Evaluation of Staffing, Hiring, and 

Retention at the FEC 

February 9, 2024 

Report No. IE-23-01 
 

 

 

 

 

 

 

 

 

 

 

EXECUTIVE SUMMARY OIG REPORT NUMBER: IE -23 -01 

FEBRUARY 9, 2024 

EVALUATION OF STAFFING, HIRING, 

AND RETENTION AT THE FEC 

WHY WE CONDUCTED THIS EVALUATION 

The Federal Election Commission (FEC) has experienced a 

significant decline in staffing levels over the last 20 years, 

losing 20% of its full-time workforce from 2002 to 2022. Based 

on this observed decline, the Office of Inspector General (OIG) 

initiated this evaluation to identify root and proximate causes 

of this decline and to evaluate related issues. 

By contrast, medium independent agencies hire 4.2% more 

staff per year than the FEC and maintain overall staffing levels 

despite having higher attrition. A root cause of the low FEC 

rate of hiring has been inadequate budgets; the FEC’s annual

budgets have declined when adjusted for inflation. Indeed, 

the decline of the FEC budget, in real terms, accounts for half 

of the overall reduction in staff over the past seven years. WHAT WE FOUND 

The decline in FEC staffing levels occurred entirely in the 

general schedule (GS) permanent segment of the workforce 

(i.e., not among Commission staff or senior level managers). 

We compared the FEC staffing decline with the group of 32 

medium independent agencies in the Office of Personnel 

Management’s FedScope database and found that the 

reduction in staff size is specific to the FEC. Other medium 

independent agencies have not experienced similar declines. 

The decline in FEC headcount is not due to high attrition. The 

FEC’s annual separation rate is lower than that of medium 

independent agencies. The proximate cause of the reduction 

in FEC staff size is that departed staff are not fully replaced. 

Personnel cost drivers in addition to salary increases have 

increased the per-staff cost as much as increases in GS pay. 

The most significant of these factors are increasing benefits 

costs and a shift toward higher average GS levels of FEC staff. 

These are typical at medium independent agencies, as well. 

Additional conclusions include: 

• The FEC’s HR staff is under resourced compared to other

agencies, which has an array of potential consequences. 

• The budget justification process and budget request levels 

have presented a historical challenge for the FEC. 

• There is a large and increasing retirement-eligible 

segment of FEC staff. By 2028, 43% of FEC staff will be 

eligible for full or immediate reduced retirement. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EXECUTIVE SUMMARY CONTINUED (page 2 of 2) 

DIVERSITY, EQUITY, INCLUSION, & ACCESSIBILITY (DEIA) 

This evaluation additionally identified potential DEIA 

successes and challenges at the FEC. The evaluation does not, 

however, explore causes or consequences. 

The ethnic/racial mix of FEC staff appears to be representative 

of the overall labor pool in Washington, DC when compared 

to medium independent agencies. However, Black/African 

American staff appear to be underrepresented at higher 

grade levels and in supervisory positions. Specifically, 

Black/African American staff hold lower average GS levels 

than other ethnic/racial segments, as much as two grade 

levels lower than other groups. 

In addition, Black/African American employees are 

underrepresented in supervisory positions at the FEC when 

compared to their overall representation among FEC staff. 

The same is not true of other groups, who are fairly or overrepresented at supervisory levels. 

Additionally, Black/African American staff appear to be 

promoted less frequently than other segments of FEC staff. 

Step level within grade is an indicator of the length of time an 

employee has spent in that grade. 

Using the standard schedule for step increases, Black/African 

American staff have an average step level of 7.4, which 

corresponds to a length of service of 11.8 years at that grade. 

That is, Black/African American staffers have spent an average 

of 11.8 years at their current grade levels, much longer than 

other racial/ethnic groups, which implies that those other 

groups promote more quickly than Black/African American 

employees. 

A success story is that the FEC has overcome the traditional 

underrepresentation of women among supervisors. This is 

FEC-specific, as the underrepresentation of women in 

supervisory positions continues to persist among medium 

independent agencies. 

WHAT WE RECOMMEND 

We recommend that the FEC evaluate: 

• Whether its human capital planning adequately forecasts 

long-term costs and budget uncertainty, and addresses 

retention, succession planning, and other key issues. 

• The sufficiency of HR staffing levels at the agency. 

• Whether data provided to OMB and Congress adequately 

communicate agency resource and staffing needs. 

