FEDERAL ELECTION COMMISSION 

OFFICE OF INSPECTOR GENERAL 

FINAL REPORT 

AUDIT OF THE FEDERAL ELECTION COMMISSION’S 

OFFICE OF HUMAN RESOURCES 

July 2013 

ASSIGNMENT No. OIG-12-05 
 

 

 

 

 

 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

TABLE OF CONTENTS 

DESCRIPTION PAGE 

Executive Summary 3 

Objectives, Scope, and Methodology 6 

Background 9 

Customer Service Survey Results 12 

Findings and Recommendations 14 

I. Performance Management 14 
 

A. Ineffective Leadership 14 

B. Inadequate Organizational Structure 17 

C. Non-compliance with FEC’s Performance Plan and 

Appraisal Policy 18 
 

II. Technology & Automation 22 
 

A. Ineffective Use of the Federal Human Resource (FHR) 

Navigator System 22 
 

B. Office of Human Resources is not Properly Utilizing and 

Maintaining their FECNet Page 24 

C. Electronic Fingerprint Scheduling Process not 

Fully Implemented 27 

III. Office Operations 28
 

A. HR On Demand Process is Ineffective 28 

B. Non-compliance with FEC’s Recruitment/Selection Process 32 

C. Outdated Global Personnel Related Policies/Directives 37 

Conclusion 39 

Summary of Findings and Recommendations Table 41 

Appendix A – Management Responses to the OHR Report 

2 
Audit of the FEC’s Office of Human Resources OIG-12-05 

EXECUTIVE SUMMARY 

The Office of Inspector General (OIG) conducted the Audit of the Federal Election 

Commission’s Office of Human Resources (OHR) based on the numerous findings 

identified in the 2009 Office of Personnel Management’s (OPM) Human Capital 

Management Evaluation Report, concerns about the effectiveness of the OHR raised by 

FEC senior leaders during the OIG’s 2012 annual audit planning process, and the 

numerous unsatisfactory responses included in the 2011 OHR’s annual customer service 

survey. 

The OHR is responsible (either directly or indirectly) for all FEC personnel related 

activities including hiring, human capital management, pay changes, promotions, 

benefits, employee performance management, among other activities. The numerous 

responsibilities of the OHR results in the office being one of the most important functions 

of the FEC, an office relied upon by every employee of the agency and prospective 

employees of the FEC. As a result of the significant responsibilities of the OHR, it is 

imperative that customer service is a main priority for OHR. 

The overall objective of this audit was to assess the effectiveness and efficiency of 

customer service in OHR. Sub-objectives of the audit were to identify if: (a) OHR’s 

processes directly related to customer service are operating effectively; (b) OHR has 

adequate policies that are up-to-date to govern HR- related functions; (c) the office is 

effectively utilizing technology and other HR automation tools, and identify areas to 

enhance efficienct and effective use of technology; and (d) additional policies or policy 

improvements/updates are needed. 

Based on this audit, the OIG concludes the OHR has significant leadership and 

operational weaknesses that are impacting the office’s ability to provide effective 

customer service and fulfill the day-to-day responsibilities of the office. Specifically, the 

agency hired a new Director of OHR in April 2010, who lacked the necessary leadership 

experience to address the many challenges facing the OHR at that time and going 

forward. To compound this issue, the Director of OHR’s supervisor at the time, failed to 

promptly provide the newly appointed Director of OHR the training necessary to address 

these leadership gaps. The OIG acknowledges the Director of OHR has put forth 

significant efforts to improve the OHR. However, most of these initiatives have not been 

effective at improving customer service and the operations of the OHR. The audit also 

found that HR- related policies are either out-dated or do not exist. 

3 
 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

To help determine if initiatives implemented in the past couple of years have been 

effective in improving OHR customer service, the OIG conducted an independent OHR 

customer service survey in September 2012. The OIG’s survey results identified 58% of 

the survey respondents believe that OHR’s customer service has not improved or has 

stayed the same over the past 12 months. Specifically, common complaints among 

employees who responded to the OIG survey related to the lack of timely OHR responses 

to employee requests and the inaccuracy of data and information provided to employees; 

more details on the results of OIG’s OHR customer service survey is included on page 

12. 

Prior to this audit, management and the Director of OHR attempted to address some 

deficiencies in program management, such as implementing the FEC’s Human Capital 

Plan in December 2011, conducting a workforce gap analysis, restructuring the office, 

and implementing HR On Demand (an electronic employee request and tracking 

process). However, the majority of these initiatives had been poorly implemented and 

not effective. For example, the FEC hired a contractor to conduct a comprehensive 

workforce gap analysis1

 (gap analysis) in fiscal year (FY) 2011 specifically for the FEC’s 

OHR at a cost of $28,984. Based on OIG’s assessment of the status of corrective actions, 

we determined that as of February 2013, OHR has only fully addressed two (2) of the 

nine (9) findings from this analysis. 

OIG identified another major factor that is hindering OHR’s ability to provide acceptable 

customer service is the poor planning and implementation of available tools and 

technology to streamline processes and improve operational efficiencies. Specifically, 

OIG is concerned with how long it has taken to implement the Federal Human Resources 

Navigator (FHR) System which is designed to assist HR offices with automating HR 

functions and processes. Six (6) of the seven (7) total FHR modules were purchased in 

September 2010 and only one (1) has been fully implemented as of February 2013 (17 

months after initial purchase). In February 2013, when the OIG inquired with OHR on 

the status of FHR implementation, OHR stated that they were pilot testing one of the 

original six modules purchased in September 2010 along with an additional module 

related to recruiting/hiring which was purchased in October 2012. 

In addition to the automated FHR system, the OHR also developed an in-house electronic 

customer service tracking system called “HR On Demand.” 

1

 OHR procured contract services in June 2011from Suntiva, LLC to conduct an analysis of their office to 

identify any performance (knowledge, skills & abilities) gaps for their entire office staff, to include the 

supervisors and the Director of Human Resources. 

4 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Due to poor implementation, including inconsistent use of the system by OHR staff, and 

a lack of knowledge on how the system worked by OHR staff, including OHR 

management, the OHR eventually acknowledged the system was not working as 

intended. 

Subsequent to the completion of the OIG’s audit fieldwork, management and OHR have 

already begun to implement corrective actions they believe will address some of the 

recommendations included in this report. For example, corrective actions are underway 

to implement a new automated customer service tracking system called “Remedy,” pilot 

testing of FHR modules has started, and work on improved policies and procedures is in 

process. In addition, management has brought on a Senior Executive Service (SES) 

candidate from another agency temporarily to help the Director of OHR improve the 

office. This person does not have an HR background but does have experience with 

process re-engineering and managing a large office. 

However, the OIG still concludes that the extent of the problems which currently exist in 

the OHR require significant leadership improvement and operational change. The OIG 

believes that failure by the agency to promptly implement the recommendations included 

in this report will result in continued, long-term challenges and weaknesses that will 

increasingly have an adverse impact on agency employee morale. 

The OIG identified 9 findings in three areas of the Office of Human Resources: 1) 

Performance Management; 2) Technology & Automation; and 3) Office Operations. The 

detailed findings along with 26 recommendations for improvement were provided to 

management for discussion prior to the release of this report and are included in the 

Findings and Recommendations section beginning on page 14. Management generally 

agreed with 25 of 26 recommendations, and disagreed with one, with the intent to 

implement an alternative corrective action. 

Management disagreed with recommendation three (3), on page 16, which is for FEC to 

“pursue a detail or other type of agreement with another federal agency to bring on board, 

on a temporary basis, a seasoned HR professional...” Instead, the FEC has brought on an 

SES candidate from another agency temporarily who has experience with process reengineering and a leadership background. 

5 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

OBJECTIVES, SCOPE & METHODOLOGY 

Objectives 

The Office of Inspector General’s (OIG) overall objective for conducting the Audit of the 

Office of Human Resources was to determine the efficiency and effectiveness of customer 

service in the Office of Human Resources (OHR). This would include sub-objectives to 

identify: 

	 if OHR’s processes directly related to customer service are operating effectively; 

	 whether OHR has adequate policies that are up-to-date to govern HR related 

functions; 

	 if the office is effectively utilizing technology and other HR automation tools, and 

identify areas to improve efficiency and effectiveness; and 

	 if additional policies or policy improvements/updates are needed. 

Scope 

To avoid duplication of work due to a planned review of the FEC’s OHR by the Office of 

Personnel Management (OPM) in the summer of 2013, the OIG structured the scope of 

this audit to focus more on areas related to OHR’s day-to-day operations and the structure 

of the office as a whole. The audit considered relevant information related to OHR 

beginning in fiscal year (FY) 2009 to present. Detailed audit testing was based on OHR 

activity during FYs 2011 and 2012. 

Methodology 

The OIG conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based on our audit 

objectives. In order to meet our audit objectives, we used interviews, inquiries, 

observations, and judgmental sampling for items selected for detailed testing. Audit 

work performed includes the following: 

6 
Audit of the FEC’s Office of Human Resources OIG-12-05 

Overall Customer Service 

	 Reviewed the results of OHR’s annual customer service survey from FY 

2011. 

	 Developed an OIG survey related to OHR’s customer service and provided 

the survey to all FEC staff. Evaluated the results of the survey to identify if 

improvements have been achieved. Survey results were used to determine 

which HR areas to focus detail audit testing. 

Policies and Procedures 

	 Assessed the status (i.e. draft, outdated etc.) of existing policies and standard 

operating procedures (SOP) of the HR office. 

	 Reviewed the policies directly related to the audit areas under review and 

performed walkthroughs of the related functions. 

Performance Management 

	 Reviewed the results and findings of HR’s Workforce Gap Analysis to assess 

HR’s progress in addressing any identified gaps or needed improvements. 

	 Reviewed HR’s FY 2011 performance appraisal process for the HR staff to 

determine compliance with the FEC’s performance management policy which 

included review of each staff member’s annual performance appraisal for 

2011 - 2012. 

	 Conducted interviews with HR staff regarding their specific roles, 

responsibilities, and their personal perspective of the effectiveness of the HR 

office. Results of interviews were utilized in our overall assessment of 

customer service and the effectiveness of HR’s corrective actions to address 

the workforce gap analysis. 

Automation and Technology 

	 Assessed OHR’s use of available technology to include the Federal Human 

Resource (FHR) Navigator (“FHR” is an automated tool to assist federal 

agencies with HR functions). Also, verified status of FHR modules 

implemented during audit testing. 

	 Assessed how OHR is utilizing their FECNet intranet page. Also, reviewed 

the OHR’s FECNet intranet page to determine if timely and current 

information is included. 

7 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

OHR Operations 

	 Reviewed and assessed the HR On Demand process (internal email system 

and a database created to receive and track employee inquiries) to determine 

effectiveness. OIG obtained a report of all inquiries received from January 

2012 to November 2012 and judgmentally selected 13 inquiries from 

employees that appeared to have sent multiple requests related to the same 

subject. OIG obtained the related emails and other supporting documentation 

to identify if HR is resolving issues and responding to customer requests in a 

reasonable amount of time. 

