

(b) measure performance toward establishing 

timeliness goals for service centers’ 

responses to customer inquiries. 

Help the Assistant Administrators and Regional 

Administrators develop and use standard position 

descriptions where practicable. These position 

descriptions should be included in the electronic 

position description library and made available to 

all offices. 

U 

O 

O 

Assistant Administrator for 

Administration and 

Resources Management 

Assistant Administrator for 

Administration and 

Resources Management 

Assistant Administrator for 

Administration and 

Resources Management 

3-2 

3-3 

19 

20 

Work with the Assistant Administrators and 

Regional Administrators to review questions in the 

EZ-Hire question library and, if needed, correct 

erroneous or out-of-date questions. 

Increase the involvement of the subject-matter 

experts in reviewing applications to determine who 

should be on the candidate list sent to the selecting 

official. 

O 

O 

Assistant Administrator for 

Administration and 

Resources Management 

Assistant Administrator for 

Administration and 

Resources Management 

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Rec. 

No. 

3-4 

Page 

No.

20 

RECOMMENDATIONS 

 Subject Status1 

Addresses staffing, policy, and procedural needs 

for processing appointment actions until EPA 

migrates to a line-of-business provider. 

Specifically: 

(a) Ensure there are sufficient, qualified 

personnel to operate the service centers; 

C 

(b) Expeditiously issue the category rating 

policy; 

C 

(c) Establish standard operating procedures 

to address (1) how recruitment actions are 

assigned to specialists, (2) the role of the 

Personnel Security Branch, and (3) how 

improvements suggested by feedback 

from the program office staff will be 

addressed; 

U 

(d) Ensure that the service centers follow the 

standard operating procedures; and 

C 

(e) Establish sufficient internal controls on 

data quality to ensure the Human 

Resources Activity and Communication 

Tracking System information is complete 

and accurate. 

C 

Action Official 

Assistant Administrator of 

Administration and 

Resources Management 

Planned 

Completion 

Date 

POTENTIAL MONETARY 

BENEFITS (in $000s) 

Claimed 

Amount 

Agreed To 

Amount 

1 O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

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Appendix A 

Agency Response to Draft Report 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

ADMINISTRATION
 

AND RESOURCES 

MANAGEMENT
 

JUNE 11, 2010 

MEMORANDUM 

SUBJECT: Response to Draft Office of Inspector General Report “EPA’s Revised Hiring 

Process Needs Additional Improvements” Project No. OPE- FY08-0015 

FROM: Craig E. Hooks /s/ Susan B. Hazen for CEH

 Assistant Administrator 

TO: Eric Lewis 

Special Review Product Line Director 

Office of Inspector General 

Thank you for the opportunity to review the subject report and provide you with our 

comments. As the National Program Manager (NPM) for Human Resources, I am the 

appropriate action official for addressing the findings and recommendations in the report. In 

general, I look forward to sharing additional information with your office to document the steps 

we have taken towards achieving the goals reflected in the recommended actions. This is due in 

no small part to the continued efforts of staff in the Shared Service Centers (SSCs) and in the 

Office of Human Resources. That information is included as an attachment to this 

memorandum. By way of clarification, we would like to offer the following observations for 

your consideration: 

In the introduction section of the report, under the heading titled “OPM Wants Agencies 

to Use Certified Providers; EPA is Uncertain What Services It Will Obtain,” the report 

acknowledges that “OPM, at the direction of OMB, is managing a government-wide effort to 

improve service and reduce costs for information technology systems and supporting processes 

associated with human resources.” We wish to point out that: 

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•	 OMB’s decision to have OPM manage this government-wide effort included a 

moratorium on any additional investments by Agencies in information technology 

systems; and 

•	 EPA was in the final planning stages for our migration to the shared service center model 

at that point in time. 

We believe that the decision to move to SSCs was appropriate. This transition better 

positions the Agency to improve human resources customer service on several fronts, 

specifically achieving greater efficiency in the hiring process. 

In closing, I would again like to offer my appreciation for the opportunity to comment on 

the draft report. We will email this memo and our responses to the proposed recommendations 

to Christine Baughman as requested. If you or your staff have any additional questions, please 

contact Kimberly Lewis, Director, Office of Human Resources at (202) 564-4606, or Marvin 

Schulman at (202) 564-7778. 

Attachment 

cc: Susan Hazen 

 Sandy Womack 

 Sherry Kaschak 

 Kimberly Lewis 

 Susan Kantrowitz 

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Attachment 

Below is the OARM response to the recommendations in the draft evaluation report “EPA’s 

Revised Hiring Process Needs Additional Improvements” Project No OPE-FY08-0015, issued by 

the Office of the Inspector General on May 4, 2010. 

Recommendations 

We recommend that the EPA Deputy Administrator: 

2-1 Determine the scope of services to be provided under a human resources line-ofbusiness provider contract. Among the services considered should be an automated 

workflow process, a tracking system with responsive in-process metrics that will be 

provided to EPA, and a system to develop and catalog position descriptions. 