In addition, the OIG has initiated an audit of DEIA disparities 

identified in this report. 
Table of Contents 

Background and Summary.............................................................................................................. 6 

Recommendations....................................................................................................................... 7 

Summary of Key Findings.............................................................................................................. 8 

1. While the Agency’s Workload Has Increased, Staffing Levels at the FEC Have Fallen 

Steadily Over the Past 20 Years.................................................................................................. 8 

2. Staff Levels Have Not Declined for Medium Independent Agencies Overall ....................... 9 

3. Staffing Declines at the FEC Have Occurred Among General Schedule Permanent Staff .. 10 

4. The FEC Has a Below-Average Attrition Rate; Reductions in Staff Size Result from a Low 

Rate of Hiring, Not Attrition..................................................................................................... 11 

5. FEC Appropriations Have Declined in Real Terms Because Appropriation Increases Have 

Not Kept Pace with Rising Costs.............................................................................................. 12 

6. The Budget Decline at the FEC is Not Typical of Medium Independent Agencies............. 13 

7. The Decline in FEC Staff Levels is Exacerbated by Cost Drivers Beyond Increases to the 

GS Pay Table: Benefits Costs, Average Grade Level, and Average Step Level ..................... 14 

8. Actual Per-FTE Costs Have Been Higher than Budget Justification Estimates; Resulting 

FTE Levels Have Been Lower Than Projected ........................................................................ 15 

9. The FEC Will Have a Personnel Budget Shortfall in FY 2024 Unless the FY 2024 Budget is 

Greater than FY 2023................................................................................................................ 16 

10. The FEC Has a Smaller HR Staff and Fewer HR Resources than Medium Independent 

Agencies.................................................................................................................................... 17 

11. By September 2028 (5 years) 61.3% of Current FEC Staff Will Be Eligible to Retire 

(Either Immediate or Deferred with 20+ Years of Service) ..................................................... 19 

12. The FEC has Bridged Supervisory Disparities on the Basis of Gender, Though Disparities 

Persist Related to Race/Ethnicity; Further Evaluation is Warranted ........................................ 20 

Review of key takeaways.......................................................................................................... 21 

OIG Summary and Observations of FEC Management Response to the Evaluation................... 22 

Analysis and Methodology: Evaluation of Staffing, Budget, HR, and Workforce Risks at the 

FEC ............................................................................................................................................... 27 

Introduction............................................................................................................................... 27 

Staffing Levels at the FEC Have Persistently Fallen While Federal Campaign Fundraising Has 

Steadily Increased ..................................................................................................................... 28 

The FEC Has a Below-Average Attrition Rate; Reductions in Staff Size are the Result of Even 

Lower Rates of Hiring .............................................................................................................. 33 

FEC Budgets Have Not Kept Pace with Cost Increases ........................................................... 34 

Actual Per-FTE Costs Have Been Higher than Budget Justification Estimates; Corresponding 

Actual FTE Levels Have Been Lower Than Projected............................................................. 37 

4 
Personnel Cost Drivers go Beyond General Schedule Salary Increases................................... 40 

Impact of Compounding Components of Personnel Costs ................................................... 41 

Increasing Grade Levels at the FEC ..................................................................................... 42 

Higher Costs Accompany the Shift to Higher Average GS Level Staff............................... 44 

Increasing Average Length of Service Results in Higher Step-In-Grade Pay...................... 45 

The Cap on Maximum GS Schedule Salaries Materially Reduces the Rate of Growth for 

Personnel Costs at the FEC................................................................................................... 46 

Comparison of Salary Growth for the Various Segments of FEC Staff ............................... 47 

Summary and Conclusion of Personnel Cost Analysis ........................................................ 48 

Recommendation 1 – Evaluate Long-Term Budget and Staffing Plans:.............................. 50 

How FEC HR Staffing Compares to Medium Independent Agencies ..................................... 51 

Specific Agency Benchmarks for Number of HR Staff and Ratio of Total Staff to HR Staff 

............................................................................................................................................... 52 

Recommendation 2 – Evaluate HR Resources ..................................................................... 54 

The FEC will Experience a Personnel Budget Deficit if the FY 2023 Budget Levels Continue 

into FY 2024 ............................................................................................................................. 55 

Implications for the FEC if FY 2024 Budget Levels are Carried into FY 2024................... 58 

Recommendation 3 – Evaluate Future Budget Justifications ............................................... 61 

A Majority of FEC Staff will be Eligible to Retire by 2025 .................................................... 62 

Diversity, Equity, Inclusion, and Accessibility Needs Further Evaluation .............................. 64 

Observation 1 – Future Evaluation of Diversity, Equity, Inclusion, and Accessibility........ 69 

Summary and Review of Recommendations................................................................................ 70 

Appendix A: Medium Independent Agency Comparison Group ................................................ 72 

Appendix B: Comparison of Various Segments of Medium Independent Agency Staffing to 

Identify Whether One Segment is Better Suited to be the Comparison Group ............................ 74 

Appendix C: Additional Detail for Projection of FY 2024 Budget ............................................. 76 

FY 2023 Projection ................................................................................................................... 76 

Cost Drivers in FY 2024 ........................................................................................................... 77 

Staffing Levels for FY 2024 ..................................................................................................... 77 

Projected Personnel Costs for FY 2024: Flat 309 Staff and No-Hire Scenarios ..................... 78 

Appendix D: Management Response to Draft Evaluation of Staffing, Hiring, and Retention at 

the FEC ......................................................................................................................................... 81 