	 To determine compliance with FEC’s hiring and recruitment policies and 

procedures, OIG judgmentally selected 10 vacancy announcements (to ensure 

a cross section of different division hires) and reviewed recruitment files and 

other supporting documentation maintained by the OHR and the Office of 

General Counsel. 

8 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

 BACKGROUND 

During the first two quarters of FY 2010, OHR consisted of nine permanent full-time 

employees (FTE) that included, an HR Director, a Supervisory HR Specialist, five HR 

Specialists, and two HR Assistants. In February 2010, the Office of Human Resources 

(OHR) experienced approximately a 50% turnover rate in staff, including the Director of 

Human Resources. In April 2010, the FEC selected a new Director of Human Resources. 

Since fiscal year (FY) 2010, several contractors and new employees have been hired to 

fill the vacancies in OHR due to the large turnover. 

In September 2010, the OHR purchased the Federal Human Resource (FHR) Navigator 

system2

 to assist with automating HR functions and processes. To date, the FEC has 

spent $33,030 on the FHR system for all modules. However, after procuring the system 

in 2010, OHR discovered that the FHR system could not be integrated with FEC’s 

current payroll system. Although all of the modules were not impacted by the lack of 

integration, only one (1) FHR module purchased was implemented and the remaining 

five (5) modules were not used. 

In June 2011, OHR contracted with Suntiva, LLC to perform a workforce competency 

gap analysis for OHR at a cost of $28,984. The contract not only provided OHR with an 

assessment of their office, but also a leadership coaching program specifically for the 

Director of HR. The analysis included team building sessions, interviews, and 

competency skill assessments for the OHR staff. Self assessments were completed by the 

entire HR office for 20 HR technical competency areas. In turn, the Director of HR also 

provided a management assessment for all HR staff, and a supervisory assessment by the 

Deputy Staff Director for Management Administration was completed for the HR 

Director. The self assessment ratings were compared to the management ratings to 

identify any existing competency gaps. The contractors provided OHR with a detailed 

report of issues identified from their analysis along with recommendations for 

improvement. The contractors noted skill gaps from the assessments for the HR staff as 

well as the HR Director. Particularly, there were large competency gaps for some staff in 

their designated area(s) of work, and a skills gap in 1/33

 of the competency areas for the 

Director of HR. 

2 A software suite that provides an integrated enterprise solution for multiple human resource functions, 

including retirement benefit calculation and processing, personnel forms and case management, onboarding management, personnel action processing, and financial planning.
 3

 The 1/3 skills gap calculation was determined and documented by Suntiva, LLC in their final analysis 

documentation for the workforce gap analysis. 

9
 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

According to the Code of Federal Regulations4, heads of agencies or their designees(s) 

are required to: 

 Identify workforce competency gaps; 

 Include strategies for closing competency gaps; and 

 Conduct periodic reviews of individual employee's training needs as related to 

program objectives. 

To assist with the Suntiva noted deficiencies and competency gaps, OHR implemented 

several corrective actions. In October 2011, OHR piloted a new organizational structure 

that divided their office into two teams, and reclassified two HR Specialists to 

supervisory positions to manage the two teams. The reorganization of the HR office 

became official in April 2012, see diagram below. 

Director of 

Human Resources 

Supervisory HR Specialist: 

HR Staffing, Systems 

Accountability Operations 

(Team A) 

Supervisory HR Specialist: 

Benefits, Compensation, and 

Worklife Operations Team 

(Team B) 

HR Specialist 

(2) Staff 

HR Assistant 

(1) Staff 

HR Specialist 

(1) Staff 

HR Assistant 

(1) Staff 

In addition to the change of office structure, two OHR employees resigned: a 

Supervisory HR Specialist (Team A), and a HR Specialist position (Team A). The HR 

Specialist separated from the agency in May 2012 and the Supervisory HR Specialist in 

November 2012. The FEC immediately placed a supervisor from another FEC office on 

a 120 day detail assignment to OHR to be the Acting Supervisory HR Specialist for Team 

A (note this person assumed the position on a permanent basis in May 2013, before the 

issuance of this report). 

During the same time of the restructuring (October 2011), OHR launched HR On 

Demand to improve OHR’s response time to inquiries from their customers. 

4 5 C.F.R. § 410.201 (2011); Executive Order 11348, 3 C.F.R. 639 (1966-1970). 

10 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

The HR On Demand system consists of an HR On Demand internal email address and a 

Microsoft Access database created to provide a centralized process to receive and track 

employee inquiries. 

After the start of the audit, the OIG learned that in May 2012, OHR evaluated the 

feasibility of procuring an HR Line of Business (LOB)5

. The cost benefit analysis6 

performed by the Deputy Staff Director for Management and Administration determined 

that the purchase of an HRLOB would not be a feasible option at that time based on the 

initial cost estimate provided by the vendor. However, after further cost analysis from 

the vendor based on clarifying information provided by the FEC, the initial estimated cost 

for the LOB was significantly reduced. According to the Deputy Staff Director for 

Management and Administration, at the time the revised estimate was provided to FEC, 

budgetary resources for the fiscal year had already been re-allocated and the LOB was 

not pursued. Due to the inability to procure the HRLOB in FY 2012, OHR began to 

implement FHR modules purchased in September 2010 that were not being used. From 

September 2010 to February 2013, the FEC spent $13,280 on the FHR modules that were 

not being used. As of February 2013, one module initially purchased has been placed in 

pilot mode, two have not been fully implemented, and OHR purchased the Recruitment 

module in October 2012, which is also in pilot testing. 

5

 HR Line of Business: Transitions an agency’s entire HR office or specific HR function(s) to another 

government agency to help automate and streamline the federal government support functions while freeing 

agency resources to focus on their core business. 

6

 OIG reviewed the LOB cost benefit analysis for informational purposes only. We did not verify the 

accuracy of the data provided. 

11 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

CUSTOMER SERVICE SURVEY RESULTS
 

OHR conducted a customer service survey in 2011 to receive feedback from FEC staff. 

The results from OHR’s 2011 survey were provided to the OIG for review for the audit. 

The OIG noted issues related to OHR’s timeliness in completing tasks, data accuracy, 

and responsiveness to customers. To assess OHR’s progress in addressing these issues, 

the OIG conducted an anonymous employee survey related to customer service in 

September 2012. 

Out of 344 FEC employees, the OIG received 116 responses to the survey, a response 

rate of 34%. Some key results of the survey are listed in the table below: 

Office of Inspector General’s 2012 OHR Survey Results 

Survey Questions Very 

Satisfied 

Somewhat 

Satisfied 

Neither 

Satisfied 

nor 

Dissatisfied 

Somewhat 

Dissatisfied 

Very 

Dissatisfied 

How satisfied were you 

with the timeliness of 

response received from 

OHR? 

21% 16% 10% 23% 30% 

How satisfied were you 

with the accuracy of the 

info received from OHR? 

23% 21% 21% 13% 22% 

Significantly 

Improved 

Slightly 

Improved 

Stayed the 

Same 

Slightly 

Declined 

Significantly 

Declined 

In the past 12 months, 

OHR customer service 

has 

7% 23% 58% 9% 3% 

Strongly 

Agree 

Somewhat 

Agree 

Neither 

Agree nor 

Disagree 

Somewhat 

Disagree 

Strongly 

Disagree 

Overall, the OHR staff is 

knowledgeable and 

helpful 

17% 17% 22% 28% 16% 

In addition to the survey questions, the OIG included comment boxes throughout the 

survey to give employees the opportunity to provide additional information and/or give 

more explanations for survey responses. The majority of the comments provided by 

employees focused on OHR’s inability to resolve employee issues and/or respond to 

12 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

inquiries in a timely manner. The OIG noted that these problems were very similar to the 

survey responses OHR received for their 2011 customer service survey. Some examples 

of responses received are listed below: 

	 “I have made several attempts to contact Human Resources via email regarding 

various issues over the past year, and despite my best efforts, sometimes months will 

go by without HR responding in any way. If they do respond, it is sometimes only to 

say they have received the request, but then months will pass, and they do not take 

any action on the request.” 

	 “I felt like it took too many tries to get the info I needed from them, had to keep doing 

follow up.” 

	 “Very slow to respond and once response was received, e-mails were incomplete and 

did not fully inform me of the status or next steps. I had to continue to ask question, 

follow-up and even physically visit the office.” 

	 “They appear to be overworked and slow to respond. When they do respond, they can 

be very helpful.” 

 “Some staff members are extremely helpful, knowledgeable and responsive.” 

 “The HR office may be in need of Leadership. I think the entire staff is very helpful 

and works hard but its like they are lacking leadership that will help them have one of 

the best HR shops in government.” 

At the end of the survey, OIG gave employees the option to request a meeting with OIG 

to further discuss the survey. As a result, OIG met with five (5) employees to discuss 

OHR customer service, and the common issues communicated to the OIG related to (1) 

OHR communicating incorrect information to internal candidates during the hiring 

process; and (2) challenges with the on-boarding process for contractors. As a result of 

the information gathered from the survey, the hiring process and HR On Demand were 

selected for detailed testing. 

Overall, OIG concludes that despite efforts by OHR management during the past 18 

months (e.g. restructuring the office, implementing HR On Demand, completing the 

workforce gap analysis), customer service has not improved. See the findings and 

recommendations beginning on page 14 for details. 

13 
 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

FINDINGS AND RECOMMENDATIONS
 

Based on the audit work performed covering OHR activity during fiscal years 2011 and 

2012, OIG has determined that there are many factors that are contributing to why 

customer service in the Office of Human Resources is unsatisfactory and is not 

improving. We have grouped our findings and recommendations into three main 

categories: (1) performance management; (2) technology and automation; and (3) office 

operations. 

I. Performance Management 

OIG reviewed the results of the OHR’s workforce competency gap analysis (gap 

analysis) completed in September 2011, along with corrective actions taken by OHR 

management to address the issues and findings identified, and assessed the progress made 

by OHR. Based on this review, OIG determined that most of the recommendations have 

not been fully implemented and/or actions taken by OHR have not been effective or 

sufficient to address the issues identified, which are described in A-C below. According 

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

Responsibility for Internal Control, Section V (Correcting Internal Control Deficiencies), 

“...Agency managers are responsible for taking timely and effective action to correct 

deficiencies... correcting deficiencies is an integral part of management accountability 

and must be considered a priority by the agency...” 

A. Ineffective Leadership 

OHR’s gap analysis report cited leadership as an area needing improvement. Specifically, 

the report stated the Director of HR needed to improve on: responsiveness, finding the 

right balance of oversight (i.e. not micromanaging); HR skills; strategic thinking; and 

trusting the team’s (HR staff) competence. The gap analysis also determined that OHR 

management is not effectively communicating expectations, setting priorities, or giving 

clear direction to the OHR staff, and that OHR employee morale is low. 

OIG notes that the Director of HR, who was hired in April 2010, had no previous 

supervisory/leadership experience. Also, the Director of HR operated in this supervisory 

role for 14 months before receiving any formal management/supervisory training from 

the Director’s supervisor at the time. To address these issues and rebuild the HR staff, 

the current Deputy Staff Director for Management and Administration held a team 

building session in May 2011 and an action plan was developed based on the results. 

