United States Government Accountability Office

GAO Testimony 

Before Congressional Subcommittees

UNITED STATES 

GOVERNMENT 

ACCOUNTABILITY OFFICE

Status of GAO’s 

Human Capital 

Transformation Efforts 

Statement of David M. Walker, 

Comptroller General of the United States 

For Release on Delivery

Expected at 10:00 a.m. EDT 

Tuesday, May 22, 2007

 

GAO-07-872T 
How GAO Assists the Congress

United States Government Accountability Office

Why GAO Prepared This 

Statement

Highlights

Accountability Integrity Reliability

May 22, 2007

UNITED STATES GOVERNMENT

ACCOUNTABILITY OFFICE 

Status of GAO’s Human Capital 

Transformation Efforts

Highlights of GAO-07-872T, a testimony 

before Congressional Subcommittees 

GAO seeks to assist the Congress in improving the economy, efficiency, 

effectiveness, ethics, and equity within the federal government. The 

Comptroller General considers these important principles in connection 

with all of his decision making relating to GAO. Furthermore, because 

GAO audits, investigates, and evaluates others, it seeks to “lead by 

example” in every major management area, including the human capital 

area. GAO fully appreciates that it is not perfect and never will be, but it 

strives to do what is right and to continuously improve. 

While GAO’s transformational human capital changes have required 

some difficult adjustments, they, along with other key reforms, have 

helped GAO to achieve record results for the Congress. Furthermore, 

GAO has continued to achieve very positive results with its key people 

measures. For example, on the basis of the results of GAO’s latest 

employee feedback survey, which was conducted after its classification 

and compensation changes and Band II restructuring effort, GAO was 

ranked number 2 among large federal employers in the most recent “Best 

Places to Work in the Federal Government” rankings. 

GAO is possibly the first major agency to implement broad banding, 

market-based pay, and skills-, knowledge-, and performance-oriented pay 

systems on an agencywide basis. This is a major accomplishment, and 

GAO’s reforms have been the subject of many positive case studies and 

articles by various external parties on how to achieve tough 

transformation changes within the federal government. 

Nonetheless, the Comptroller General regrets that there were certain 

expectation and communication gaps that occurred in connection with 

GAO’s initial implementation of market-based pay ranges and related 

across-the-board pay adjustments in 2006. GAO has, however, taken 

numerous steps to address this matter over the past year so that any such

gaps should no longer exist. Furthermore, the Comptroller General 

believes that all of GAO’s actions have been fully consistent with the law 

and principles of economy, efficiency, effectiveness, ethics, and equity. 

GAO has taken steps in the past year to provide additional opportunities 

for pay increases to many employees. In addition, GAO will soon submit 

legislation that will seek to enhance the pay and pension provisions 

applicable to its employees. 

The subcommittees asked the 

Comptroller General of the United

States to discuss recent human

capital reform efforts at the U.S. 

Government Accountability Office

(GAO). In 2004, GAO conducted its 

first ever market-based

compensation study after laying the 

necessary foundation by

implementing a modern,

competency-based performance

management system. GAO hired a

top compensation consulting firm 

on a competitive basis to conduct a 

market-based pay study using 

generally accepted approaches and 

based on independent and 

professional judgment. As a result 

of the study, the 2006 pay ranges

for about 25 percent of GAO’s 

employees were raised and about 

10 percent of GAO’s employees 

were determined to be paid above 

market levels based on their roles,

responsibilities, and/or relative

performance. No GAO employee

has had his or her pay cut as a 

result of GAO’s classification and 

compensation changes. Still, GAO’s 

approach to market-based pay and 

related Band II restructuring 

efforts, which were very

challenging and likely

unprecedented in government, 

have been the source of

considerable attention and some

controversy. 

www.gao.gov/cgi-bin/getrpt?GAO-07-872T.

To view the full product, click on the link 

above. For more information, contact David 

M. Walker at (202) 512-5500 or 

CGQuestions@gao.gov. 
Chairman Akaka, Chairman Davis, and Members of the Subcommittees: 

I appreciate the opportunity to appear before you today to discuss recent 

human capital reform efforts at the U.S. Government Accountability Office 

(GAO). As you know, GAO is in the performance and accountability 

business. We try to improve economy, efficiency, effectiveness, ethics, and 

equity within the federal government. I consider these important 

principles in connection with all of my decision making relating to GAO. 

Furthermore, because we are the ones who audit, investigate, and evaluate 

others, GAO seeks to “lead by example” in every major management area, 

including the human capital area. We are not perfect and we never will be, 

but we strive to do what is right and to continuously improve. 

Before I address our recent human capital changes, I would like to put this

issue in context. As you know, GAO put the issue of Human Capital 

Strategy on our High-Risk List in 2001 as a governmentwide challenge. 

This was due to a variety of factors including the following: 

1. the downsizing of government in the 1990s, 

2. hiring freezes in selected government agencies, 

3. skills and knowledge gaps in many agencies, 

4. governmentwide succession planning challenges, and 

5. outdated human capital policies and practices within the federal 

government.

Clearly the government’s greatest asset is its employees. Such is certainly 

the case at GAO. Therefore, all of our human capital reform efforts need 

to be designed to attract and retain top talent within current and expected

resource levels. 

Our recent transformation efforts at GAO, including our human capital 

reforms, have been acclaimed by many and criticized by some. Such

criticism is not surprising, since transforming government is tough 

business and most people don't like to change, especially when the change 

may not be beneficial to them personally. This is especially true in 

connection with major human capital reforms. At the same time, as 

Comptroller General of the United States, I have a fiduciary and 

stewardship responsibility to focus not just on today but also to do what's 

right for tomorrow. This requires me, among other things, to focus on 

Page 1 GAO-07-872T 
what is in the collective best interest of all GAO’s employees rather than 

what might be in the narrow interest of some of GAO’s employees. It also 

requires me to consider which policies are appropriate to attract and 

retain a topflight workforce while ensuring that such policies are both 

affordable today and sustainable over the longer term. 