Appendix E: Edits and Changes Between the Draft Evaluation Provided to Management and the 

Final Report .................................................................................................................................. 94 

5 
 

Background and Summary 

In January 2023, The Office of Inspector General (OIG) at the Federal Election Commission 

(FEC) initiated this evaluation of staffing and human resource (HR) issues at the FEC. The 

backdrop for this evaluation is that staffing levels at the FEC have persistently declined despite 

significant growth in federal campaign funding and corresponding workload. Impacts include 

the FEC’s reduction of certain performance benchmarks and adverse effects on agency 

performance.1 

An additional (and potentially related) issue is that the FEC ranked 26 out of 30 in the 2022 

Best Places to Work2 rankings for small federal agencies. In the 2022 Federal Employment 

Viewpoint Survey (FEVS), 34.8% of responding FEC staff indicated they are considering 

leaving the organization.3 In contrast, other small agency respondents said “yes” to this question 

less frequently: 22.5% of the time. The issues of declining staff, increased workload, and morale 

concerns frame this evaluation. 

This evaluation relies primarily on public information sources: OPM workforce data 

(FedScope), FEC reports including budget justifications and financial reports, media and press 

resources, and other public and governmental data sources. A key goal in this evaluation has 

been to provide statistics, measures, and findings for the FEC that can be compared to 

corresponding measures for comparable federal agencies. The data sources used to provide 

information on the FEC have either provided equivalent information on comparable federal 

agencies, or alternative public data sources have been available to do so. 

The analysis herein did utilize one specific FEC-provided data source: retirement eligibility 

data for FEC staff. In addition, FEC staff provided feedback, perspective, and supporting 

information on numerous occasions. This input meaningfully improved this product and the OIG 

is grateful for the attention agency staff provided and for their contributions. 

Another objective has been to produce baseline measures and descriptive statistics that relate 

to FEC staffing including retention, separations, hiring, budgeting, and resource constraints. The 

evaluation also considers factors that have adversely impacted the FEC’s ability to secure

funding levels that would enable the agency to obtain and maintain adequate staffing levels. 

Other topics include HR resourcing relative to comparable agencies, an analysis of projected FY 

2024 shortfalls in personnel budget, and a look at agency successes and challenges in diversity, 

equity, inclusion, and accessibility (DEIA). 

This evaluation identifies potential factors that drive various outcomes, including proximate 

and root causes. Where applicable, the OIG makes recommendations for policy and process 

1 See, e.g., the FEC’s FY 2024 Congressional Budget Justification at footnotes 24, 42, 43 and Sec. 3D. 

https://www.fec.gov/resources/cms-content/documents/fy24-fec-congressional-budget-justification.pdf 

2 https://bestplacestowork.org/rankings/?view=overall&size=small&category=leadership& 

3 Question language: Based on your work unit’s current telework or remote work options, are you considering leaving

your organization, and if so, why? 

6 
improvements at the FEC. Below is an overview of the main takeaways and observations that 

will be examined in more depth in the body of this report: 

• FEC staff has persistently declined over the last 20 years. 

• This decline has occurred among General Schedule (GS) permanent staff. 

• The decline is attributable to hiring, not attrition (which has been low at the FEC). 

• FEC budget growth has not kept pace with increasing GS salary levels. 

• Additional costs beyond GS salary level increases have further contributed to the 

reduction in agency staffing levels. 

• Actual per-staff personnel costs have exceeded budget justification projections. 

• The FEC will experience a budget shortfall in personnel costs if the FY 2023 

appropriation level is carried over into FY 2024. 

• The FEC has fewer HR staff than comparable medium independent agencies. 

• A significant portion of FEC staff is retirement-eligible or will be within 5 years. 

• Further examination of DEIA issues is warranted in light of potential disparities 

identified in this evaluation. 

Recommendations 

The FEC OIG makes three recommendations. We also include one observation related to an 

area of further work for the FEC OIG that is significant and relevant to the findings in this report. 

Recommendation 1 – Evaluate Long-Term Budget and Staffing Plans: The FEC OIG 

recommends that the FEC evaluate whether its human capital planning adequately forecasts 

long-term costs, contemplates budget uncertainty, and addresses retention, succession planning, 

development, and acquisition of personnel, experience, and skills essential to successful delivery 

of FEC mission priorities. 

Recommendation 2 – Evaluate HR Resources: The FEC OIG recommends that the FEC 

evaluate the sufficiency of HR staffing levels and of overall HR resources available to the 

agency. The FEC should, as appropriate, increase resources to levels commensurate with other 

medium independent agencies and to provide capacity for HR-related strategic initiatives. 

Recommendation 3 – Evaluate Future Budget Justifications: The FEC OIG recommends that 

the FEC evaluate data provided to OMB and Congressional appropriators to ensure budget 

justifications adequately communicate the agency’s personnel budget requirements. 