While we are in agreement with the substance of the recommendation, we believe that the 

Assistant Administrator (AA) for OARM is the appropriate action official for determining the 

scope of services to be included in our human resources line-of-business (HR LoB) system. 

“Workflow” is not only important for the electronic routing of various HR documents, but is also 

necessary for an effective tracking system where information is in the hands of the requesting 

office at any time. The ability to provide this information is very important to the selection of an 

HR LoB provider. We agree with the report’s recommendation for including a system to 

develop and catalog position descriptions (a PD library). The system we have been exploring 

has these capabilities. 

2-2	 Based on the above considerations select a line-of-business provider and develop 

and implement a plan to migrate to the selected provider. 

Staffs from the Office of the Chief Financial Officer, Office of Human Resources, and 

human resources representatives from the regions and shared service centers have been involved 

in fit-gap exercises to examine the functionality of a potential replacement for our current 

Peoplesoft and DFAS systems. This is a critical step to ensuring that the Agency’s system needs 

can be met, in order to make a recommendation to senior management that is in EPA’s best 

interests. 

A presentation on the HR LoB provider currently under consideration was made to 

members of the Assistant Regional Administrator (ARA) community and other Agency leaders 

in late May, 2010. The purpose of the presentation was to explain the progress to date in 

conducting the fit-gap analyses to identify any potential technical system logistics, gather 

feedback on any system needs or concerns the ARAs may have had, and to gain their support for 

this effort. 

An implementation plan, mapping out the steps that need to be taken from the point of 

selection to the point that the system is operational has been drafted. It projects having a new 

line-of-business system implemented and operational in FY2013 provided the AA for OARM 

and the Chief Financial Officer reach a final decision on a line-of-business provider by the end of 

FY2010. 

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We recommend that the Assistant Administrator for Administration and Resources 

Management: 

2-3 Change EPA Order 1110.8A5, EPA Reorganization Policy, and the related Toolkit, 

to require that infrastructure requirements (including information systems) are 

considered and addressed, and risks are assessed in accordance with OMB Circular 

A-123 before implementing reorganizations. 

We will review the Order and make any changes as appropriate. 

2-4 As specified in the 2008 Customer Service Standards, design and implement 

methods to 

(a) identify customer inquiries and how long it took to respond to those inquiries, 

and 

(b) measure performance toward established timeliness goals for service centers’ 

responses to customer inquiries. 

The 2008 Customer Service Standards were developed at the outset of our migration to 

the shared service center model. Based on our experience and additional analysis, we believe it 

is not practical or feasible to track customer inquiries. We are currently analyzing the 

practicality of this requirement. 

The data in the Human Resources Activity and Communication Tracking System 

(HRACTS) is better and more accurate than was the case when representatives from OIG looked 

at the system during the early phases of their evaluation. Program offices now have direct 

access to the HRACTS system, alleviating the need to make inquiries 

Recommendations 

We recommend that the Deputy Administrator direct the Assistant and Regional 

Administrators to: 

3-1 Develop and use standard position descriptions where practicable. These position 

descriptions should be included in the electronic position description library and 

made available to all offices. 

An effort to develop standard position descriptions (PDs) has already begun. A 

workgroup composed of Staff from the RTP Shared Service Center and representatives from the 

Philadelphia Regional Office has been assembled to “kick-start the effort and develop a 

proposed work plan” to develop standard PDs. The workgroup made an initial presentation to 

the ARAs, the Regional Human Resources Officers and the Headquarters Program Management 

Officers at a conference in May. The workgroup showcased a sample of a standard PD they 

drafted for an interdisciplinary Remedial Project Manager, GS-401/819/1301-13, along with a 

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sample vacancy announcement and job analysis record. The workgroup has established a plan 

that calls for standardized PDs to be developed for the top ten most frequent positions by the end 

of the fourth quarter of FY 10. Under this approach, the workgroup plans to standardize 

approximately 15 positions every quarter, and post them on the SSC website for supervisors and 

managers to access. 

3-2	 Review questions in the EZ-Hire question library associated with their office and, if 

needed, recommend that the Assistant Administrator for Administration and 

Resources Management correct erroneous or out-of-date questions. 

Staff in the Office of Human Resources’ IT Division (ITD) have made a number of 

improvements to the EZHire question library, including correcting or eliminating erroneous or 

out-of-date questions. There have been a number of drivers behind this effort. In April of this 

year, EPA transitioned to an upgraded version of the Monster Government Solutions (MGS) 

hiring software that EPA calls “EZHire.” As part of that effort the ITD staff reviewed and 

eliminated all inactive questions and questions designed for interdisciplinary positions. They 

also eliminated spelling, punctuation or grammatical errors in the remaining questions. The staff 

is part of a workgroup comprised of representatives from across the Federal government who use 

the MGS Enterprise Hiring Management System. The purpose of the workgroup is to identify 

best practices, and to share ideas and make recommendations on current/future system 

enhancements to improve the hiring process. 