The Director of HR was subsequently provided a management coach and instituted 

weekly staff meetings to better communicate with OHR staff. 

14 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Based on the OIG’s audit testing and OIG interviews of OHR staff members (excluding 

the Director of HR) conducted in February 2013, we acknowledge that the Director of 

OHR has put forth significant efforts to improve OHR. However, most of the initiatives 

prior to this audit had not been effective at improving the office and motivating the staff. 

For example, four (4) of six (6) OHR employees interviewed by the OIG indicated that 

employee morale in the OHR continues to be low, 20 months after the gap analysis 

concluded this is an issue. 

The interviews also indicated that there is still a breakdown in communication between 

OHR management and their staff. For example, OHR Management stated that staff roles 

and responsibilities have been clearly communicated and are reiterated during staff 

meetings. However, staff roles and responsibilities are not clearly understood by some 

OHR staff members. 

Ineffective leadership and inadequate performance management are the major factors 

causing OHR customer service problems, and are also having an adverse effect on OHR 

employee morale. According to 5 C.F.R. § 430.102 (2011)(Performance Management), 

Agency management and its employees are responsible for ensuring effective processes 

and procedures are in place to accomplish agency mission and goals. As Human 

Resources is a critical element of any agency, it is imperative that OHR has strong 

leadership to improve. The likelihood of successfully implementing processes and 

controls required to significantly improve customer service levels and to achieve the 

goals of the office and mission of the agency will not be achieved without effective 

leadership. 

Recommendation #1 

OHR Management should reevaluate methods used to communicate expectations, to give 

feedback on staff performance, and to promote and address feedback from OHR staff in 

order to identify meaningful solutions to improve the organization. Then, OHR 

Management should make it a priority to implement corrective actions. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management to 

ensure that it fully addresses this recommendation. 

15 
Audit of the FEC’s Office of Human Resources OIG-12-05 

Recommendation #2 

OHR Management should make a clear distinction between the roles of the Director of 

OHR and the two supervisors who are responsible for supervising their subordinates on a 

daily basis. In addition, the roles and responsibilities for each OHR member should be 

clearly communicated. 

Management Response: 

Office of Human Resource Management (Management) agrees with this
 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management to 

ensure that it fully addresses this recommendation. 

Recommendation #3 

The FEC should pursue a detail or other type of agreement with another federal agency to 

bring on board, no less than six months, a seasoned HR professional with significant 

experience in federal government HR operations, management and customer service, to 

provide clear direction, training, and focus to improve the HR office. 

Management Response: 

Office of Human Resource Management (Management) disagrees with this 

recommendation. However, alternate corrective action has been taken. In this 

sequestered budgetary environment, it is unlikely that a seasoned federal official 

trained specifically in HR matters will leave its agency to help the FEC, at no cost to 

the Commission. However, Management was successful in creating a win-win 

situation by bringing a SES candidate (at no cost to the Commission) to help with the 

issues as part of his development assignments. In addition, the Deputy Staff Director 

for Management and Administration assumed the managerial role of the OHR for the 

months of May and June and conducted team meetings on a weekly basis in order to 

strengthen team morale, staff collaboration, and improving customer service. The 

effectiveness of these recent initiatives will be re-evaluated in September 2013. 

OIG Comment: 

Based on OIG’s review of the SES candidate’s background, past experience, and 

objectives for this assignment, it appears that this person could be helpful in 

providing valuable guidance and help to OHR. We look forward to reviewing 

16 
Audit of the FEC’s Office of Human Resources OIG-12-05 

the results and recommendations from this assignment to determine if desired results 

have been achieved. 

B. Inadequate Organizational Structure 

Based on recommendations from the gap analysis, OHR management reorganized the 

office structure in April 2012 that divided their office into two teams, and promoted two 

of the HR Specialists to supervisory positions (Supervisory HR Specialist) to lead each 

team. Shortly after the new structure was implemented, one of the HR Specialists 

assigned to one of the teams resigned from the FEC. OHR did not receive approval to 

replace this position; rather, the tasks assigned for this position have been distributed to 

the remaining OHR staff members and a contractor. OIG notes that no permanent 

solution has been established for this position. Based on the results from OHR’s team 

building session and employee interviews conducted by OIG, OHR staff members feel 

“overextended” and some staff members believe that the new organizational structure has 

created uneven and/or improper distribution of work. In addition, no formal designated 

back-ups have been established for each task/position to ensure proper office coverage in 

the event an employee is out of the office, or resigns. 

Based on OMB guidance on internal controls (Circular A-123), “...Within the 

organizational structure, management must clearly: define areas of authority and 

responsibility; appropriately delegate the authority and responsibility throughout the 

agency;...establish a suitable hierarchy for reporting;..." Not properly managing OHR 

resources, such as allowing sufficient time to address employee inquiries, increases the 

risk that personnel related issues are not resolved timely, which will have a direct impact 

on OHR’s customer service. In addition, if management does not reevaluate the new 

structure in light of these unforeseen circumstances, the intended benefits of the 

reorganization may not be fully realized. 

Recommendation #4 

OHR Management should reassess the new OHR office structure to determine if there is 

a need to adjust the functions/tasks between the two teams, and/or individual team 

members, in order to better balance the workload amongst the teams/team members. 

Management Response: 

Office of Human Resource Management agrees with this recommendation. Although 

Management already started to reassess the existing structure, roles, and 

responsibilities it is important to note that the OHR restructuring provided a better 

structure than it had before by engaging staff in the OHR office design. 

17 
  

Audit of the FEC’s Office of Human Resources OIG-12-05 

The OHR engaged in several team building sessions where roles and responsibilities 

were repeatedly clarified and discussed. The sessions also focused on setting priorities 

and improving customer service. 

OIG Comment: 

The OIG agrees that the OHR reorganization was better than the existing structure at 

the time and that Management could not have foreseen that individuals in critical roles 

would leave the agency. In light of the current situation in OHR, we are pleased that 

Management has begun to reevaluate if adjustments are warranted. The OIG looks 

forward to reviewing corrective actions to ensure that it fully addresses this 

recommendation. 

C. Non-compliance with FEC’s Performance Plan and Appraisal Policy 

The gap analysis reported that staff roles were not clearly identified. 5 C.F.R. § 

430.206(b)(3) states, ” An appraisal program shall require that each employee be 

covered by an appropriate written or otherwise recorded, performance plan based on 

work assignments and responsibilities....” The OIG performed detailed testing of 

OHR’s performance appraisal process for the 2011-2012 performance period. Based 

on testing, we determined that OHR did not comply with their current policy and 

procedures for the annual performance appraisal process, as follows: 

Performance plans: 

 A performance plan outlines the employee goals to be accomplished during the plan 

year and establishes agreed upon expectations that the employee will be evaluated 

against. According to the instructions for FEC Performance Plan and Appraisal 

Record for Non-Bargaining Unit Non-Supervisory Employees (performance process), 

which are distributed by the Director of HR each plan year, the employee and 

supervisor (reviewer) should jointly develop annual objectives and complete the 

employees’ performance plan. The employee, supervisor, and second level supervisor 

are required to sign the plan. Three (3) of six (6) HR staff members did not have a 

detailed performance plan for 2011-2012, and 3 of 6 HR staff members who had 

performance plans had no required second level supervisory approval signature. 

Not having documented performance plans increases the risk that OHR staff may not 

have a clear understanding of their goals and objectives (day-to-day tasks, back-up 

assistance to other team members, training, special projects, etc.). Documented 

performance plans are important tools not only for the employee, but management 

also. They provide shared expectations for the coming performance year and 

18 
Audit of the FEC’s Office of Human Resources OIG-12-05 

enable the employee to know what is expected of them and provides management with 

a guide to assist the employee in reaching their goals and correcting problems with 

performance at an earlier stage.

 Mid-year reviews/annual performance appraisals: 

The FEC’s performance process states that mid-year reviews are mandatory for all 

non-bargaining unit employees (this would include all OHR staff) and they are due by 

January 30 of each year. For the mid-year review the employee should complete “key 

accomplishments” and for the annual performance appraisal process, the employee 

must prepare a self-assessment. The reviewer must meet with the employee to provide 

performance feedback and the discussion must be documented in a mid-year review 

form and annual performance appraisal form. Then, the form must be signed by both 

the employee and the reviewer. Based on OIG testing, we found the following 

exceptions: 

	 Mid- year reviews were not timely for three OHR staff members. One staff 

member’s mid-year review was not completed until May (four months late), and 

one was not completed until June which is the last month of the performance year. 

Also, there was no evidence to support that one staff member received a mid-year 

review. 

	 Mid-year reviews were not adequately documented for all HR staff members, 

including the Director of HR. The mid-year review form only included the initials 

of the staff and supervisor. There was not a written summary of the review or what 

was discussed. 

 There was no evidence to support that HR members completed mid-year self 

assessments (evaluations). 

 Only one HR employee had evidence of a year-end self assessment. 

 Failing to comply with the required performance appraisal process increases the risk 

that: 

	 All HR staff may not have documented performance plans to provide a clear 

understanding of their goals and objectives (day-to-day tasks, assistance to other 

team members, training, special projects, etc.); 

 Employees may not receive constructive and timely feedback on performance; 

 Supervisors and management may fail to understand the challenges and obstacles 

that prevent OHR staff from achieving their goals and objectives; 

 Low or poor performance is not corrected/addressed in a timely manner; and 

19 
Audit of the FEC’s Office of Human Resources OIG-12-05 

	 Disparity between the employees’ and supervisors’/management’s perception of 

employee performance could impact employee morale. 

In response to this testing, OHR management stated that their general practice was to 

only orally communicate the details of the mid-year reviews, and only sign the mid-year 

review form to indicate that it was done. OHR management stated they were unaware 

that the policy required mid-year reviews to be documented in writing. However, the 

instructions distributed FEC-wide by the Director of HR clearly include this requirement. 

The OIG’s findings in this area are especially troubling because one of the OHR’s 

responsibilities for the agency is to oversee the performance management process for all 

employees, and OHR was not following this same process for their own office. The 

OHR’s weaknesses in this area and lack of understanding of their own process are 

noteworthy and concerning. 

Recommendation #5 

Ensure all HR staff has detailed performance plans that include their specific tasks and 

goals for their HR position. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

Recommendation #6 

Ensure all performance plans are properly reviewed and approved by the first and second 

line supervisors in accordance with the annual performance appraisal process. 

Management Response: 

Office of Human Resource Management (Management) agrees with this
 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

20 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Recommendation #7 

Ensure that all staff completes the required self assessment for the mid-year and year-end 

performance review. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

Recommendation #8 

Ensure that the mid-year review discussion is documented and signed off by the 

employee and supervisor in accordance with the annual performance appraisal process. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

Recommendation #9 

Ensure all required sections of the annual performance appraisal process are completed, 

discussed and properly reviewed by the due dates specified in the performance appraisal 

template. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by Management 

to ensure that it fully addresses this recommendation. 

21 
Audit of the FEC’s Office of Human Resources OIG-12-05 

II. Technology & Automation 

The Office of Human Resources has not utilized available technology and automated 

tools to help streamline OHR processes and improve internal controls. 