Observation 1 – Further Evaluation of DEIA and Equal Employment Opportunity (EEO): 

The FEC OIG has initiated an audit of DEIA as well as EEO programs at the FEC. This audit is 

informed in part by data derived in this evaluation but is separately supported through various 

survey, employee satisfaction, and risk assessment processes. 

7 
 

Summary of Key Findings 

This summary section provides an overview of the key takeaways from the body of the report 

and analysis.4 It includes observations and illustrations on 12 topics. 

1. While the Agency’s Workload Has Increased, Staffing Levels at the FEC Have 

Fallen Steadily Over the Past 20 Years 

From 2002 to 2022, the FEC staffing level fell 19.3% from 363 to 293. The reduction in 

staffing levels has coincided with sharply increasing activity in campaign contributions – both in 

transaction number and dollar volume. To achieve a balance of historical trends and relevancy 

to current circumstances, this evaluation will focus on FY 2016 through FY 2022, which 

coincides with the period from the 2016 presidential campaign through the 2022 mid-term 

election cycle and encompasses the rapid increase in contribution volumes. 

4 As a summary, this section is not comprehensive. More thorough information about methodology, data sources, 

approaches to analysis, and decisions around data selection is available in the body of the report that follows – and in 

some cases, as appendices. 

8 
2. Staff Levels Have Not Declined for Medium Independent Agencies Overall 

FEC staffing fell 11.5% from 331 in September 2015 to 293 in September 2022. To provide 

context for this statistic, this evaluation looked at the staffing level trend for a comparison group 

of medium independent agencies.5  The aggregate staffing level of these 32 medium independent 

agencies increased 0.5% from September 2015 to September 2022, increasing from 12,217 to 

12,284 employees. 

The staffing level trend of the comparison group is illustrated by the gray line in the chart 

which presents the change in medium independent agency staffing levels in proportion to the 

FEC staffing level as of September 2015. (I.e., the gray line is scaled to show what FEC staffing 

levels would have been if they had followed the overall staffing level trend of medium 

independent agencies. Specifically, the beginning FEC staffing level of 331 would have 

increased to 332.8 as of September 2022.) 

The decline in staffing levels at the FEC is not reflective of broader trends in federal 

employment; it is specific to the FEC. 

The green line illustrates the disparity between the FEC staffing level trend and the 

comparable staffing level for the medium independent agency comparison group. 

5

A more thorough description and discussion of the medium independent agency comparison group is provided in 

Appendix A. In short, the comparison group is comprised of the 32 medium independent agencies as determined by 

FedScope. These are independent agencies with 100 to 999 staff. 

9 
 

3. Staffing Declines at the FEC Have Occurred Among General Schedule 

Permanent Staff 

There are four unique segments of FEC staff: commissioners, commission staff, senior 

leaders (SL), and general schedule non-seasonal full-time permanent staff (GS permanent). The 

first three categories remained relatively stable or grew from September 2015 to September 

20226

. The GS permanent staff level fell by 13.5% from 304 employees on board in September 

2015 to 263 in September 2022. GS permanent staff make up approximately 90% of the total 

FEC workforce and execute the programs and processes that deliver on the FEC’s mission. 

For this reason, this evaluation will focus primarily on GS permanent staff. 

6 Note that the FEC lacked a quorum at FY 2019 and FY 2020 year-end with only 3 commissioners. Commissioners 

are presidentially appointed and senate confirmed. Most commission staff are assigned to specific commissioners and 

as a result, the number of commission staff varies in relation to the number of serving commissioners. 

10 
4. The FEC Has a Below-Average Attrition Rate; Reductions in Staff Size Result 

from a Low Rate of Hiring, Not Attrition 

The FEC experienced an average 8.0% separations rate for GS permanent staff from 

September 2015 to September 2022. The FEC’s annualized hiring rate over this period was 

6.3%, which means the FEC has historically hired approximately three employees for every four 

employees who separated. This difference between the rate at which staff leave the agency and 

the lower rate at which they are replaced is what accounts for the decline in FEC staffing levels. 

For comparison, medium independent agencies in the DC area have experienced a 10.4% 

annual separations rate for GS permanent staff. The comparison group has hired at an 

annualized rate of 10.3%, keeping pace with the rate of separations and maintaining overall 

staffing levels. 

This evaluation will use the group of 32 medium independent agencies, narrowed to their 

DC-based GS permanent staff, as a reference to provide context for FEC staffing statistics.7  

7 Because much of this evaluation will directly or indirectly relate to costs and budget, restricting the comparison 

group to staff located Washington, DC ensures comparable cost comparisons. Both FEC and DC-located medium 

independent agency staff share the common Washington, Baltimore, Arlington locality pay table. Narrowing the 

comparison group to the same regional employment market also minimizes variations attributable to specific regional 

or local employment factors. 