With regard to our pay ranges, some of our employees have interpreted 

our market-based pay determination as undervaluing their abilities and 

contributions. Such is clearly not the case. GAO’s workforce is highly 

skilled and dedicated to our mission. We have over 3,000 valuable and 

valued employees who work hard and make meaningful contributions to 

our agency each and every day. We appreciate what each GAO employee 

does for the Congress and the country. Our employees are working hard 

to make a meaningful and lasting difference, and so am I. 

The fact is when you are making tough transformational changes you 

cannot make everybody happy. This is especially true when you are 

making changes to an agency's classification and compensation systems. 

Nonetheless, it is important for an agency's leadership to listen to the 

views of all clients, employees, and other key stakeholders, and to 

seriously consider all legitimate comments and concerns. At the same 

time, at the end of the day, it is critically important for leaders to make 

difficult decisions based on what they think is the right thing to do, even 

though it may not be popular. This is the approach that we employ at 

GAO. 

One aspect of our recent human capital changes is our movement to a 

more market-based and performance-oriented pay system. Importantly, 

we are not the only federal agency seeking to do so. As a result, I believe

it is important to compare what we have done and how we have done it to 

others in order to provide context to your oversight and deliberations. 

While our transformational human capital changes have required some 

difficult adjustments, they, along with other key reforms, have helped us to

achieve record organizational results (see appendix I). Furthermore, we 

have continued to achieve very positive results in connection with our key 

people measures, including in connection with our annual employee 

feedback survey (see appendices II and III). For example, based on the 

results of our latest employee feedback survey, which was conducted after 

our classification and compensation changes and Band II restructuring 

effort, GAO was ranked number 2 among large federal employers in the 

most recent “Best Places to Work in the Federal Government 2007” 

rankings. 

Page 2 GAO-07-872T 
Most employee concerns regarding our recent changes relate to the 

implications of our moving to a more market-based, skills-, knowledge-, 

and performance-oriented pay system. In 2004, we conducted our first 

ever market-based pay study after laying the necessary foundation by 

implementing a modern, competency-based performance management 

system. We hired a top compensation consulting firm, Watson Wyatt, with

extensive public, private, and not-for-profit sector experience, through a 

competitive process. Our related internal consultation effort involved a 

variety of actions, including task teams, focus groups, “town hall 

meetings,” and meetings with our Employee Advisory Council. Watson 

Wyatt conducted the market-based pay study using generally accepted

approaches and based on its independent and professional judgment. 

Importantly, for a variety of reasons and at our request, the study did not 

consider employee benefits in establishing pay ranges for GAO's 

employees. This resulted in pay ranges that were somewhat higher than 

otherwise would have been the case.

As a result of the study, the pay ranges for about 25 percent of our 

employees were raised. In this regard, GAO’s Executive Committee raised 

several of the pay ranges proposed by Watson Wyatt to ensure our 

competitiveness externally and to enhance equity internally. Importantly, 

we did not lower any of the proposed ranges. This was good news for the 

affected employees. However, the study also determined that while most 

employees were paid within market ranges, about 10 percent of our 

employees were paid above market levels based on their roles, 

responsibilities, and/or relative performance. This was not good news for 

the affected 10 percent, and some of them have been vocal in their related 

complaints. As a result, our related restructuring efforts, which were very 

challenging and possibly unprecedented in government, have been the 

source of considerable attention and some controversy. 

Our reforms, while very significant, are by no means perfect. Perfection 

does not exist on this earth. We believe, however, that our actions have 

been consistent with both the law and the important principles that I 

outlined at the outset of my testimony. Our reforms also recognize the 

need to modernize the federal government's human capital practices, given

21st century realities. 

We believe we are the first major agency to implement broad banding;

market-based pay; and skills-, knowledge-, and performance-oriented pay 

systems on an agencywide basis. As noted previously, this is a major 

accomplishment, and our reforms have been the subject of many positive 

case studies and articles by various organizations, academics, and others 

Page 3 GAO-07-872T 
on how to achieve tough transformation changes within the federal 

government (see appendix IV). We are proud of what GAO has 

accomplished in the human capital area, including our recent 

classification and compensation system changes. 

Nonetheless, as I have stated previously, in hindsight, I regret that there 

were certain expectation and communication gaps that occurred in 

connection with our initial implementation of market-based pay ranges 

and related across-the-board pay adjustments in 2006. We have, however, 

taken numerous steps to address this matter over the past year so that any

such gaps should no longer exist. Candidly, there is no easy way to tell

people that they are overpaid based on the market, their roles and 

responsibilities, and possibly their relative performance. It is also difficult

to change from a system under which annual adjustments are largely on 

autopilot to one that is more market- and performance-based. 

At the same time, given the express statutory criteria that apply to GAO's 

annual pay adjustments, our constrained budgets since 2003, and our 

dedication to the principles of economy, efficiency, effectiveness, ethics, 

and equity, we took steps that, as Comptroller General, I deemed to be 

both prudent and necessary for GAO. Unfortunately, despite our concerted 

and good faith efforts, there has been a lot of false or misleading 

information circulated and reported about our classification and 

compensation changes. In this regard, I’d like to set the record straight in 

connection with several matters. 

First and foremost, I know that some are concerned that I did not follow 

through on certain assurances I made in 2003 during consideration of 

GAO's Human Capital Reform Act, namely, that we would provide acrossthe-board pay adjustments to GAO employees who received at least a 

“meets expectations” rating. In late 2004, after we received the marketbased pay study, we were faced with the reality that some of our 

employees were paid above market levels. This fact was not known when I 

testified in 2003. In retrospect, we should have advised the Congress and 

others sooner that we did not view my prior statements as applying to 

employees who were paid above market levels. I am sorry that we did not 

do that; however, the fact remains that I did not believe then, nor do I 

believe now, that it would be appropriate or equitable to provide acrossthe-board pay increase to employees who are paid above market levels. 

The very notion that one would provide across-the-board pay adjustments 

to those paid above market is, in my opinion, fundamentally inconsistent 

with the very premise of a market-based pay system and the concept of

equal pay for work of equal value. Again, while I regret that I did not 

Page 4 GAO-07-872T 
clarify this point in a more timely manner, I firmly believe that my exercise 

of judgment on this matter has been fully consistent with the principles 

and criteria that were under consideration in July 2003, when I testified, 

and that were enacted into law in July 2004. 