A. Ineffective Use of the FHR System 

OHR purchased the Federal Human Resources (FHR) Navigator System in September 

2010 to assist with automating and integrating human resources processes. The FHR is 

a software package used by several government agency HR offices. OHR initially 

purchased six modules but has only fully implemented one module 

(Retirement/Separation) since acquiring the system approximately 2 1⁄2 years ago. 

According to OHR Management, the main reason why all modules were not 

implemented upon purchase is because it was determined after the purchase that the 

FHR system could not be integrated with FEC’s current payroll system. OHR 

Management decided to put the implementation of the other five FHR modules on 

hold and began to evaluate the feasibility of an HR Line of Business (LOB) as an 

alternate solution. The objective of an HR LOB is to transition an agency’s entire HR 

office or specific HR function(s) to another government agency to help automate and 

streamline the support functions while freeing agency resources to focus on their core 

business. The LOB analysis was completed in May 2012 and was determined not to be 

a cost effective option based on the initial cost of the LOB received by the agency. 

The lack of effective planning by OHR prior to the purchase of the FHR resulted in 

wasted funds of $13,280, the cost of the modules not being used for the period from 

September 2010 to February 2013. According to OMB Circular A-123, 

Management’s Responsibility for Internal Control, “...The proper stewardship of 

Federal resources is an essential responsibility of agency managers and staff. Federal 

employees must ensure that ... Federal resources are used efficiently and effectively to 

achieve desired objectives. Programs must operate and resources must be used ... 

with minimal potential for waste....” 

As a result of improper planning, many OHR processes and procedures that could 

have been automated in 2010 are currently still manual or not available. Therefore, 

the OHR is not operating as efficiently as possible, which in turn is having an adverse 

effect on customer service. OIG notes that OHR has initiated pilot testing for one (1) 

of the unused modules purchased in September 2010, and the recruitment module 

purchased in 2012, immediately after OIG inquired about the status of implementing 

FHR. In addition, an interim solution to the lack of integration with 

22 
Audit of the FEC’s Office of Human Resources OIG-12-05 

FEC’s payroll system was implemented, and data is now uploaded to FHR twice a 

month. However, the data uploaded to FHR is not “real time” (one month lag). Once 

the FHR modules are fully implemented, controls and efficiencies over the applicable 

processes are expected to improve. This in turn should allow HR more time to 

concentrate on responding to and resolving employee inquiries. 

Recommendation #10 

Fully implement the FHR modules to the maximum extent feasible to improve the 

effectiveness and efficiency of the OHR by September 2013. 

Management Response: 

Office of Human Resource Management (Management) partially agrees with this 

recommendation. OHR is on the way to implement the FHR modules that are 

already purchased; however, currently there are some technical issues for the full 

implementation that require additional funding. The FHR modules’ 

implementation will be delivered based on availability of funds and priorities of 

staff members’ assignments. At this point, and before assessment of the OHR 

structure, priorities, and available resources; management cannot commit to the 

September 2013 deadline for full implementation. 

OIG Comment: 

The OIG believes management’s response will address this recommendation. We 

look forward to reviewing the automated processes once FHR modules have been 

fully implemented. 

Recommendation #11 

Establish an agreement with the Information Technology Division (ITD) to have an 

ITD staff member(s) assigned to the HR office to aid in any technical issues with 

project implementation. 

Management Response: 

Office of Human Resource Management (Management) partially agrees with this 

recommendation. Currently, OCIO staff members are assisting HR Office in 

technical issues and project implementation; however, OCIO is unable to provide 

dedicated staff member, due to lack of resources. Also, each project may require 

different type of OCIO expertise and different OCIO staff member may be 

assigned to different HR projects. 

23 
Audit of the FEC’s Office of Human Resources OIG-12-05 

OIG Comment: 

The OIG agrees that corrective actions by management will address the current 

OHR projects to implement FHR modules. However, OIG believes that 

Management should consider a formal agreement with ITD to ensure OHR’s 

future technical needs are met; this would not require a dedicated ITD staff 

member. 

Recommendation #12 

Develop and implement a template planning document guide prior to a) purchasing a 

new system; b) implementing/revamping a system (internal or external); or c) 

acquiring services (service provider, HRLOB, interagency agreements, etc.) that 

details: 

a.	 the needs of the office; 

b.	 services/benefits that will be received (ex: fully meets objectives, cost savings, 

etc.); 

c.	 any affects (positive/negative) to other offices that could be impacted or 

benefit from consultation; 

d.	 costs to the agency, both start-up and ongoing; 

e.	 alternative solutions (if any); 

f.	 implementation dates/milestones; and 

g.	 HR and other staff responsible for oversight and implementation. 

Management Response: 

Office of Human Resource Management (Management) agrees with this
 

recommendation.
 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

B. OHR is not Properly Utilizing and Maintaining their FECNet Page 

Agency intranet websites, such as the FEC’s ‘FECNet,’ that include individual 

division/office web pages can be an effective communication tool and use of 

technology. Specifically for OHR, an office intranet site can be a great tool for 

customer service in providing timely information to their customers. It can also help 

with streamlining processes and allowing easy access to important documents (e.g. 

central repository for policies and procedures, access to forms/requests, etc.). 

24 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Based on audit work performed, OIG determined that OHR’s intranet pages are 

outdated and have not been updated since April 2012. Per OMB Circular A-123, 

Management’s Responsibility for Internal Control, Section II, Standards: D. 

Information and Communications, “...Information should be communicated to 

relevant personnel at all levels within an organization. The information should be 

relevant, reliable, and timely...” 

During audit testing, the OIG noted the following issues with OHR’s FECNet pages: 

 The office organizational chart has not been updated to reflect the staff 

reorganization that became effective in April 2012; 

	 Five former employees, who have been separated from the agency for at least 

three years, are included on the OHR’s organization chart posted on HR's FECNet 

page; 

	 HR's “Contact Us” page has not been updated to reflect current employees; 

	 The "Welcome Message" from the HR Director is signed by the former Director 

of HR who separated from the agency in February 2010. However, the “Contact 

Us” page did list the current Director of HR. 

 Information regarding FEC Ethics Officials are former employees who separated 

from the FEC in May 2011 and June 2012; and 

 Several toolbar tabs are not properly linked to information or do not work. 

(Training, What’s New, etc.). 

According to the Director of HR, the OHR FECNet page(s) were corrupted in April 

2012 and the reconstruction of the FECNet page has not been a priority. The OIG 

believes that the failure to properly utilize and ensure the OHR’s FECNet information 

is relevant and timely increases the risk that: 

 FEC staff are unaware of who to contact in HR for specific needs; 

 FEC employees are relying on outdated OHR information; and 

 Unreliable information for basic forms and policies may increase the number of 

inquires received by OHR and decrease staff productivity. 

In addition, OIG concludes that the consistent lack of accuracy and timeliness of 

information provided by OHR is contributing to the FEC staff’s negative perception 

and lack of confidence in the HR office as reflected in OHR’s annual customer 

service surveys. 

25 
Audit of the FEC’s Office of Human Resources OIG-12-05 

Recommendation #13 

Identify one HR staff member who will be the owner/manager of the content for HR's 

FECNet page and revise their annual performance plan to reflect their duties and 

responsibilities for maintaining the content of HR's FECNet page. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. OHR had an “owner” of FECNet page who left FEC and the 

position was not backfilled. However, OHR will be assigning a new content 

manager who will act as a team lead to ensure HR’s FECNet pages are updated 

and revised periodically. 

OIG Comment: 

The OIG agrees that corrective actions planned by Management should address 

this recommendation. 

Recommendation #14 

Update all content on HR's FECNet page by September 2013 to ensure all 

information is accurate, up-to-date, and relevant. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by Management 

to ensure that it fully addresses this recommendation. 

Recommendation #15 

Establish an agreement with ITD to have an ITD staff member(s) assigned to the 

OHR to aid in any technical issues with developing HR’s FECNet page. 

Management Response: 

Office of Human Resource Management (Management) partially agrees with this 

recommendation. ITD staff members have always been very responsive in 

resolving technical issues for the HR’s FECNet page. ITD does not have the 

resources to provide a dedicated assigned ITD staff to HR office. However, as 

problems rise ITD and OHR will work together to solve them as soon as possible, 

26 
Audit of the FEC’s Office of Human Resources OIG-12-05 

knowing that HR FECNet page is important tool for HR communications with its 

customers. 

OIG Comment: 

The OIG agrees that corrective actions planned by management should address 

the current issues with OHR’s FECNet page(s). However, OIG believes that 

Management should consider a formal agreement with ITD to ensure OHR’s 

future technical needs are met; a dedicated ITD staff member would not be 

required. 

C. Electronic Fingerprint Scheduling Process not Fully Implemented 

Currently, OHR staff is manually scheduling and tracking fingerprints for contractors 

and new hires when an automated process is available to streamline the process and 

provide a central place for storing fingerprint appointments. Fingerprints are required 

as part of the background check process. OIG notes that a former OHR employee set 

up an electronic fingerprint scheduling process via Lotus Notes, the FEC’s email 

program, but the available tool and process has not been documented, fully 

implemented or communicated to contracting officer representatives (COR) who are 

responsible for coordinating with OHR to bring contractors onboard that need 

fingerprints recorded. According to OMB Circular A-123, Management’s 

Responsibility for Internal Controls, management should ensure adequate control 

activities are implemented to include “policies, procedures and mechanisms in place to 

help ensure that agency objectives are met...” In addition, “...information should be 

communicated to relevant personnel at all levels within an organization...” 

Neglecting to use the Lotus Notes process for scheduling fingerprints decreases the 

productivity of HR staff. Not using a centralized place for documenting fingerprint 

appointments that is visible to multiple OHR staff reduces the likelihood that an OHR 

staff member is always available for scheduled appointments. This in turn increases 

the risk that fingerprint appointments must be cancelled and rescheduled when there is 

a lack of coverage in OHR. 

Recommendation #16 

Fully implement the electronic fingerprint scheduling process and notify CORs that it 

is available. 

27 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by Management 

to ensure that it fully addresses this recommendation. 

Recommendation #17 

Develop a policy and procedures that documents and instructs how to use the 

electronic fingerprint scheduling tool. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by Management 

to ensure that it fully addresses this recommendation. 

III. Office Operations 

Office operations relates to the day-to-day functions of the OHR to include hiring, 

personnel actions, retirement, etc. Overall, OIG determined that OHR processes are 

not operating effectively because (1) adequate internal controls are not in place; and 

(2) policies and procedures are outdated, not formally documented, or not enforced. 

Details of findings are described below: 

A. HR On Demand Process is Ineffective 

Based on the OIG’s OHR customer service survey conducted in September 2012, 

53% of the employees who responded to the survey stated that they were somewhat 

dissatisfied or very dissatisfied with the timeliness of responses received from OHR. 

In addition, there were 40 comments received from 116 employees who completed 

the survey that specifically talked about the lack of timely responses from the Office 

of Human Resources. 

The HR On Demand system and process, which is a centralized employee inquiry 

receipt and tracking system, was implemented to improve OHR’s response time to 

28 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

employee requests/inquiries, was not properly designed and implemented. Based on 

OIG inquiries and observations, we noted the following inefficient use of the database 

is negatively impacting customer service. 