11 
5. FEC Appropriations Have Declined in Real Terms Because Appropriation 

Increases Have Not Kept Pace with Rising Costs 

FEC appropriation levels increased by a total 10.4% from FY 2015 to FY 2022 from $67.5 to 

$74.5 million. The GS salary cost of an employee in FY 2022, however, was 17.0% higher than 

in FY 2015.8  The GS pay table is a major driver of the FEC’s overall cost structure. GS staff 

comprise 94% of total FEC staffing, and personnel costs (principally compensation and benefits) 

comprise approximately 70% of the FEC’s total budget. 

Because FEC appropriation increases did not keep pace with increases in the GS pay tables, 

the FEC budget declined in real terms – i.e., it would not be possible to maintain the same level 

of staffing. After factoring in the 17.0% increase in general schedule employment costs, the FY 

2022 budget of $74.5 million becomes equivalent to $63.7 million FY 2015 dollars, or 5.6% less 

than the actual $67.5 million FY 2015 appropriation. This cost-adjusted appropriations gap 

accounts for approximately 17 of the 41 general schedule employees lost from September 2015 

to September 2022. 

The fact that FEC appropriations have not kept pace with increases in the general schedule 

pay table is a significant, but incomplete explanation for the decline in staffing levels at the FEC. 

8 The GS pay table increase of 17.0% directly relates to personnel costs which comprise approximately 70% of the 

FEC budget. Over the same period, the Consumer Price Index (CPI) increased 25%. 

12 
6. The Budget Decline at the FEC is Not Typical of Medium Independent Agencies 

When adjusted for inflation, FEC appropriations fell 3.0% from FY 2015 to FY 2023.9  FEC 

appropriations increased 21.0% over these 8 years and did not keep pace with the 24.7% increase 

in the Consumer Price Index (CPI). The FEC’s decline in inflation-adjusted appropriations is not 

reflective of federal medium independent agencies overall. The average inflation-adjusted 

increase in appropriation levels for medium independent agencies was 2.3% from FY 2015 to FY 

2023. 

Overall inflation-adjusted funding of medium independent agencies increased 1.0% over this 

period. To distinguish these statistics, the total aggregate funding for all medium independent 

agencies combined increased 1.0%, whereas the average medium independent agency had its 

own budget increase by 2.3%. The reason for this difference is that some of the largest-budget 

agencies had below-average increases over this period, skewing the aggregate statistic. 

The FEC decline in inflation-adjusted appropriations is not reflective of trends in either 

individual agency or overall agency funding. 

9 This chart deviates from the standard timeframe of this evaluation: it uses the eight-year period from FY 2015 to 

FY 2023. The reason for this is that the FEC budget increased 9.6% from FY 2022 to FY 2023 to $81.7 million. 

Although this increase is an outlier in FEC appropriations history, it is included to provide the best-case measure of 

FEC appropriations declines when adjusted for inflation, and to preemptively address the question of what the funding 

trend would be with FY 2023’s increase included. 

13 
7. The Decline in FEC Staff Levels is Exacerbated by Cost Drivers Beyond Increases 

to the GS Pay Table: Benefits Costs, Average Grade Level, and Average Step Level 

The average cost in salary and benefits per GS permanent employee increased by 30.8% 

from September 2015 to September 2022. Increases to the GS pay table only account for 17.6% 

of this increase.10 Appropriation levels increased 10.4% over this period. The proportion of total 

FEC budget allocated to personnel increased slightly over the period FY 2015 to FY 2022. After 

combining FEC appropriation increases with the increased percentage of total FEC budget 

allocated to personnel from FY 2015 to FY 2022, the total increase in available funds for 

personnel costs increased by 14.7% over seven years, nearly matching the GS increases.11 

Feasible staffing levels have been impacted by additional costs over and above GS pay table 

increases – specifically, rapidly increasing benefits costs and higher per-staff salaries as the 

average GS level and step within grade of FEC staff has increase (related to increases in average 

length of service of FEC employees). These additional cost drivers, and the corresponding 

reduction in the number of staff that can be supported by the FEC personnel budget, account for 

the loss of approximately 32 GS staff from September 2015 to September 2022. 

To ensure stable or growing staff levels, FEC budgets must incorporate future cost increases 

including benefits overhead and staffing structures with higher-GS and higher-step employees. 

10 Note that the seven-year increase cited here is 17.6%. 17.0% was cited in a prior summary section. This is an 

example of the difference between point- and period measures. The September 2015 to September 2022 increase was 

17.6%, measuring the increase in the GS pay table as of that month. The 17.0% increase in the prior section referred 

to the increase in FY 2015 to FY 2022 GS salaries (because fiscal years run October through September, three months 

of salary are paid by one annual GS pay table and the following 9 months are paid by the subsequent year pay table). 