3-3 Increase the involvement of the subject matter experts in reviewing applications to 

determine who should be on the candidate list sent to the selecting official. 

We agree that additional involvement from subject matter experts (SMEs) can have an 

impact on the quality of the certificates of eligibles sent to selecting officials. We recognize that 

their involvement in the selection and weighting of EZHire questions when developing the job 

analysis is also critical. We will review the standard operating procedures (SOPs) and look for 

opportunities to increase their involvement. 

We recommend that the Assistant Administrator for Administration and Resources 

Management: 

3-4 Addresses staffing, policy, and procedural needs for processing appointment actions 

until EPA migrates to a line-of-business provider. Specifically: 

• Ensure there are sufficient, qualified personnel to operate the service centers; 

We agree with this recommendation and have taken steps to ensure that all of the SSCs 

are currently at their allocated FTE ceilings. The SSCs have developed an internal training 

curriculum for those employees hired into trainee positions, use on-the-job training 

opportunities, and have also assigned staff to serve in a quality assurance capacity. As a result of 

these efforts, this recommendation has already been implemented and completed. 

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• Expeditiously issue the category rating policy; 

The Office of Human Resources has finalized the Agency guidance on category rating, 

and is in the process of developing a roll-out strategy to train (1) the HR specialists on how to 

effectively use the category rating process; and (2) selecting officials. This step is critical to 

ensuring that supervisors understand how category rating process is different from the “rule of 

three” under the Delegated Examining authority, or the process used under our merit promotion 

plan. We anticipate implementing this new rating process before November 1, 2010, as 

mandated by OPM. 

• Establish standard operating procedures to address 

(1) how recruitment actions are assigned to specialists; 

Our SSC customer service standards are focused on timely and quality delivery of our 

services. Managers take this into account when making work assignments. 

(2) the role of the Personnel Security Branch; and 

The role of the Personnel Security Branch (PSB) in the screening of position descriptions 

was the result of an effort to standardize the processes by which risk designation levels were 

assigned to positions and the manner in which such suitability determinations were made. This 

is similar to the changes experienced by the various Regional offices as a result of migrating to a 

SSC. We will review the SOPs to determine the proper placement of PSB’s role. 

(3) how improvements suggested by feedback from the program office 

staff will be addressed. 

We use customer service visits and survey data as valuable tools to guide our 

improvements. 

• Ensure that the service centers follow the standard operating procedures; and 

The Office of Administration and Resources Management has three primary mechanisms 

in place to ensure that the SSCs are following their standard operating procedures. The first of 

these is the Agency’s HR assessment program which is managed by the Human Capital 

Accountability Branch within the Office of Human Resources. Under this program, an 

assessment team conducts a transactional audit of the work performed by the shared service 

centers. The team reviews transactional work conducted by the SSCs for regulatory compliance 

as well as compliance with the Agency policies and SOPs. Representatives from the Office of 

Personnel Management typically accompany assessment team members on these assessments, 

and copies of the final report are sent to OPM as well as the Office of the Inspector General, as 

part of this process. The first assessment of an SSC was conducted during the last quarter of FY 

2009. FY 2010 is the first year in which all three SSCs will be visited by the assessment team. 

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The second mechanism for ensuring consistency involves discussion of such issues 

(when they occur) as a regular part of the HR SSC Executive Meetings. These meetings are held 

quarterly and chaired by OARM’s Principal Deputy Assistant Administrator. 

Third, OARM created and filled an “HR Liaison” position during the last quarter of FY 

2009 to serve as a high-level point of contact and interface between the SSCs and their regional 

and headquarters clients. The Liaison is an active participant on the SSC’s SOP workgroup, 

coordinates SSC issues with other parts of OHR, and participates in the SSC Executive 

Meetings. Creating this position also provided another avenue for representatives from the 

regions or AAships to ask questions or raise concerns, including those involving consistent 

application of the SOPs. 

•	 Establish sufficient internal controls on data quality to ensure the Human Resources 

Activity and Communication Tracking System (HRACTS) information is complete 

and accurate. 

While the SSC Branch Chiefs and team leaders have made additional efforts to ensure 

that the information in the system is complete and accurate, additional challenges to keeping the 

system up-to-date remain. The SSCs have included metrics for updating the system in the 

performance standards for their HR Specialists and HR Assistants, and will use that information 

as part of the performance assessment process. 

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Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Administration and Resources Management 

Assistant Administrator for Environmental Information and Chief Information Officer 

Chief Financial Officer 

Agency Audit Follow-up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Audit Follow-up Coordinator, Office of Administration and Resources Management 

Audit Follow-up Coordinator, Office of Environmental Information 

Audit Follow-up Coordinator, Chief Financial Officer 

Inspector General 

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