With regard to our recent Band II restructuring effort, the plain and simple 

truth is that no GAO employee took a pay cut as a result of our 

classification and compensation changes. Furthermore, all GAO 

employees who were on board as of January 2006 were given the 

opportunity to earn what they could have under the prior Band II pay 

system at the time of the conversion

As you may know, GAO has a two-tiered annual pay adjustment system. 

The first tier relates to the annual across-the-board pay adjustment that is 

determined by the Comptroller General based on the statutory criteria that 

I am required to consider; general market conditions; and certain other 

factors (e.g., our budget). All employees who achieve a “meets 

expectation” or higher rating on all applicable competencies and who are

paid within applicable market-based compensation limits, including 

consideration of the Band IIB speed bump, receive this increase.1

 The 

second tier is our supplemental performance-based compensation (PBC). 

While the amount of this increase is also contingent on our budget, PBC is

based on how well an employee performs relative to his or her applicable

peer group. 

While 308 GAO employees who performed at the “meets expectation” level 

or better did not initially receive an across-the board-pay adjustment in 

2006 because they were paid above market, this number decreased to 298 

as a result of the recent Personnel Appeals Board (PAB) settlement. Of 

this number, only 47 employees did not receive any PBC for that year. 

Given GAO’s constrained budgets, the plain truth is that any funds 

allocated to employees who are paid above market are funds that are not 

available for allocation to employees who are not paid above market, who 

may be better performers, and who may have more responsibility. 

 1

With regard to the speed bump, employees at the Band IIB level must meet the criteria 

above, and they also must be in the top 50 percent of their peer group if their salary 

exceeds the market-based speed bump. The speed bump for staff at the Band IIB level is 

necessary, given the significant degree of overlap in the salary ranges for Band IIB and 

Band III level employees. 

Page 5 GAO-07-872T 
The number of employees who did not receive across-the-board pay 

adjustments declined from about 10 percent of our total workforce in 2006 

to about 5 percent in 2007. Furthermore, of the 139 employees who did 

not receive across-the-board adjustments in 2007, only 2 did not receive

any PBC. Importantly, our limits on across-the-board pay adjustments for 

certain Band IIA employees represent a temporary transition issue. As a 

result, by the time that I leave office, we expect there no longer will be any 

Band IIA employees performing at the “meets expectation level” or better 

who do not receive an across-the-board pay adjustment (see appendix V). 

Some have asserted that morale at GAO is poor. This assertion is not 

supported by the facts. While the morale of certain Band II employees 

understandably went down in 2006 as a result of our Band II restructuring 

effort, overall morale at GAO has risen by 33 percent from the levels when 

I became Comptroller General. Furthermore, as noted previously, GAO 

was recently ranked number 2 among all large federal agencies across 

government in the “Best Places to Work in the Federal Government 2007” 

rankings published by the Partnership for Public Service in cooperation 

with American University. This ranking is based on the opinions of GAO 

employees obtained after our classification and compensation changes 

and Band II restructuring effort. Furthermore, GAO is also ranked highly

by a broad cross section of demographic groups (see appendix VI). 

Contrary to assertions by some, GAO’s rankings are based on responses to 

the exact same questions as the ones used in the Office of Personnel 

Management’s (OPM) survey of executive branch agencies. Moreover, 

despite what some have asserted, GAO employed an extensive outreach, 

employee participation, and communication effort in connection with our 

classification and compensation review and Band II restructuring effort. 

We made a number of important adjustments to our approach based on 

feedback we received from our employees. Our major agencywide efforts 

are summarized in appendix VII. Many of these efforts involved a broad 

range of GAO executives, including myself. The reality is that no matter 

how many outreach and listening sessions we might have conducted, some 

percentage of our employees would not have supported any proposed 

changes, especially those individuals who were deemed to be paid above 

market. 

Importantly, we have taken steps in the past year to provide additional 

opportunities for pay increases to many employees. For example, all GAO 

employees, including those who are paid above market levels, were 

eligible for 100 percent of their PBC in 2007. In addition, all of their PBC 

was added to their base pay up to applicable market-based pay limits. We 

Page 6 GAO-07-872T 
have also eliminated all pay range speed bumps other than the one 

applicable to Band IIB employees. In addition, we will soon be submitting 

legislation that will seek to enhance the pay and pension provisions 

applicable to our employees. GAO’s 2007 salary ranges, with comparisons 

to the most applicable 2007 General Schedule (GS) ranges, are included in

appendix VIII. 

Some have raised questions or criticized our market-based pay approaches

in ways that reflect a basic misunderstanding of how market-based pay 

studies are conducted. These criticisms also reflect a lack of 

understanding as to how the GS pay ranges are determined and updated.

Just because the GS system is widespread in the federal government and 

persons have a better understanding of how they are likely to fare under 

the system does not mean that it is appropriate, reflects modern 

compensation practices, or that individuals are treated fairly based on 

their skills, knowledge, and performance. On the basis of recent briefings 

by officials from OPM and the Bureau of Labor Statistics (BLS), in my 

view, the current GS system is outdated and is designed primarily to 

reward length of service rather than performance. In addition, as we found 

at GAO even before our Band II restructuring effort, performance 

appraisals can be negatively correlated to pay for employees paid at the 

cap for their applicable level. 

Given the apparent widespread lack of understanding of the methodology 

associated with establishing and updating the GS pay ranges, determining 

related annual across-the-board pay adjustments, and other annual pay 

adjustments, I believe there is a need to perform a review of the GS 

system. I would like to do such a study at the request of your

subcommittees, but I am willing to do it under my statutory authority as 

Comptroller General of the United States, if necessary. I look forward to 

publishing the results of this work. In any event, we will keep you 

informed as we conduct this work, and I hope that your subcommittees 

will hold a hearing on the report after it is issued. 

Some have questioned the degree of diversity in GAO’s workforce. These 

assertions do not stand up based on a comparison of GAO’s workforce to 

applicable civilian labor force data (see appendix IX), nor are they valid 

based on the change in GAO’s diversity profile over time (see appendix X). 