11 The FEC was able to retain approximately 9 GS employees by shifting budget from non-personnel to personnel. 

14 
 

 

 

 

 

 

 

 

 

8. Actual Per-FTE Costs Have Been Higher than Budget Justification Estimates; 

Resulting FTE Levels Have Been Lower Than Projected 

The FEC submits budget justifications for each fiscal year that include an overall budget 

request amount and a projection for how many FTEs that amount would provide for.12 From FY 

2016 through FY 2022, the FEC was appropriated 99.2% of its budget requests.

13 This would 

suggest that the FEC received budgetary resources sufficient to support 99.2% of the requested 

FTE levels. However, the actual FTE levels for FY 2016 through FY 2022 were only 91.6% of 

the projected full-budget FTE levels – 7.6% lower (or approximately 23 FTEs). This 

discrepancy has been persistent through all seven fiscal years. 

Take FY 2018 as an example. The FEC requested and received a $71.25 million 

appropriation. The budget justification stated: “The FY 2018 Funding request takes into 

account full year funding for up to 345 FTE for FY 2018.”14 Although the FY 2018 request was 

fully funded, the actual FTE count was approximately 315.15 A material factor in the decline in 

staffing levels is that the budget justification projected lower per-FTE costs than were actually 

incurred. The FY 2018 per-FTE cost (compensation and benefits divided by projected 

supportable FTEs) was $140,784. The actual per FTE cost (year-ending compensation and 

12 FTE is used here as the technical budgetary measure defined by the GAO. A more detailed description of the 

distinction between FTE and staffing level, and methodology, is provided in the corresponding section within the main 

report body. 

13 We are excluding a $5.0 million lease expiration expense included for FY 2016 and an $8.0 million lease expiration 

expense included for FY 2017. 

14 Federal Election Commission Fiscal Year 2018 Congressional Budget Justification. 

15 The FEC staffing level in FedScope began at 322 in September 2017, falling by quarters to 319, 315, 313, and 

ending at 304 as of September 2018 for an average of 315. 

15 
 

benefits divided by FTEs) was $147,245. This is typical of all years and the chart above 

illustrates the projected and actual per-FTE cost, as well as the difference. 

Potential contributing factors for the discrepancy between projected and actual costs are 

discussed in the body of this evaluation. It should also be noted that budget request development 

is not fully within the control of agency budget managers (OMB plays a role in budget 

development, for example). These complications, along with the fact the budget request timeline 

creates a two-year lag between the request year and last complete fiscal year, underscore the 

importance of proactively incorporating both known and anticipated cost drivers in the budget 

development process to ensure a close correlation between appropriated funds and program 

delivery. 

9. The FEC Will Have a Personnel Budget Shortfall in FY 2024 Unless the FY 2024 

Budget is Greater than FY 2023 

The FEC leveraged its FY 2023 budget, which was 9.6% higher FY 2022, by increasing its 

staffing level from 293 at September 2022 to 309 at September 2023. Personnel costs (defined 

as salary and benefits) will be higher in FY 2024, both because of the 5.2% increase for 2024 

articulated in the president’s 2024 budget16 and because of likely additional increases due to cost 

drivers beyond pay schedules. 

Two scenarios for FY 2024 are presented in the chart above: first, a “Flat 309 Staff” scenario 

in which the FEC maintains an overall headcount of 309 employees throughout the year; and 

second, a “No-Hire” scenario where the FEC does not backfill any positions other than 

commissioners and commission staff. This second scenario results in projected year-end staffing 

level of 287. In both cases, projected personnel cost for FY 2024 will exceed the FY 2023 

16 Office of Management and Budget Budget of the U.S. Government Fiscal Year 2024. (page 51). 

16 
 

 

personnel budget – by $3.0 million in the “Flat 309 Staff” scenario and by $0.8 million in the 

“No-Hire” scenario. Both scenarios assume full utilization of the original FY 2023 personnel 

budget of $56.3 million (which the FEC did not fully utilize for personnel costs in FY 2023). 

The FEC would need an appropriation of approximately $84.7 million (an increase of 3.7% 

over FY 2023) to avoid reducing staff in FY2024 while maintaining non-personnel costs at FY 

2023 levels. 

10. The FEC Has a Smaller HR Staff and Fewer HR Resources than Medium 

Independent Agencies 

As of December 2022,17 the FEC had four HR specialists. This is the typical staffing level 

for HR specialists (0201/0203 occupation series) going back to 2018. With four HR staff, and a 

total FEC staffing level of 298, the ratio of staff to HR specialists was 74.5-to-1. The magenta 

line in the chart shows the ratio of total staff to HR specialists for the comparison group of 

medium independent agencies (sorted from largest to smallest). The blue line shows the median 

ratio of total staff to HR specialists (37-to-1). 

17 This chart uses December 2022, rather than September 2022, because the September FEC happened to have 4 HR 

specialists. The FEC has typically has four and at September month-end the FEC had experienced an HR specialist 

departure which was in the process of being backfilled. An FEC headcount of three HR specialists would have given 

a ratio of staff to HR specialists of approximately 100:1 which is atypical of FEC staffing trends. The December 2022 

headcount of four HR specialists is representative of typical FEC staffing levels for this specialization. 