 All HR On Demand inquiries received via email must also be manually entered 

into the customer service access database to track and monitor employee 

inquiries/requests. This is not an efficient use of OHR resources. 

	 HR On Demand is also used to track other OHR tasks/assignments, which reduces 

the effectiveness of monitoring the status of outstanding inquiries. OIG notes that 

the original purpose of HR On Demand was to improve OHR response time to 

employee requests. 

	 HR On Demand inquiries related to personnel actions are entered into the HR on 

Demand customer service access database as well as logged into a Microsoft 

Excel spreadsheet specifically used to track personnel actions. This is a 

duplication of effort and inefficient. 

OIG also sampled 13 inquiries received via the HR On Demand email system 

between January and November 2012 and reviewed the OHR’s response to the 

inquiries for timeliness. Test results determined that seven (7) of 13 (54%) inquiries 

sampled were not resolved timely. Of the 7 inquiries that were not resolved timely: 

 3 inquiries required follow-up with OHR by the FEC employee because a 

response was never provided to the initial request. 

	 4 inquiries required follow-up with OHR on multiple occasions because the initial 

request was not adequately resolved by OHR, or OHR failed to work with other 

offices/divisions to sufficiently resolve customer issues. 

During testing, OIG determined that many HR On Demand inquiries are related to 

personnel actions. Based on the OIG’s review of three (3) of the seven (7) inquiries 

related to personnel actions, we identified that the Director of HR is not consistently 

approving Request for Personnel Actions Forms (SF-52s) in a timely manner. In 

addition, one of these SF-52s was approved after it was processed in the National 

Finance Center (NFC) payroll system, which is not in compliance with policy and 

procedures related to personnel actions. Personnel actions should be approved by the 

HR Director prior to being processed and effective in the NFC system. 

According to OMB Circular A-123, Management’s Responsibility for Internal 

Control “... As agencies develop and execute strategies for implementing or 

reengineering agency programs and operations, they should design management 

structures that help ensure accountability for results.” 

29 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

An OHR email announcement, dated October 31, 2011, to introduce the HR On 

Demand process to FEC staff stated that requestors should “...receive an 

acknowledgement the same day and generally a response within 24 hours...” 

There are several factors that contributed to the ineffective implementation of HR on 

Demand: 

1.	 The system used to receive employee inquiries (HR On Demand mailbox account 

via Lotus Notes) was not integrated with the Microsoft Access database created to 

track and monitor employee inquiries. As a result, there is a lag time between 

when inquiries are received in the HR On Demand email system and when they 

are logged and updated in the database. 

2.	 Lack of proper planning and research to determine if there was available off-theshelf software (e.g. the Remedy help desk system used by the FEC IT department) 

that could be utilized. 

3.	 No formal policy and standard operating procedures were documented by the 

OHR. OIG notes that OHR only has a flowchart of the HR On Demand process, 

but no formal policy or standard operating procedure that clearly explains how the 

process works, what each staff person’s responsibility is, timing of when inquiries 

are supposed to be entered into the database, when an inquiry can be considered 

“closed” in the database, and what other types of assignments beyond FEC staff 

inquiries should be entered into the database, if any. 

4.	 Miscommunication or misunderstanding between the Director of HR and the 

OHR staff related to non-HR On Demand inquires and assignments were also 

required to be entered into the HR On Demand Access database. As a result, 

there were inconsistencies among OHR staff members as to what was included in 

the database. Some employees were including what appeared to be every single 

task completed throughout their work day, such as HR staff meetings, rather than 

tasks directly related to customer service issues. 

Currently, OHR Management is not using the HR On Demand system as a tool to 

improve timeliness and other customer service issues. This was evident by the time it 

took to receive requested reports during the course of the audit and the lack of 

timeliness in responding to FEC employees’ requests for assistance. The time and 

effort required to properly manage the database could be better used to actually 

address employee inquiries and/or resolving employee issues. Improving the controls 

and streamlining the HR On Demand process will increase the likelihood that 

employee inquiries will be resolved timely and thus help improve customer service. 

OIG notes that subsequent to our inquiries about the HR On Demand process, 

30 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

OHR began working with ITD to fully automate the HR On Demand process by 

implementing the same customer request tracking system (“Remedy”) used by the IT 

helpdesk. 

Recommendation #18 

Management should ensure OHR and ITD continue to work together to ensure that 

“Remedy” is properly implemented, tested, and customized to fit the needs of the HR 

on Demand process. The Remedy solution should be fully implemented by 

September 2013. 

Management Response: 

Office of Human Resource Management (Management) partially agrees with this 

recommendation. Management agrees that OHR staff should work with OCIO to 

implement technological solutions at OHR. Even before receiving results of the 

OIG’s customer survey of OHR, Management was aware that a system is required 

for tracking and providing visibility for improving OHR customer service. In 

2012 the HR Director met with the IT Helpdesk Manager and requested to create 

a customer request tracking system similar to the Remedy system used by the IT 

Helpdesk. The Remedy system provides visibility and audit trail for handling 

customers’ requests by the IT Helpdesk. At that time the system was not available 

for OHR, therefore the HR on Demand was resurrected as a temporary band-aid 

while the HR Director explored other means. When the Remedy system became 

available, Management took immediate remedial action and developed the system 

for tracking customers’ requests. OHR staff is being trained and the system will 

be fully functional by the end of July. The effectiveness of the Remedy system 

and the provided customer service training to the HR staff will be re-evaluated in 

September 2013. 

OIG Comment: 

The OIG agrees with management that the Remedy system will automate the 

tracking and monitoring of employee inquiries and should improve OHR response 

time to employee inquiries. Once the Remedy system is fully implemented, we 

look forward to reviewing the results to ensure that the system is operating 

effectively and has improved OHR responsiveness to employee requests. 

Recommendation #19 

Once the Remedy customer request tracking system is implemented, OHR 

Management should determine the most effective way to use the automated system to 

improve the HR On Demand process and leverage the new system to streamline 

31 
Audit of the FEC’s Office of Human Resources OIG-12-05 

other related processes and procedures. In addition, this new process along with other 

related processes should be formally documented in a policy and/or standard 

operating procedures(SOP). The policies/SOPs should clearly document each OHR 

members’ role and responsibilities, as well as details about the technical and 

operational components of the processes. 

Management Response: 

Office of Human Resource Management (Management) agrees with this
 

recommendation. 

OIG Comment: 

The OIG agrees that corrective actions in progress and planned by management 

should address this recommendation. OIG looks forward to reviewing once fully 

implemented to ensure this recommendation has in fact been fully addressed. 

Recommendation #20 

Management should ensure the entire OHR staff is adequately trained on how to use 

the new Remedy customer request tracking system. 

Management Response: 

Office of Human Resource Management (Management) agrees with this
 

recommendation.
 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by management 

to ensure that it fully addresses this recommendation. 

B. Non-compliance with FEC’s Recruitment/Selection Process 

The FEC is not consistently complying with the current employee recruitment and 

selection procedures. According to OMB Circular A-123, Management’s 

Responsibility for Internal Control, Section I (Introduction) “... Management has a 

fundamental responsibility to develop and maintain effective internal control. ... 

Federal employees must ensure that Federal programs operate ... efficiently and 

effectively to achieve desired objectives. Programs must operate ... in compliance 

with laws and regulations, and with minimal potential for ... mismanagement...“ 

A vacancy announcement (VA) is the formal document used to communicate and to 

advertise open positions at the FEC. 

32 
Audit of the FEC’s Office of Human Resources OIG-12-05 

The VA includes the position title, salary range, job responsibilities, among other 

criteria for applicants to apply for FEC jobs. The OIG judgmentally sampled 10 VA’s 

during FY 2011 and FY 2012 and reviewed related files for compliance with current 

procedures and noted the following: 

	 1 of 10 included the wrong salary range (salary maximum range listed was for 

GS-10 instead of a GS-9). 

	 8 of 10 had an SF-52 (Request for Personnel Action) that was signed-off by the 

hiring official, Budget Office, and the Director of HR after the VA was 

advertised. Positions are required to be approved by these offices before they can 

be advertised. 

	 4 of 10 VAs included an SF-52 that did not include proper review and approval (3 

did not include sign-off by a HR Staffing and Classification Specialist and one (1) 

did not include any of the required sign-offs). 

 2 of 10 hiring files did not include evidence to support why all candidates that 

met minimum qualifications were not rated and ranked. According to FEC hiring 

practices, all candidates that meet minimum qualifications should be rated based 

on predetermined criteria. Both hiring actions were for Office of General Counsel 

(OGC) positions. According to OGC, documentation is not maintained to 

evidence the additional criteria used to determine which candidates to rate and 

rank when a large number of applicants meet the minimum qualifications. OIG 

notes that this additional criteria and how it was applied should have been 

documented. 

	 3 of 10 hiring files were missing evidence to support that structured interviews 

were conducted. Structured interviews include pre-established standard questions 

that are asked of all interviewees. The purpose is to ensure all interviewees are 

fairly evaluated. Based on follow-up with HR, evidence was subsequently 

obtained for two (2) selections. OIG notes that evidence to support structured 

interviews should be maintained in the hiring file. 

	 9 of 10 did not include adequate evidence that the position was approved by the 

Personnel Committee (PC). The Personnel Committee is composed of two 

Commissioners, and all new and vacant positions must be approved by the PC. 

Prior to June 2012, the only evidence required for PC approval was an email from 

the hiring official stating PC approval received. As of June 2012, OHR 

implemented the personnel request (PR) form which requires the hiring official to 

check-off that the position was approved by the PC. The PR form was missing for 

2 of 3 positions posted after the effective date of the PR form. 

33 
Audit of the FEC’s Office of Human Resources OIG-12-05 

Based on additional OIG follow-up, which included the above testing and 

inquiries, to employee issues communicated during survey interviews, OIG noted 

the following: 

 OHR notifications sent to internal candidates (current FEC employees) related 

to their application status do not consistently include accurate information or 

the wrong notifications are sent. For example, one employee received a 

notification from OHR stating they were not selected for a position they 

applied for, when in fact they were selected and did not accept the position. 

Another employee received a notification thanking them for interviewing and 

stated that although they were among the best qualified they were not 

selected. However, the person was never granted an interview, and when the 

employee followed-up with OHR, the employee was told that the email was 

sent to them in error, as they in fact did not make the best qualified list (which 

OIG confirmed). 

	 Internal candidates that are interviewed and make the best qualified (BQ) list 

do not always receive follow-up notification to inform the FEC employee that 

they were not selected. For example, in one particular case, an FEC employee 

applied for another FEC position seeking advancement; however, the 

employee was not selected for the position. This person did not learn about 

the outcome of her interview and a decision on the hiring until the successful 

applicant started work at FEC. 

The recruitment and selection process at the FEC is still a very manual process. 

Based on our audit testing, there was a lack of HR supervisory oversight to ensure 

all steps of the recruitment process were being complied with. OIG also notes that 

OHR is not directly involved in the recruitment and selection process for OGC 

positions and does not provide proper oversight for the monitoring and 

documentation of these positions. Although there have been changes to the 

recruitment/selection process, the current policies on FEC recruitment and hiring 

are outdated. A revised final draft of the Directive for Appointment and 

Promotion Procedures for Non-Bargaining Unit Positions was forwarded to the 

Commission on July 17, 2012, but has yet to be approved by the Commission. In 

addition, OHR has developed revised standard operating procedures (SOPs) that 

include a detailed checklist for each step of the recruitment and hiring process. 