As I have stated on many occasions, GAO is committed to maintaining a

diverse and high performing workforce with equal opportunity for all and 

zero tolerance for discrimination of any type. We take a number of 

affirmative steps and incorporate a number of important safeguards in 

Page 7 GAO-07-872T 
relation to all major human capital decisions to help ensure that we 

achieve this important goal. Our recent decision to voluntarily contract 

for an independent assessment of African-American employees’ 

performance ratings is unprecedented and serves to demonstrate our 

commitment in this area.

Finally, on May 8, 2007, the International Federation of Professional and 

Technical Engineers (IFPTE) filed a petition with the PAB to start the 

process to organize and represent certain GAO employees. As I have said

on numerous occasions, I support the rights of our employees to organize 

and have taken steps to ensure that GAO’s management complies with 

applicable labor laws. We are willing to support a timely election. 

However, GAO will challenge any attempts by the union to organize 

supervisory or confidential personnel. Ultimately, the PAB will be 

required to decide any issues that are in dispute. We hope that this matter 

can be resolved in a professional and expeditious manner. 

In closing, GAO’s leadership team is committed to continuous 

improvement while avoiding constant change. As I said before, GAO is not 

perfect and it never will be. We are, however, a leader in transforming 

many management areas within the federal government, including the 

human capital area. We are proud of this fact and plan to do everything 

that we can, in partnership with our clients and employees, to stay that 

way. 

Thank you for your time and attention. I would be happy to answer any 

questions that you may have. 

Page 8 GAO-07-872T 
Appendix I 

Organizational Results Measures 

Measures Fiscal Year 1998 Fiscal Year 2006

Financial benefits (billions of dollars) $19.7 $51.0a

Nonfinancial benefits (number of actions) 537 1,342

Past recommendations implemented 69% 82%

New products with recommendations 33% 65%

Source: GAO. 

Note: Additional years of data are available for comparison. See GAO, Performance and 

Accountability Report, Fiscal Year 2006, GAO-07-2SP (Washington, D.C.: November 15, 2006). 

a

$51 billion dollars represents a $105 return on every dollar the Congress invests in GAO. 

Page 9 GAO-07-872T 
Appendix II 

People Measures: Attracting and Retaining Staff 

Measures Fiscal year 2002aFiscal year 2006

New hire rate 96% 94%

Acceptance rate 81% 70%b

Retention rate with retirements 91% 90%

Retention rate without retirements 97% 94%

Source: GAO.

Note: Additional years of data are available for comparison. See GAO, Performance and 

Accountability Report, Fiscal Year 2006, GAO-07-2SP (Washington, D.C.: November 15, 2006). 

a

Fiscal year 2002 was the first year in which GAO publicly reported all four of these people measures 

for trend purposes. Prior to fiscal year 2002, data were not collected for either the new hire rate or 

the acceptance rate. 

b

The acceptance rate was lower in fiscal year 2006 due, in large part, to the uncertainty of our 

appropriation, which affected our ability to make hiring offers in a timely manner. 

Page 10 GAO-07-872T 
Appendix III 

People Measures: Developing, Using, Leading, and Supporting Staff 

Measures Fiscal year 2002 Fiscal year 2006

Staff development 71% 76%

Staff utilization 67% 75%

Leadership 75% 79%

Organizational climate 67% 73%

Source: GAO. 

Notes: These measures are based on responses to selected questions in GAO’s annual employee 

feedback survey, which was revised in 2002 to reflect GAO’s organizational realignment. While GAO 

conducted annual employee feedback surveys prior to 2002, these prior instruments are not 

comparable in their content or design. 

Additional years of data are available for comparison. See GAO, Performance and Accountability

Report, Fiscal Year 2006, GAO-07-2SP (Washington, D.C.: November 15, 2006). 

Page 11 GAO-07-872T 
Excerpts from Case Studies and Articles Highlighting GAO’s Human Capital System

Published source Excerpted text

The IBM Center for The Business of

Government

“Designing and Implementing 

Performance-Oriented Payband 

Systems” 

James R. Thompson 

Associate Professor 

Graduate Program in Public 

Administration

University of Illinois at Chicago 

May 2007 

• “The interest in pay banding derives in substantial part from the flexibility paybanding 

affords managers in matters of pay and classification. There is widespread

agreement among those who have examined compensation practices in the federal 

government that the approach embodied by the traditional General Schedule (GS) is 

obsolete. A common complaint is that the system is too rigid and that the 15-grade 

structure induces excessive attention to minor distinctions in duties and 

responsibilities that can affect how a position is classified.” 

• “Another concern is that pay increases are granted largely on the basis of longevity 

rather then performance.” 

• “The GAO and DoD systems link the pay of their employees more explicitly to the 

market then do the systems in the other agencies. The intent is both to insure that 

they can compete for talent and to avoid paying more than is necessary to get the 

talent.” 

• “GAO has the most sophisticated of the eight systems reviewed here.” 

• “GAO’s system is one of only two that are explicitly market-based. GAO determines 

a ‘competitive pay rate,’ which represents the market median for positions within 

each band. The amount of performance-based compensation is calculated as a 

percentage of the competitive pay rate.” 

• “The standardization of rating averages by pay groups, which makes rating

consistency across groups less important and which de facto identifies relative levels 

of performance within each group.” 

• “Similar to GAO, at the Navy Demonstration Project, the link between the overall 

rating and the pay increase is direct; no additional intervention by the supervisor is 

required at the pay setting stage.” 

• “GAO follows a private sector practice by conducting surveys to determine the market 

rate for each occupational group.” 

• “Of the eight systems reviewed here, only GAO’s is market-based: Salaries are 

periodically adjusted according to compensation levels for similar positions in the 

private sector.”

• “Several of the agencies included in this study use boards of senior managers to 

review ratings across units. GAO’s system, on the other hand, does not assume or 

require rating consistency. The standardized rating score on which each employee’s 

pay increase is based is a function of relative performance within each employee’s 

work group.” 

• “GAO does not use pay pools. Adjustments to ensure that salary costs stay within 

budgeted amounts occur only at the top. The comptroller general determines both 

the ‘annual adjustment’ analogous to the general pay increase received by GS

employees and the ‘budget factor,’ which figures prominently in the calculation of 

individual performance-based compensation increases.” 