17 
 

 

 

 

The FEC does use the services of OPM’s HR Solutions to provide an array of process 

supports, as well as access to specialists across various human resources functions that would be 

challenging for the FEC to hire, develop, or maintain in-house. Additionally, there is a staffer in 

administration who works approximately half-time on HR issues. This staffer and the HR 

services the FEC engages could represent the cost of up to approximately 2.5 full-time in-house 

HR specialists.18 

When these resources are added to the four full-time HR Specialists, the total FEC HR 

investment could be as high as 6.5 full-time staff. This corresponds with an adjusted staff-to-HR 

Specialists ratio of 46-to-1 which still represents only 80% of the total resource level of the 

median medium independent agency on a staff-to-HR Specialist basis. To the extent other 

medium independent agencies also engage external service providers, this comparison underestimates the extent to which FEC HR investment is below that of the comparison group of 

medium independent agencies. 

One potential mitigating factor is that FEC HR expressed confidence that the OPM service 

contract provides greater capacity, flexibility, and expertise than would be possible with 

equivalent resources devoted only to in-house FEC staffing. The OIG is not able to quantify 

these benefits but agrees in principle that OPM’s HR Solutions can leverage the FEC’s 

investment in overall human resources capacity. Nevertheless, the fact remains that the FEC has 

a lower level of HR Specialist staff and overall resources committed to human resources than 

medium independent agencies overall. This reduced level of HR staff and capacity could 

negatively impact the ability of the FEC to implement staff planning, assessment, hiring, and 

training initiatives. 

18 FEC HR provided an estimate that the FEC’s HR services could provide funding for approximately two full-time, 

in-house HR Specialist staff. FEC HR also provided the OPM Human Resources Solutions Interagency 

Agreement/Statement of Work which corroborates this estimate. 

18 
11. By September 2028 (5 years) 61.3% of Current FEC Staff Will Be Eligible to 

Retire (Either Immediate or Deferred with 20+ Years of Service) 

The FEC had 52 staff eligible for full immediate retirement as of September 2023. This is 

17.0% or approximately one-sixth of the total FEC staff. The FEC has an additional 24 staff 

eligible for immediate reduced retirement, bringing the total immediate retirement eligible staff 

to 76 or 24.9% of total staff. In five years (by September 2028), these numbers will increase to 

112 and 18, respectively – for 36.7% of all current FEC staff eligible for immediate full 

retirement and 42.6% eligible for immediate retirement overall. 

Adding in staff eligible for deferred retirement (with 20+ years of service), 61.3% of current 

FEC staff will be retirement-eligible by September 2028. The historical trend from FY 2015 

through FY 2022 is that retirements each year equal 18.3% of the number of immediate full 

retirement-eligible staff. If this trend continues, 51 FEC staff will retire during FY 2024 through 

FY 2028 leaving 64 FEC staff eligible for immediate full retirement (and 82 overall, including 

immediate reduced) as of September 2028. 

Succession planning over the next five years should focus on mitigating losses of skills, 

expertise, and institutional knowledge. 

19 
 

 

12. The FEC has Bridged Supervisory Disparities on the Basis of Gender, Though 

Disparities Persist Related to Race/Ethnicity; Further Evaluation is Warranted 

The FedScope Diversity database provides visibility into similarities and differences between 

staff segments in terms of GS level, time between promotion, salary, and supervisory status. 

These factors can be examined based on gender, age, or ethnicity/race. The table above provides 

one specific view from the Diversity database: the percentage of FEC staff and the percentage of 

FEC supervisors within each racial/ethnic group. 

The proportion of supervisors at the FEC is equal to or greater than the proportion of overall 

staff for all groups other than Black/African American. For Black/African American GS 

permanent staff, there is a notable gap in supervisory representation. The percentage of 

Black/African American GS permanent supervisors at the FEC was 23.2%, significantly less 

than this group’s overall 35.0% proportion of GS permanent staff. 

This gap is no longer present with respect to gender as the following chart illustrates: 

Because of the importance and complexity of the issues, background, strategies, and 

outcomes related to DEIA, the OIG is conducting a further review on this topic. 

20 
 

 

Review of key takeaways 

Below is an overview of the main takeaways and observations that will be examined in more 

depth in the body of this evaluation: 

• FEC staff has persistently declined over the last 20 years. 

• This decline has occurred among General Schedule (GS) permanent staff. 

• The decline is attributable to hiring, not attrition (which has been low at the FEC). 

• FEC budget growth has not kept pace with increasing GS salary levels. 

• Additional costs beyond GS salary level increases have contributed to the reduction in 

agency staffing levels. 

• Actual per-staffer personnel costs have exceeded budget justification projections. 

• The FEC will experience a budget shortfall in personnel costs if the FY 2023 

appropriation level is carried over into FY 2024. 

• The FEC has fewer HR staff than comparable medium independent agencies. 