However, OIG testing determined that this checklist has not been fully 

implemented. 

Lack of proper controls, including OHR management oversight over the 

recruitment and selection process, increases the risk that: 

34 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

	 FEC may not be following standard government labor regulations and fair 

hiring practices, which in turn increases the risk that potential discriminatory, 

bias, or other prohibitive hiring practices could occur and go undetected. 

	 An adequate audit trail is not maintained to provide evidence of a hiring 

action, documentation that may be needed if a job applicant is not selected for 

a position and files a complaint, among other reasons. 

 The best qualified candidate may not be selected and/or the candidate selected 

did not meet the appropriate criteria. 

 Positions could be filled without the proper funds available or an employee is 

hired at a higher salary level than the position warrants. 

OIG notes that OHR is currently in the process of implementing the FHR module 

to automate the recruitment/selection process. Once this module is fully 

implemented, controls and efficiencies over the hiring process are expected to 

improve. 

Recommendation #21 

The recruitment and selection checklist should be completed by the HR Specialist 

as each step in the process is completed for each position filled. The completed 

recruitment and selection checklist should be maintained in the related VA file. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by 

Management to ensure that it fully addresses this recommendation.
 

Recommendation #22 

The Supervisory HR Specialist (HR Supervisor) responsible for the recruitment 

and selection process should be required to review each VA file to ensure the 

proper documentation is included in the file and that every step on the recruitment 

and selection checklist has been completed. Once reviewed, the HR Senior 

Specialist should sign-off on the checklist indicating that the VA file is complete 

and that the recruitment and selection policy and procedures was adhered to. 

35 
 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by 

management to ensure that it fully addresses this recommendation.
 

Recommendation #23 

OHR should conduct adequate oversight for all OGC positions and ensure all 

documentation is completed and included in applicable files. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. OHR should and will conduct adequate oversight for all 

FEC positions to ensure completed documentation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by 

management to ensure that it fully addresses this recommendation.
 

Recommendation #24 

Management should implement Office of Personnel Management (OPM) 

guidance which states “...develop and use a ‘Hiring Contract’ between the hiring 

manager and the Human Resources Office that spells out each party's 

responsibility for filling the job...” The recruitment and selection checklist 

included in the OHR SOP for recruitment could be utilized as the hiring contract 

and this checklist should be reviewed with the hiring official at the beginning and 

throughout the recruitment and hiring process to discuss timelines and 

expectations. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by 

management to ensure that it fully addresses this recommendation.
 

36 
Audit of the FEC’s Office of Human Resources OIG-12-05 

C. Outdated Global Personnel Related Policies/Directives 

All of OHR’s current policies in place have not been updated to reflect current 

practices, and policies that have been updated to reflect current practice have not 

been finalized and approved by the Commission (i.e. Policy for Appointments & 

Promotions for Non Bargaining Positions, Senior Level Pay, Dual Compensation 

Waiver, Congressional Job References Appointments above the Minimum, 

Restoration of Duty, and Position Classification). OMB Circular A-123, 

Management’s Responsibility for Internal Control, Section C (Control Activity) 

“...Control activities include policies, procedures and mechanisms in place to 

help ensure that agency objectives are met.” 

OIG notes that OHR does not have a control in place to ensure that agency-wide 

policies are periodically reviewed and updated for changes in business practices 

and/or changes in government-wide guidelines. The revised policy for 

Appointments & Promotions for Non Bargaining Positions sent by OHR to the 

Commission in July 2012 has not been finalized and approved by the Commission 

as of this date. A lack of up-to-date agency-wide policies and procedures that 

reflect current business practices and requirements increases the risk that the FEC 

has internal controls that are not properly implemented and thus not effective. For 

example, changes in federal personnel laws and regulations will not be reflected 

in FEC policy and can create non-compliance with laws and regulations intended 

to promote fair hiring practices; employees could be promoted before they are 

eligible for promotion; or cash awards, benefits and pay could be paid to 

employees who are not eligible or for incorrect amounts. In addition, for 

managers/employees who are performing or involved in an HR-related task for 

the first time (e.g. processing a new hire/separation, scheduling contractor 

fingerprints), the manager/employee may not be aware of their responsibilities or 

lack proper guidance to ensure that they are in compliance. 

Recommendation #25 

OHR should periodically (at least annually) review all HR-related policies and 

procedures for the agency and for the OHR to ensure policies and procedures are 

accurate and relevant, and update as needed. 

Management Response: 

Office of Human Resource Management (Management) agrees with this 

recommendation. The OIG statement is partially correct. Two thirds of the 

FEC employees are bargaining unit employees who follow the Labor 

37 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Management Agreement. The policies for bargaining unit employees are 

all updated, negotiated, and approved under the LMA as of May 12, 2013. 

All the managers were trained by OHR on the contents of the LMA and 

the approved agreement has been provided to all staff and is posted on the 

FECNet. OHR is addressing final stakeholder comments in several 

policies. 

OIG Comment: 

The OIG notes that one third of the FEC employees are not part of the 

bargaining unit and thus policies that impact any and all agency 

employees should be up to date. 

The OIG looks forward to reviewing corrective actions planned by 

management to ensure that it fully addresses this recommendation. 

Recommendation #26 

All policies and procedures should be posted in a central location accessible to all 

FEC staff (ex: FECNet, the FEC computer server). In addition, when policies and 

procedures are updated they should be reposted and an email sent to all FEC staff 

on the changes/updates. 

Management Response: 

Office of Human Resource Management (Management) agrees with this

 recommendation. 

OIG Comment: 

The OIG looks forward to reviewing corrective actions planned by 

management to ensure that it fully addresses this recommendation. 

38 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

CONCLUSION 

The areas that were reviewed by the OIG during this audit of the Office of Human 

Resources (OHR) all link back to a review of the effectiveness of OHR’s customer 

service. In order for the OHR staff to provide effective customer service, the information 

and communication provided to their customers (FEC employees, job applicants, etc.) 

must be relevant, timely, and reliable. In addition, the OHR staff as a whole must be 

equipped with the knowledge and skills to carry out the mission and objectives of the 

office. Based on this audit, and the responses to the OIG’s HR customer service survey 

from 2012, OHR has not managed to find a consistent way to provide effective and 

efficient customer service to FEC staff. Based on the audit results, there are several 

factors that contributed to OHR’s inadequate customer service. These factors include: 

 Inadequate leadership/program management; 

 Inadequate performance management, and 

 Lack of automation. 

Management did not adhere to the Title 5, Code of Federal Regulations, (Administration 

Personnel)7 by failing to provide managerial training to the Director of OHR within one 

year of initial appointment. As the Director of OHR’s position was a critical career 

transition from a non-supervisory position to a manager, training should have been 

provided to the HR Director in a timely manner, rather than 14 months after appointment. 

In addition, OIG notes that many leadership shortcomings were highlighted via the 

workforce gap analysis, interviews by the OIG with OHR staff, and the existing 

challenges in OHR to accomplish their mission. Adequate leadership is a critical factor 

in the success of achieving the mission and goals of the HR office. Therefore, OIG 

recommended that the agency enter into a detail agreement or another similar mechanism 

to bring on-board, for a temporary period, a seasoned federal government HR leader. 

This temporary detail is necessary to provide the Director of OHR and staff the guidance 

and direction to bring about change to the OHR. OIG acknowledges that Management 

has brought in a seasoned federal employee that is an SES candidate from another 

agency. This person is on a four month detail, with the possibility of an extension, and 

has specific goals including (1) improve OHR staff performance and moral; (2) improve 

OHR customer service; and (3) develop performance measurements. Although the SES 

candidate does not have an HR background, he has experience with process reengineering and managing a large office which should benefit the OHR. 

7

 5 C.F.R. § 412.202 (2011). 

39 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

The OIG notes that the majority of OHR’s processes are handled manually which 

increases the susceptibility to human error which has a direct impact on customer service. 

The OIG recognizes that OHR management is committed to improve customer service 

and has agreed to implement many of the OIG's recommendations. For example, OHR 

management is currently pilot testing several FHR modules and is in the process of 

implementing the new automated customer service tracking system (“Remedy”). The 

OIG encourages OHR management to invest the necessary time and resources to 

adequately develop a realistic plan of action for resolving the audit findings in this report, 

ensure the plan is properly communicated to all OHR staff, and ensure continuous 

dialogue with the OHR's primary customers, the FEC staff. OIG believes that once OHR 

takes full advantage of existing technology, they will be able to streamline processes 

which in turn should increase productivity and help to improve customer service. 

40 
 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

1A. Ineffective 

Leadership 

1. OHR Management should 

reevaluate methods used to 

communicate expectations, to 

give feedback on staff 

performance, and to promote 

and address feedback from 

OHR staff in order to identify 

meaningful solutions to 

improve the organization. 

Then, OHR Management 

should make it a priority to 

implement corrective actions. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by Management to 

ensure that it fully addresses 

this recommendation. 

2. OHR Management should 

make a clear distinction 

between the roles of the 

Director of OHR and the two 

supervisors who are 

responsible for supervising 

their subordinates on a daily 

basis. In addition, the roles 

and responsibilities for each 

OHR member should be 

clearly communicated. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

3. The FEC should pursue a Disagree with recommendation: Based on OIG’s review of the 

detail or other type of “In this sequestered budgetary SES candidate’s background, 

agreement with another environment, it is unlikely that a past experience, and objectives 

federal agency to bring on seasoned federal official trained for this assignment, it appears 

board, no less than six specifically in HR matters will that the SES candidate could be 

months, a seasoned HR leave its agency to help the FEC, helpful in providing valuable 

professional with significant at no cost to the Commission. guidance and help improve the 

experience in federal However, Management was OHR. We look forward to 

government HR operations, successful in creating a win-win reviewing the results and 

management and customer situation by bringing a SES recommendations from this 

service, to provide clear candidate (at no cost to the assignment to determine if 

direction, training, and focus Commission) to help with the desired results have been 

to improve the HR office. issues as part of his development 

assignments. In addition, the 

Deputy Staff Director for 

Management and Administration 

assumed the managerial role of 

the OHR for the months of May 

and June and conducted team 

meetings on a weekly basis in 

order to strengthen team morale, 

staff collaboration, and 

improving customer service. The 

effectiveness of these recent 

initiatives will be re-evaluated in 

September 2013.” 

achieved. 

41 
 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

1B. Inadequate 4. OHR Management should Agree with recommendation: The OIG agrees that the OHR 

Organizational reassess the new OHR office “Although Management already reorganization was better than 

Structure structure to determine if there 

is a need to adjust the 

functions/tasks between the 

two teams, and/or individual 

started to reassess the existing 

structure, roles, and 

responsibilities it is important to 

note that the OHR restructuring 

the existing structure at the time 

and that management could not 

have foreseen that individuals 

team members, in order to provided a better structure than in critical roles would leave the 

better balance the workload it had before by engaging staff in agency. In light of the current 

amongst the teams/team the OHR office design. The OHR situation in OHR, we are 

members. engaged in several team building pleased that management has 

sessions where roles and 

responsibilities were repeatedly 

clarified and discussed. The 

sessions also focused on setting 

begun to reevaluate if 

adjustments are warranted. The 

OIG looks forward to reviewing 

priorities and improving corrective actions to ensure that 

customer service.” it fully addresses this 

recommendation. 