Appendix IV 

Page 12 GAO-07-872T 
Published source Excerpted text

Harvard Business Review

“Change Management in Government” 

Frank Ostroff 

May 2006 

• “The Government Accountability Office, or GAO, which investigates other federal 

agencies and issues reports on their performance, adopted many of the talentmanagement practices found in the private sector.” 

• “To encourage GAO staffers to embrace new procedures, Walker focused on 

incentives. GAO had been a place where almost all employees received pay 

increases largely on the basis of time on the job and job classification or grade, 

regardless of performance. Now, compensation is structured on market-based salary 

ranges, and employees are rewarded for expertise, leadership, increased

responsibility, and other contributions to performance.” 

• “At GAO, for example, David Walker began by talking with Congress and the 

agency’s two key internal groups- the agency’s managing directors and the 25 

employee representatives who sit on the Employees’ Advisory Council. ‘We talk 

about what we need to do. I discuss it with them live so that they can provide input 

and ask questions.’“ 

• “As Walker puts it, ‘I find that often you have more flexibility than people believe. 

Many rules, as well as civil service limitations on what you can and can’t do, are 

good, and they need to be followed. But there is a difference between what you can 

and can’t do and what has been done and not done in the past.’ As reported by 

GAO, during Walker’s tenure, that agency has roughly doubled savings achieved and 

resources freed up from $19 billion per year to $40 billion at other agencies as a 

result of its recommendations.” 

IBM Center for the Business of

Government

The Transformation of the Government 

Accountability Office: Using Human 

Capital to Drive Change 

Jonathan Walters 

Governing Magazine 

Charles Thompson 

IBM Business Consulting Services 

July 2005 

• “Many close observers of federal personnel systems believe GAO has a significant 

amount to offer in answering questions around public sector human capital reform. 

‘GAO is worth paying attention to,’ says Steve Nelson, director of the Office of Policy 

and Evaluation at the Merit Systems Protection Board. ‘They’ve been well ahead of 

other federal agencies in implementing changes, including large ones like pay for 

performance and going to market based pay.’” 

• “Nobody interviewed for this report complained about being underpaid; indeed many 

staff said that the combination of interesting work and decent pay and benefits made 

GAO a very attractive place to be.” 

• Remarks attributed to Colleen Kelly, President of the National Treasury Employees 

Union regarding GAO’s human capital transformation: ‘If the administration were 

really sincere about improving human capital management, they would pay closer 

attention to what’s gone on at GAO.’” 

Partnership for Public Service 

Case Study “GAO: Leading by Example” 

November 5, 2003 

• “GAO has some of the best analytical talent in the country. More then 60 percent of 

its 3,000-plus employees have master’s degrees and PhDs, and their expertise 

covers the entire range of federal government programs.” 

• “GAO’s strategic objectives and annual operating objectives are now strongly linked

to its performance appraisal system through the use of a competency approach as 

the centerpiece of its performance management and all other human capital 

systems.” 

• “In GAO’s performance management process, the employee is front and center. 

They are expected to play an active role in defining their annual goals and 

performance expectations. Moreover, employees’ self-assessments of their own 

performance serve as the starting point for formal evaluations.” 

• “After the close of the first year under the new system, GAO gathered feedback from 

its Employee Advisory Council and Managing Directors about the results of the first 

performance appraisal and management cycle. Based on that feedback, several 

important improvements to the system were made to continue the change process.” 

Page 13 GAO-07-872T 
Published source Excerpted text

Government Leader 

“Walker takes GAO from accounting to 

accountability”

John Pulley 

May 14, 2007 

• “Walker’s overhaul of GAO’s job classification and employee appraisal systems links 

pay to market forces and raises to job performance. Broad pay bands have replaced 

the regimented General Schedule, which was created in 1949 to manage a largely 

clerical federal workforce. The results is the most far-reaching overhaul of pay and 

job classification that any agency of the federal government has undertaken.” 

• Remarks attributed to John Palguta, Vice President of Policy at the Partnership for 

Public Service: ‘At a time when 70 percent of federal jobs are professional or 

administrative, linking pay to performance and rewarding high achievers is overdue. 

Kudos to GAO for trying to demonstrate—very personally and very aggressively—

that this should be the compensation system of the future. It’s a bold move on the 

part of GAO, and it has caused some consternation within the agency.’” 

• Remarks attributed to Elizabeth Singer, a member of GAO’s Employee Advisory 

Council: “The critics are very intense, very vocal, very angry, very bitter, but they do 

not represent the majority opinion.’’” 

• Remarks attributed to Robert Tobias, Director of American University’s Institute for 

the Study of Public Policy Implementation: ‘If I’m in the executive branch and I’m an 

appointee, my focus is on creating public policy, not implementing it. The 

Washington Post focuses on fights in Congress, not on agencies that do good work. 

A sustained, focused attention on public policy implementation was not present until 

Walker came on the scene.’” 

FCW.COM 

“A question of ranking” 

Richard W. Walker 

May 2007

• “In response [to allegations that GAO’s survey did not include the same questions 

posed to other executive branch employees], Robert Tobias, director of the Institute 

for the Study of Public Policy Implementation, said, ‘That is not accurate. The three 

questions in the GAO survey that we used to provide an overall ranking [for the Best 

Places to Work in the Federal Government ranking] were the exact same questions 

that were used in the federal human capital survey.’” 

Mike Causey’s Federal Report 

May 9, 2007 

• “GAO has ruffled lots of feathers in its day doing its duty. But most people conceded 

it is one of, if not, the best run operations in government. But even in the best places, 

not all the troops are always happy.” 

• “Washington attorney Bill Bransford says the small number of complaints may be an 

indication that GAO has a winner. Comptroller General David Walker said the PFP 

[pay for performance] system must have reviews and a safety valve, and Bransford, 

whose firm specializes in helping feds in trouble, says ‘it appears to be a good 

program.’” 

• “Anyhow after the dust settles, it is likely that GAO will turn out to have the best PFP 

system in government. It’s a highly-trained, motivated place with lots of talented

people and a boss, Comptroller General David Walker, who has a number of 

strengths.” 