1C. Non-compliance 

with FEC’s 

Performance Plan 

and Appraisal Policy 

5. Ensure all HR staff have 

detailed performance plans 

that include their specific 

tasks and goals for their HR 

position. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

6. Ensure all performance 

plans are properly reviewed 

and approved by the first and 

second line supervisors in 

accordance with the annual 

performance appraisal 

process. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

7. Ensure that all staff Agree with recommendation The OIG looks forward to 

completes the required self reviewing corrective actions 

assessment for the mid-year planned by management to 

and year-end performance ensure that it fully addresses 

review. this recommendation. 

8. Ensure that the mid-year 

review discussion is 

documented and signed off by 

the employee and supervisor 

in accordance with the annual 

performance appraisal 

process. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

9. Ensure that all required 

sections of the annual 

performance appraisal process 

are completed, discussed and 

properly reviewed by the due 

dates specified in the 

performance appraisal 

template. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

42 
 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

IIA. Ineffective Use of 

the FHR System 

10. Fully implement the FHR 

modules to the maximum 

extent feasible to improve the 

effectiveness and efficiency of 

the OHR by September 2013. 

Partially agree with 

recommendation: “OHR is on 

the way to implement the FHR 

modules that are already 

purchased; however, currently 

there are some technical issues 

for the full implementation that 

require additional funding. The 

FHR modules’ implementation 

will be delivered based on 

availability of funds and 

priorities of staff members’ 

assignments. At this point, and 

before assessment of the OHR 

structure, priorities, and 

available resources; management 

cannot commit to the September 

2013 deadline for full 

implementation.” 

The OIG believes that 

management’s response will 

address this recommendation. 

We look forward to reviewing 

the automated processes over 

FHR modules have been fully 

implemented. 

11. Establish an agreement Partially agree with The OIG agrees that corrective 

with the Information recommendation: “Currently, actions by management will 

Technology Division (ITD) to OCIO staff members are assisting address the current OHR 

have an ITD staff member(s) HR Office in technical issues and projects to implement FHR 

assigned to the HR office to project implementation; however, modules. However, OIG 

aid in any technical issues OCIO is unable to provide believes that management 

with project implementation. dedicated staff member, due to 

lack of resources. Also, each 

project may require different type 

of OCIO expertise and different 

OCIO staff member may be 

assigned to different HR 

projects.” 

should consider a formal 

agreement with ITD to ensure 

OHR’s future technical needs 

are met. 

43 
 

 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

12. Develop and implement a 

template planning document 

guide prior to a) purchasing a 

new system; b) 

implementing/revamping a 

system (internal or external); 

or c) acquiring services 

(service provider, HR LOB, 

interagency agreements, etc.) 

that details: 

a. the needs of the office; 

b. services/benefits that 

will be received (ex: 

fully meets objectives, 

cost savings, etc.); 

c. any affects 

(positive/negative) to 

other offices that could 

be impacted or benefit 

from consultation; 

d. costs to the agency, both 

start-up and ongoing; 

e. alternative solutions (if 

any); 

f. implementation 

dates/milestones; and 

g. HR and other staff 

responsible for 

oversight and 

implementation. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

II.B. OHR is Not 

Properly Utilizing 

and Maintaining 

their FECNet Page 

13. Identify one HR staff 

member who will be the 

owner/manager of the content 

for HR's FECNet page and 

revise their annual 

performance plan to reflect 

their duties and 

responsibilities for 

maintaining the content of 

HR's FECNet page. 

Agree with recommendation: 

“OHR had an “owner” of 

FECNet page who left FEC and 

the position was not backfilled. 

However, OHR will be assigning 

a new content manager who will 

act as a team lead to ensure HR’s 

FECNet pages are updated and 

revised periodically.” 

The OIG agrees that corrective 

actions planned by management 

should address this 

recommendation. 

14. Update all content on Agree with recommendation The OIG looks forward to 

HR's FECNet page by reviewing corrective actions 

September 2013 to ensure all planned by management to 

information is accurate, up- ensure that it fully addresses 

to- date, and relevant. this recommendation. 

44 
 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

15. Establish an agreement 

with ITD to have an ITD staff 

member(s) assigned to the 

OHR office to aid in any 

technical issues with 

developing HR’s FECNet 

page. 

Partially agree with 

recommendation: “ITD staff 

members have always been very 

responsive in resolving technical 

issues for the HR’s FECNet page. 

ITD does not have the resources 

to provide a dedicated assigned 

ITD staff to HR office. However, 

as problems rise ITD and OHR 

will work together to solve them 

as soon as possible, knowing that 

HR FECNet page is important 

tool for HR communications with 

its customers.” 

The OIG agrees that corrective 

actions planned by management 

should address the current 

issues with OHR’s FECNet 

page(s). However, OIG 

believes that management 

should consider a formal 

agreement with ITD to ensure 

OHR’s future technical needs 

are met. 

II.C. Electronic 

Fingerprint 

Scheduling Process 

not Fully 

Implemented 

16. Fully implement the 

electronic fingerprint 

scheduling process and notify 

CORs that it is available. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

17. Develop a policy and Agree with recommendation The OIG looks forward to 

procedures that documents reviewing corrective actions 

and instructs how to use the planned by management to 

electronic fingerprint ensure that it fully addresses 

scheduling tool. this recommendation. 

45 
 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

III.A. HR On 18. Management should Partially agree with The OIG agrees with 

Demand Process is ensure OHR and ITD recommendation: “Management management that the Remedy 

Ineffective continue to work together to 

ensure that “Remedy” is 

properly implemented, tested, 

and customized to fit the 

needs of the HR on Demand 

process. The Remedy 

solution should be 

implemented by September 

2013. 

agrees that OHR staff should 

work with OCIO to implement 

technological solutions at OHR. 

Even before receiving results of 

the OIG’s customer survey of 

OHR, Management was aware 

that a system is required for 

tracking and providing visibility 

for improving OHR customer 

service. In 2012 the HR Director 

met with the IT Helpdesk 

Manager and requested to create 

a customer request tracking 

system similar to the Remedy 

system used by the IT Helpdesk. 

The Remedy system provides 

visibility and audit trail for 

handling customers’ requests by 

the IT Helpdesk. At that time the 

system was not available for 

OHR, therefore the HR on 

Demand was resurrected as a 

temporary band-aid while the HR 

Director explored other means. 

When the Remedy system became 

available, Management took 

immediate remedial action and 

developed the system for tracking 

customers’ requests. OHR staff is 

being trained and the system will 

be fully functional by the end of 

July. The effectiveness of the 

Remedy system and the provided 

customer service training to the 

HR staff will be re-evaluated in 

September 2013.” 

system will automate the 

tracking and monitoring of 

employee inquiries and should 

improve OHR response time to 

employee inquiries. Once the 

Remedy system is fully 

implemented, we look forward 

to reviewing to ensure that the 

system is operating effectively 

and has improved OHR 

responsiveness to employee 

requests. 

46 
 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

19. Once the Remedy 

customer request tracking 

system is implemented, OHR 

Management should 

determine the most effective 

way to use the automated 

system to improve the HR On 

Demand process and leverage 

the new system to streamline 

other related processes and 

procedures. In addition, this 

new process along with other 

related processes should be 

formally documented in a 

policy and/or standard 

operating procedures (SOP). 

The policies/SOPs should 

clearly document each OHR 

members’ role and 

responsibilities, as well as 

details about the technical and 

operational components of the 

processes. 

Agree with recommendation: 

“The HR Director has not been 

consistently approving personnel 

actions late. The OHR staff, in 

an attempt to be customer service 

oriented, was processing 

personnel action prior to the 

action being circulated for review 

and approval, based on 

customers’ desired and proposed 

dates. When the HR Director 

became aware of this situation 

she immediately instituted the 

following corrective actions; 1) 

mandated the use of the 

government-wide “Guide to 

Processing Personnel Actions” 

instead of HR staff relying on 

memory; 2) updated the OHR 

Standard Operating Procedures 

for “Setting Effective Dates;” 3) 

required staff to circulate the SF52 by “walking it around” to 

ensure that it is reviewed and 

signed within a day by the 

appropriate officials; and 4) will 

use the FHR system once 

implemented to process personnel 

actions so that the requesting 

offices, not OHR, are initiating 

their own SF-52s instead of OHR 

preparing them based on the 

requesting office’s email 

requests.” 

The OIG agrees that corrective 

actions in progress and planned 

by management should address 

this recommendation. OIG 

looks forward to reviewing 

once fully implemented to 

ensure this recommendation has 

in fact been fully addressed. 

20. Management should Agree with recommendation The OIG looks forward to 

ensure the entire OHR staff is reviewing corrective actions 

adequately trained on how to planned by management to 

use the new Remedy customer ensure that it fully addresses 

request tracking system. this recommendation. 

III.B. Noncompliance with 

FEC’s 

Recruitment/Selection 

Process 

21. The recruitment and 

selection checklist should be 

completed by the HR 

Specialist as each step in the 

process is completed, for each 

position filled. The 

completed recruitment and 

selection checklist should be 

maintained in the related VA 

file. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation 

47 
 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

22. The Supervisory HR 

Specialist (HR Supervisor) 

responsible for the 

recruitment and selection 

process should be required to 

review each VA file to ensure 

the proper documentation is 

included in the file and that 

every step on the recruitment 

and selection checklist has 

been completed. Once 

reviewed, the HR Senior 

Specialist should sign-off on 

the checklist indicating that 

the VA file is complete and 

that the recruitment and 

selection policy and 

procedures was adhered to. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

23. OHR should conduct 

adequate oversight for all 

OGC positions and ensure all 

documentation is completed 

and included in applicable 

files. 

Agree with recommendation: 

“OHR should and will conduct 

adequate oversight for all FEC 

positions to ensure completed 

documentation” 

The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

24. Management should 

implement Office of 

Personnel Management 

(OPM) guidance which states 

“...develop and use a ‘Hiring 

Contract’ between the hiring 

manager and the Human 

Resources Office that spells 

out each party's responsibility 

for filling the job...” The 

recruitment and selection 

checklist included in the OHR 

SOP for recruitment could be 

utilized as the hiring contract 

and this checklist should be 

reviewed with the hiring 

official at the beginning and 

throughout the recruitment 

and hiring process to discuss 

timelines and expectations. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

48 
 

 

 

 

Audit of the FEC’s Office of Human Resources OIG-12-05 

Summary of Audit Findings and Recommendations and Management’s 

Response 

Finding Recommendation Management Response OIG Comment 

III.C. Outdated 

Global Personnel 

Related 

Policies/Directives 

25. OHR should periodically 

(at least annually) review all 

HR- related policies and 

procedures for the agency and 

for the OHR to ensure policies 

and procedures are accurate 

and relevant, and update as 

needed. 