Page 14 GAO-07-872T 
Published source Excerpted text

Partnership for Public Service 

Written Testimony of Max Stier 

President and CEO, Partnership for 

Public Service

Prepared for the House Committee on 

Armed Services Subcommittee on 

Readiness hearing: “The National 

Security Personnel System: Is it Really 

Working?” 

March 6, 2007

• “We know that the GS [General Schedule] pay system and the traditional 

performance management system is in need of reform by listening to federal 

employees themselves. In OPM’s 2006 Federal Human Capital Survey, to which 

over 50,000 DOD civilian employees responded, less than one-third (31 percent) 

agreed that ‘In my work unit, differences in performance are recognized in a

meaningful way.’” 

Government Leader 

“Pay for the Right Results” 

Wyatt Kash 

January 13, 2006 

• “There have been pockets of success: at the Federal Aviation Administration, the 

IRS, the National Institute of Standards and Technology and the Government 

Accountability Office. Each demonstrated that progressive leadership could break 

the chains of the General Schedule system and attract and retain the talent

government needs. Indeed, more then 90,000 federal workers are now in some form 

of performance-based pay system.” 

• “GAO and its chief, David Walker, are widely credited these days with doing the job 

right. Critics quickly dismiss GAO for having some distinct advantages: its workforce 

is small, relatively homogenous and highly educated. But the lessons of GAO—and 

the principled approach of comptroller general Walker... offer important leadership 

examples worth emulating.” 

Federal Times

“GAO’s Worthy Example” 

November 28, 2005 

• “GAO’s first, and possibly most important, step was to institute a credible 

performance appraisal system—three to four years before it attempted to tie 

performance to pay. Having established that system during the three years that 

followed, the agency is now ready to tie that system to pay raises.” 

• “GAO leaders also avoided making decisions by fiat. Walker invited employee input 

at open meetings, through advisory councils and by circulating draft plans that invited

comments. Employee suggestions were then incorporated into the final plan.” 

Source: GAO synthesis of published sources, as noted. 

Page 15 GAO-07-872T 
Appendix V 

Disposition of Band II Staff Initially Placed in Band IIA on January 8, 2006 Projected

Through 2012 

Notes: Figures represent staff counts going into the annual adjustment and PBC process each 

January after the salary ranges have been adjusted upward. Thus, staff in the IIT range are those 

who would receive no annual adjustment that cycle. 

Calculations assume 3.19 percent annual adjustments; 3.19 percent salary range growth; 2.15

percent PBC (with 75/25 allocation); and current IIT rules. 

The actual transition period could be shorter if persons are placed in Band IIB before the adjusted pay 

cap for Band IIA catches up to the Band IIT cap. 

Page 16 GAO-07-872T 
Appendix VI 

GAO’s Ranking among Large Federal Agencies, by Demographic Group 

Demographic category Ranking

Overall 2

African-American 2

Hispanic 2

Asian 6

Female 2

Source: GAO. 

Page 17 GAO-07-872T 
Examples of Employee Outreach Related to the Classification and Compensation Review and Band II Restructuring Efforts 

2002 •

August • Employee Advisory Council and Executive Committee conduct regular quarterly meeting: begin to discuss the 

feasibility of splitting the Band II level. 

December • Employee Advisory Council and Executive Committee conduct regular quarterly meeting: discuss the role of the EAC 

in future discussions of splitting the Band II level. Also discuss that the project will not get under way until calendar 

year 2003 and that no changes are expected until 2004. 

2003 •

April • Executive Committee conducts three town hall forums with Band II staff to discuss human capital reforms. 

• Explanation for Human Capital II legislation posted to GAO Intranet for all employees. 

May • Questions and Answers document for Human Capital II legislation posted to the GAO Intranet for all employees. 

June • Memo on proposed reforms to the performance management system, based on Employee Advisory Council and 

Managing Directors’ feedback, posted to the GAO Intranet for all employees. 

September • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss the distinction between 

jobs performed at the Band II level. 

December • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss status of congressional 

action related to Human Capital II legislation; note that a project team (Band II Advisory Group) had been formed to 

study the Band II split, with EAC representation, and that the earliest the split will happen will be October 1, 2004. 

2004 •

January • Comptroller General conducts “CG Chat:” discusses the planned split of the Band II level into two bands—one for 

those who act as Analysts-in-Charge on a recurring basis and one for those who function primarily as Senior 

Auditors, Analysts, and Investigators, and occasionally serve as Analysts-in-Charge. 

• Detailed work plan on Band II restructuring posted to the GAO Intranet for all employees. 

February • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss the reasons for the 

proposed Band II split and note that the split likely will occur between October 2004 and January 2005. 

• Executive Committee conducts special town hall forum with Band II staff. 

• Executive Committee conducts meeting with Advisory Group on Band II restructuring. 

March • Executive Committee conducts special town hall forum with Band I population on Band II restructuring. 

• Executive Committee conducts special town hall forum with Band IIs to discuss the compensation and classification

review. 

April • Comptroller General conducts “CG Chat:” discusses the upcoming classification and compensation review; how it 

evolved from the “Band II split;” and its underlying objectives, principles, processes, and time frames. 

May • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss the status of the Band II 

Advisory Committee’s efforts and the fact that the group will not meet again until the Classification and Compensation 

Review (CCR) is complete (planned for summer 2004), note that January 2005 will be the earliest date for 

implementing any CCR results, and add that no employee’s pay would be cut, including locality pay. Employee

Advisory Council members asked to provide input by June 2004 on the kinds of organizations that GAO should 

consider for pay comparison. 

July • Comptroller General conducts “CG Chat:” provides a status report on the CCR. 

• Contract awarded to Watson Wyatt for compensation study.

August • Watson Wyatt briefs the Managing Directors. 

• Watson Wyatt briefs the Employee Advisory Council. 

• Watson Wyatt conducts approximately 35 hours’ worth of meetings with Career Stream Focal Points. 

Appendix VII 

Page 18 GAO-07-872T 
September • Comptroller General conducts “CG Chat:” discusses CCR and notes that starting with the next pay adjustment for 

Analysts, Attorneys, and Specialists, all pay categories will be eliminated and all performance-based pay increases 

will be made on an individual-by-individual basis. 

October • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss the hiring of Watson Wyatt 

to start the CCR and note that the study is expected to be completed by the end of the month. 

• Comptroller General conducts “CG Chat:” discusses performance appraisal and pay issues. 

• Watson Wyatt briefs employees on compensation design elements. 

November • Watson Wyatt conducts meeting with the Executive Committee and Managing Directors on GAO’s adaptation of their 

findings. 

December • Comptroller General conducts “CG Chat:” shows briefing slides to explain how GAO will use Watson Wyatt’s findings 

to determine salaries for Analysts, Attorneys, and Specialists. 

2005 •

January • Comptroller General conducts “CG Chat:” explains how pay adjustments will be made; explains methods used to 

calculate 2005 performance based compensation increases for Analysts, Attorneys, and Specialists; explains the 

concept of standardized rating scores. 

April • Employee Advisory Council and Executive Committee conduct quarterly meeting: discuss a future briefing for the 

Employee Advisory Council by the end of April on the proposed plan for updating the roles of Band IIA/IIB; the 

selection criteria; and the process for initial placement. Also request that the Employee Advisory Council nominate 

three of its members to serve on a GAO-task team related to Band II restructuring that will convene in May. 

May • Comptroller General conducts “CG Chat:” reviews plans for next year’s pay adjustments for Analysts, Attorneys, and 

Specialists; announces plans for placing Band II staff members in IIA and IIB salary ranges, establishing a career 

path for Written Communications Specialists, and developing a process for Communications Analysts to transfer to 

Band IIA analyst positions. CG also released a project plan to (1) make the initial placements to implement the 

Band IIA and Band IIB market-based compensation ranges, (2) establish a career path for Written Communications 

Professionals, and (3) provide a process through which Communications Analysts may apply for a transfer to 

generalist analyst positions at the Band IIA level. 

• Project plan for Band II restructuring posted to the GAO Intranet for all employees. 

June • Project plan and announcement of employee task teams’ creation to study and develop proposals to implement Band

IIA and IIB market-based compensation ranges for Analysts and Specialists posted to the GAO Intranet for all 

employees. 

July • Executive Committee and Employee Advisory Council conduct quarterly meeting: discuss topics for July 15, 2005, 

“CG Chat” and provide an update on the Band II restructuring effort. 

• Comptroller General conducts “CG Chat:” notes that the Executive Committee will review reports from the task teams 

established to develop recommendations for the roles and responsibilities of Band II Analysts, Specialists, and 

Communications Professionals. 

• “Phase I” draft proposals for identifying the IIA and IIB roles and responsibilities for Analysts and Specialists and a 

career track for Written Communications Professionals posted to the GAO Intranet for all employees for comment. 

August • Executive Committee conducts special town hall meetings with all staff on Analyst proposals.

• Executive Committee conducts special town hall meetings with all staff on Attorney proposals.

• Executive Committee conducts special town hall meetings with all staff on Specialist proposals. 

• Notice announcing that focus groups are forming to discuss “Phase II” proposals for implementing Band IIA and IIB 

market-based compensation ranges for Band II Analysts and Specialists (to be effective January 2006) posted to the 

GAO Intranet for all employees. 

Page 19 GAO-07-872T 
September • Draft Band II restructuring “Phase II” proposals for identifying the criteria and process for placing Analyst and 

Specialist staff in the IIB pay range posted on the GAO Intranet for all employees for comment. 

• Notice posted to the GAO Intranet for all employees announcing the availability on the Intranet of the Band II 

Restructuring roles and responsibilities for Senior Analysts in the IIA and IIB pay ranges, Specialists in the IIA and IIB 

pay ranges, and Communication Analysts in the Band I and II pay ranges. 

October • Questions and Answers document on the Band II restructuring posted to the GAO Intranet for all employees. 

• Draft GAO Order on the Band II Restructuring, containing the latest “Phase I” roles and responsibilities and additional 

information about the “Phase II” straw proposal regarding the criteria and process for initial IIB pay range placement, 

posted to the GAO Intranet for all employees to comment. 

• Executive Committee and Employee Advisory Council conduct quarterly meeting: CG notes that not many comments 

were received on “Phase I” (roles and responsibilities) of the Band II restructuring effort and reminds EAC members 

that the GAO order on “Phase II” (criteria and process) is currently out for comment. 

• Notice posted to the GAO Intranet for all employees announcing the extension of the comment period for the draft 

GAO order on the Band II restructuring. 

November • Executive Committee conducts special meeting with Managing Directors on Band II restructuring. 

• Comptroller General conducts “CG Chat:” announces the kick off of an accelerated process for placing current 

Band II staff members in the IIA and IIB pay ranges by announcing final decisions on the criteria and process to be 

used and announces decisions about 2006 pay rates for Analysts, Attorneys, and Specialists, with a warning that 

they were contingent on GAO’s final budget. 

• Notice posted to the GAO Intranet for all employees announcing the availability on the GAO Intranet of the slides 

used in the previous day’s “CG Chat.” 

• Draft GAO order related to GAO’s administrative grievance procedure, updated to include information related to the 

restructuring of Band II, posted to the GAO Intranet for all employees to comment. 

• Notice posted to the GAO Intranet for all employees announcing changes in eligibility requirements found in the 

restructuring order and changes in the dates that Band IIB selection panels would convene. 

• Questions and Answers document on the Band II restructuring for “Phase II” posted on the GAO Intranet for all 

employees. 

December • Band IIB selection panels convene. 

• Staff noncompetitively placed in Band IIB are notified of their selection. 

• Information describing the Band IIB reconsideration process posted to the GAO Intranet for all employees. 

Page 20 GAO-07-872T 
2006 •

January • Effective date of reassignment for staff placed in IIB. 

• Notice posted to the GAO Intranet for all employees to comment announcing the procedures for Band IIB Placement 

Reconsideration Requests. 

• Notice posted to the GAO Intranet for all employees to comment clarifying the status of Criminal Investigators (series 

1811) as a result of the recent Band II restructuring. 