Agree with recommendation: 

“The OIG statement is partially 

correct. Two thirds of the FEC 

employees are bargaining unit 

employees who follow the Labor 

Management Agreement. The 

policies for bargaining unit 

employees are all updated, 

negotiated, and approved under 

the LMA as of May 12, 2013. All 

the managers were trained by 

OHR on the contents of the LMA 

and the approved agreement has 

been provided to all staff and is 

posted on the FECNet. OHR is 

addressing final stakeholder 

comments in several policies.” 

The OIG notes that one third of 

the FEC employees are not part 

of the bargaining unit and thus 

policies that impact any and all 

agency employees should be up 

to date. The OIG looks forward 

to reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

26. All policies and 

procedures should be posted 

in a central location accessible 

to all FEC staff (ex: FECNet, 

the FEC computer server). In 

addition, when policies and 

procedures are updated they 

should be reposted and an 

email sent to all FEC staff on 

the changes/updates. 

Agree with recommendation The OIG looks forward to 

reviewing corrective actions 

planned by management to 

ensure that it fully addresses 

this recommendation. 

49 
FEDERAL ELECTION COMMISSION 

WASH I NGTON , Q,C 20463 

MEMORANDUM 

TO: 

THROUGH: 

FROM: 

SUBJECT: 

Lynne McFarland 

Inspector General 

Alec palmerJO\-~ Staff Director -~ 

July 9, 2013 

Mitra K. Nejad-Guerin C)/1 ,_ A _______ 

Deputy Staff Director f~ pfa~;~nt and Administration 

Judy McLaughlin Uw~ Director of the Offic ;i m~~ Re;ou~ces 

Management Response to the Office of the Inspector General's Draft Report on the 

Audit of the Office of the Human Resources (0IG-12-05) 

Management hereby responds to the Office of the Inspector General's (OIG) Draft Report on the Audit 

ofthe Office of Human Resources (0IG-12-05) received on June 25, 2013. 

Management agrees with most of the OIG recommendations; however, Management requests that 

certain paragraphs in the report be modified to fairly identify the issues, as follows: 

1. Executive Summary of the draft report, page 3, , fourth paragraph the OIG stated that "Based on 

this audit, the OIG concludes the OHR has significant leadership and operational weaknesses that 

are impacting the office's ability to provide effective customer service and fulfill the day-to-day 

responsibilities ofthe office. Specifically, the agency hired a new OHR Director in April 2010, who 

lacked the necessary HR operations and leadership background that was necessary to address the 

many challenges facing the OHR at that time, and going forward. To compound this issue, the OHR 

Director's supervisor at the time, failed to promptly provide the OHR Director the training necessary 

to address these gaps." 

Management Response: We disagree with this statement and would like it removed or revised. 

Previous to her current appointment as the FEe's HR Director, the incumbent was acting EEO Director 

for the Commission for over a year. In this capacity the incumbent received a performance assessment 

from the former Staff Director, for whom she was a direct report, as "Exceed Expectations". Specifically, 

her supervisor at that time wrote that she "has done an admirable job as the Acting Director of the 

OEEO." In fact, she was doing such a good job that her three months detail got extended many times. 

When the incumbent moved to the HR Director position, there were no gaps identified in her leadership 

capability of that time. In addition, since the HR Office was in a state of array (half of the OHR staff 

1 
resigned at once), most of the OHR remaining FY 2010 budget went to contract support to support the 

office .. Moreover in this severely strained situation, it was wise for the leadership to remain at the 

office at all times. It is also important to note that with the first opportunity, after stability was 

established, the HR Director received one-on-one coaching and intense management training. 

In terms of having experience with HR operations, the incumbent was selected for the position as the 

best qualified because of her extensive experience (over 20 years) in HR operational functions. 

Due to these facts, management requests that the OIG remove the above paragraph from the Executive 

Summary and revise the language of section LA. "Ineffective Leadership" on page 14 and 15. 

2. Page 4 of the Executive Summary, paragraph 2, the OIG stated "Subsequent to the completion of 

the gap analysis, the OHR failed to develop these training plans. 

Management Response: Training plans were developed and executed in FY 2011 and FY 2012 for the 

staff in OHR. Copies of the plans and implementation were provided to the OIG during the audit. 

3. Page 5 of the Executive Summary, Paragraph 2, the OIG stated liThe OIG further concludes that the 

extent of the problems which currently exist in the OHR require significant leadership and 

operational changes. Related to this issue is the OIG's recommendation #3 . 

Management Response: The FEe's Office of Human Resources has a significantly long history of 

instability, which has created substantial staff turn-over and morale issues. These deep rooted cultural 

problems cannot and will not be healed overnight. Any drastic changes to the current leadership will 

rekindle even stronger the old fractures and will ultimately damage the Commission. The Management 

would like to avoid the FY 2010 history repeating itself. In this sequestered budgetary environment, it is 

unlikely that a seasoned Federal official trained specifically in HR matters will leave its agency to help 

the FEC, at no cost to the Commission. However, the management was successful in creating a win-win 

situation by bringing a SES Candidate (at no cost to the Commission) to help with the issues as a part of 

his developmental assignments. In addition, the Deputy Staff Director for Management and 

Administration assumed the managerial role of the OHR for the months of May and June and conducted 

team meetings on a weekly basis in order to strengthen team morale, staff collaboration, and improving 

customer service. The effectiveness of these recent initiatives will be re-evaluated in September 2013. 

4. Page 13, last paragraph, "OIG concludes that despite efforts by OHR management during the past 

18 months, customer service has not improved. 

Management Response: Even before receiving results of the OIG's customer survey of the OHR, 

management was aware that a system is required for tracking and providing visibility for improving OHR 

customer service. In 2012, the HR Director met with the Information Technology (IT) Help Desk 

iVlanager and requested to create a customer requests tracking system similar to the Remedy system 

used by the IT Help Desk . The Remedy system provides visibility and an audit trail for handling 

customers' requests by HR Specialists. At that time, the Remedy system was not available for OHR, 

therefore the HR on Demand was resurrected as a temporary band-aid while the HR Director explored 

other means. When the Remedy system became available, management took immediate remedial 

action and developed the system for tracking customers' requests. OHR staff is being trained and the 

2 
Remedy system will be fully functional by the end of July. The effectiveness of the Remedy system and 

the provided customer service training to the HR staff will be re-evaluated in September 2013. 

5. OIG Recommendation #4, page 17 "OHR Management should reassess the new OHR office 

structure to determine if there is a need to adjust the functions/tasks between the two teams, 

and/or individual team members, in order to better balance the workload amongst the teams/team 

members." 

Management Response: Although management already started to reassess the existing structure, roles, 

and responsibilities; it is important to note that the OHR restructuring provided a better structure than it 

had before by engaging staff in the OHR office design. 

The OHR engaged in several team building sessions where roles and responsibilities were repeatedly 

clarified and discussed . The sessions also focused on setting priorities and improving customer service. 

In addition, the two existing non-supervisory GS-14 Human Resources Specialists were ultimately 

appointed permanently as supervisors, in order to provide hands-on coaching and to increase staff 

accountability, These changes may not have fully remedied the old persistent problems; but it 

definitely improved the situation. The successful implementation of the eOPF project, which provided 

every FEC staff access to their electronic official personnel files; successful completion of the Labor 

Management Agreement negotiations; development and implementation of the FEe's telework policies; 

the OPM approval of a new and improved performance management system are some examples of OHR 

successes in these last couple of years. We request that the OIG recognize these successes for improved 

customer service, use of technology (eOPF), and updated policies (new approved LMA), while the 

management agrees that OHR customer service needs additional improvements. 

6. Section III. Office Operations, Page 28, first paragraph, the OIG stated: liThe Director of HR is not 

consistently approving Request for Personnel Actions (SF-52s) in a timely manner." 

Management Response: The HR Director has not been consistently approving personnel actions late. 

The OHR staff, in an attempt to be customer service oriented, was processing personnel actions prior to 

the action being circulated for review and approval, based on customers' desired and proposed dates. 

When the HR Director became aware of this situation, she immediately instituted the following 

corrective actions: 1) mandated the use of the government-wide "Guide to Processing Personnel 

Actions," instead of HR staff relying on memory; 2) updated the OHR Standard Operating Procedures for 

"Setting Effective Dates;" 3), required staff to circulate the SF-52 by "walking it around" to ensure that it 

is reviewed and signed within a day by the appropriate officials; and 4)mandated the use of the FHR 

system once implemented to process personnel actions so that the requesting offices, not OHR, are 

initiating their own SF-52s, instead of OHR preparing them based on the requesting office's email 

requests. 

7. Section III. C Outdated Global Personnel Related Policies/Directives, the OIG stated that_"AII of 

OHR's current policies in place have not been updated to reflect current practices." 

Management Response: The OIG statement is partially correct. Two thirds of the FEC employees are 

bargaining unit employees who follow the Labor Management Agreement. The policies for bargaining 

3 
unit employees are all updated, negotiated, and approved under the LMA, as of May 12, 2013. All the 

managers were trained by OHR on the contents of the LMA and the approved agreement has been 

provided to all staff and is posted on the FECNet. 

OHR is addressing final comments received from the stakeholders on the remaining policies before 

receiving final approval. 

8. We would like to bring to the attention of the OIG additional Improvements completed since the 

start of the OIG Audit in July/August 2012. 

In addition to those improvements listed above, the following are additional recent 

improvements: 

• Staff members at OHR are identified to keep the FECNet updated on a regular basis; 

• IT and OHR staff are working closely together to employ FHR modules, in FY 2014. Some 

IT security issues need to be resolved for the system's full employment; 

• Weekly Friday team meetings with the HR Director and all staff are established. In these 

meetings team issues and customer requests issues are discussed and resolved; 

• Daily status meetings between the HR Director and the two supervisors are established. 

In these short standing meetings, daily priorities are made; 

• Additional hands-on training was provided to HR Assistants to process SF-S2s; 

• New process was put in place (revised SOP; walking forms for signature until FHR system 

is up and running); and 

• We are continuing to work on automating the process with FHR. 

4 
 

or toll free at 1-800-424-9530 (press 0; then dial 1015) 

Fax us at 202-501-8134 or e-mail us at oig@fec.gov 

Visit or write to us at 999 E Street, N.W., Suite 940, Washington DC 20463 

Federal Election Commission 

Office of Inspector General 

Individuals including FEC and FEC contractor employees are encouraged to alert the OIG to 

fraud, waste, abuse, and mismanagement of agency programs and operations. Individuals 

who contact the OIG can remain anonymous. However, persons who report allegations are encouraged 

to provide their contact information in the event additional questions arise as the OIG evaluates the 

allegations. Allegations with limited details or merit may be held in abeyance until further specific details 

are reported or obtained. Pursuant to the Inspector General Act of 1978, as amended, the Inspector 

General will not disclose the identity of an individual who provides information without the consent of that 

individual, unless the Inspector General determines that such disclosure is unavoidable during the course 

of an investigation. To learn more about the OIG, visit our Website at: http://www.fec.gov/fecig/fecig.shtml 

Together we can make a difference. 

Fraud Hotline 

202-694-1015