• Comptroller General conducts “CG Chat:” reviews results of Band IIB placements and notes that there will be other 

opportunities for competitive placement in Band IIB—the next one by the end of June and conducted at the same 

time as the Band IIA promotion process; announces that a proposed procedure for current Communication Analysts 

and PT-II staff members to apply for certification as Band IIA Analysts, as recommended by a special employee task 

force, will soon be posted for comments. Notes that—based on the employee task team’s work—the Executive 

Committee decided not to employ a certification process for moving staff from Band I to Band IIA, meaning that for 

the time being, the process will remain competitive and there will be no speed bump in the IIA pay range. 

• Executive Committee and Employee Advisory Council conduct quarterly meeting: Employee Advisory Council 

members raise concerns about how the selection criteria for the Band IIB position were applied, inquires about how 

future rounds of placements will be conducted, and notes the perceived decrease in staff morale as a result of the 

restructuring. Discusses the employee task forces’ work related to a certification process for Communication Analysts 

and APSS staff interested in converting to Analyst positions.

• In response to issues raised by the Employee Advisory Council, a memo providing additional information on the 

Band II restructuring process; Personnel Appeals Board and GAO’s Office of Opportunity and Inclusiveness appeals 

processes and filing deadlines; Managing Director feedback on central panel results; and other related issues is 

posted to the GAO Intranet for all employees. 

• Staff who applied for reconsideration to be placed in IIB are notified of decisions. 

February • Comptroller General conducts “CG Chat:” reviews the results of Band IIB reconsideration and discusses the rationale 

for recalculating standardized rating scores to determine the amount of performance-based pay for Band IIA and IIB 

staff members. 

• Employees file petitions with the Personnel Appeals Board on Band II restructuring. 

April • Executive Committee and Employee Advisory Council conduct quarterly meeting: Employee Advisory Council 

members summarize the results of their Band II outreach effort and all parties discuss possibilities for how and when

to post the list of staff placed in IIB; discuss the process for future rounds of IIB placement. 

• Question and Answer document on the Band II restructuring posted to the GAO Intranet for all employees. 

May • Notice of the implementation of a uniform appraisal cycle for Analysts and Specialists, based on feedback from the 

Employee Advisory Council and the Managing Directors, posted to the GAO Intranet for all employees. 

• Revisions to Band IIB Performance Appraisal Standards posted to the GAO Intranet for all employees to comment. 

July • Comptroller General conducts “CG Chat:” announces that subject to budget constraints, the Executive Committee is 

considering various proposals: all GAO staff, regardless of their salary level and their position within their pay band, 

will be eligible to receive their full performance-based compensation (currently, staff who are at or above their 

applicable pay cap are not eligible for PBC). Notes that the minimum merit percentage could be set at greater than 

50 percent (current guidelines call for 50 percent of PBC to be paid in merit or base pay). Also announces that speed 

bumps will be eliminated in all pay ranges for both mission and APSS staff, except for Band IIB. Notes that GAO staff 

will be provided an opportunity to review and comment on these proposals before they are implemented. Reviews 

results from the first round of IIA and IIB placements following the initial restructuring effort. 

• Executive Committee and Employee Advisory Council conduct quarterly meeting: review the proposed

enhancements to the compensation system that were discussed in the prior day’s chat. 

October • Executive Committee and Employee Advisory Council conduct quarterly meeting: discuss rating periods for staff 

recently placed in IIB. 

Page 21 GAO-07-872T 
2007 •

April • The PAB cases, filed in February 2006 regarding the Band II restructuring and involving 12 employees, are resolved

via settlement. 

May • Watson Wyatt briefs the Employee Advisory Council. 

Source: GAO. 

Page 22 GAO-07-872T 
Appendix VIII 

Comparison of GAO’s 2007 Banded Salary Ranges with 2007 GS Levels (All Steps) for the Washington/Baltimore/ Northern

Virginia Locality Area 

GAO band 

GAO 

minimum 

GAO

competitive rate

GAO

speed bump

GAO 

maximum 

GS ranges

(all steps within grade)

I

a

$42,900 $60,600 N/A $78,200 $37,640—$86,801

(GS 7-12)

IIA / IITb$71,900 / 

$77,400 

$88,300 N/A $104,700/$118,700 $79,397—$103,220

(GS-13)

IIB $84,600 $108,400 $121,600 $132,200 $93,822—$121,967

(GS-14)

III $107,200 $117,500 N/A $143,471 $110,363—$143,471

(GS-15)

Source: GAO and OMB. 

a

Analyst ranges only. Does not include ranges for IT Analyst, Financial Auditor, or Communication 

Analyst positions. 

b

IIT is not a separate band, but rather a separate classification of staff with unique salary 

circumstances. 

Page 23 GAO-07-872T 
Appendix IX 

GAO Analyst and Related Staff Compared with the 2000 Civilian Labor Force (CLF) Data (Note: GAO data as of October 1, 

2006) 

 African American Asian Hispanic Women

GAO 

occupations

Total

GAO staff % in CLF % in GAO % in CLF % in GAO % in CLF % in GAO % in CLF % in GAO

Analyst 1,816 5.87% 11.78% 5.71% 7.38% 3.58% 5.23% 38.61% 54.24%

Auditor 239 7.89% 13.81% 8.06% 11.72% 5.13% 7.11% 57.02% 53.56%

Computer 

sci/telecomm 115 7.83% 13.91% 10.79% 19.13% 4.70% 6.09% 33.23% 50.43%

All other 

analyst 

relateda

256 7.98% 14.84% 9.63% 6.25% 5.05% 1.95% 39.62% 39.84%

Total 2,426 6.62% 12.41% 6.81% 8.24% 4.13% 5.11% 43.24% 52.47%

Source: GAO.

a

Includes occupations like Economists, Financial Analysts, Criminal Investigators, Statisticians, and

other specialists with as few as 1 GAO employee.

Page 24 GAO-07-872T 
Appendix X Appendix X 

GAO’s Diversity Profile among Senior Analysts, Assistant Directors, and SES Level (Note: scales on vertical axes differ, 

reflecting the differences in representation for each group)

Page 25 GAO-07-872T 
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