• A significant portion of FEC staff is retirement-eligible or will be within 5 years. 

• Further examination of DEIA and EEO issues is warranted. 

Recommendations 

Recommendation 1 – Evaluate Long-Term Budget and Staffing Plans: The FEC OIG 

recommends that the FEC evaluate whether its human capital planning adequately forecasts 

long-term costs, contemplates budget uncertainty, and addresses retention, succession planning, 

development, and acquisition of personnel, experience, and skills essential to successful delivery 

of FEC mission priorities. 

Recommendation 2 – Evaluate HR Resources: The FEC OIG recommends that the FEC 

evaluate the sufficiency of HR staffing levels and of overall HR resources available to the 

agency. The FEC should, as appropriate, increase resources to levels commensurate with other 

medium independent agencies and to provide capacity for HR-related strategic initiatives. 

Recommendation 3 – Evaluate Future Budget Justifications: The FEC OIG recommends that 

the FEC evaluate data provided to OMB and Congressional appropriators to ensure budget 

justifications adequately communicate the agency’s personnel budget requirements. 

21 
 

 

 

 

OIG Summary and Observations of FEC Management Response to 

the Evaluation 

Background 

On December 19, 2023, FEC management provided a Management Response to this report. 

Subsequently, the OIG requested confirmation of Management’s concurrence status for each of 

the three recommendations from this Evaluation. As such, Management submitted an updated 

response on February 5, 2024, which is provided in full as Appendix D. FEC management 

shares a number of concerns with the FEC OIG and noted a range of successes and 

accomplishments related to budget and staffing at the agency. The Management Response also 

provided additional context and consideration for several issues, as well as some areas of 

disagreement. 

Management agreement with the three recommendations in this evaluation can be 

summarized as follows: 

• Recommendation 1: Management does not concur. 

• Recommendation 2: Management partially concurs and has addressed the issue.19 

• Recommendation 3: Management concurs, providing additional context and 

considerations.20 

The OIG would like to take this opportunity to highlight, and in some cases amplify, the key 

issues addressed by FEC management. Regarding areas of disagreement, the OIG believes that 

some may be attributable to differences in understanding concerning the data and analysis in the 

draft report. 

Overview of Management Response 

The FEC shares many of the concerns presented in the Evaluation, including concerns with 

flat funding levels at the agency, declining staffing levels, growth in campaign finance activity, 

and challenges posed by the nearly two-year lag between each fiscal year’s budget development 

and implementation. The FEC Management Response additionally cites several FEC successes 

and accomplishments, including: 

• The FEC approaches human capital planning and budget planning in an iterative, 

practical way that provides robust and context-specific strategies. 

• In FY 2022, for example, the FEC undertook assessments of staffing and budget risks 

that led to agency-wide mitigation strategies. 

19 FEC management previously evaluated agency Human Resource (HR) capacity and allocated additional resources 

to HR independent of the draft evaluation. In light of this, FEC management “considers this recommendation closed.”

20 “Management agrees with the recommendation and partially agrees with the conclusions reached by the OIG

through the analyses included in the report.” While intending to incorporate important elements of this analysis into 

its Budget document, FEC management believes the predominant factors determining budget figures were only 

partially considered. 

22 
 

• The FEC has requested and advocated for significant budget increases in FY 2023 and 

FY 2024 to end and reverse the historical decline in staffing levels. 

• The successful 9.6% budget increase request for FY 2023 allowed the FEC to increase 

staff by 5.5% by fiscal-year-end. 

• In years prior, the agency achieved operational efficiencies through revised staff plans 

and utilization of new technologies. 

• A review of the Office of Human Resources resulted in increasing the number of HR 

Specialists and overall HR capacity at the FEC. 

• The FEC approach to monitoring and evaluating the sufficiency of HR staffing and 

resources is effective and the agency considers this recommendation closed. 

• FEC budgets are developed to be executable given a range of future funding scenarios 

and timing of funding availability. 

Management raises several additional considerations and points, including: 

• The FEC must develop budgets that include all staff cohorts, not just GS permanent staff 

(general career staff). 

• The availability of funds, which is often constrained due to short-term continuing 

resolutions, introduces specific risks and operational challenges and limitations. 

• Hiring of personnel is particularly sensitive to the availability of funds both in hiring 

timelines and in budget utilization. 

• Budget development limitations exist due to OMB Circular A-11 which provides 

guidance and direction on issues such as entry salaries for new staff, within-grade pay 

increases, savings through hiring lag times, etc. 

• Finally, enterprise risk management is ultimately an agency, not OIG, responsibility. 

FEC management also raises points of disagreement: 

• Management disagrees that stagnant appropriation levels and staff reductions are a result 

of inadequate human capital planning and forecasting. 

• Management opined that the comparison group of medium independent agencies is not 

sufficiently informative because of agency-specific variation including mission 

challenges, appropriation structure, property portfolios, proportion of personnel costs, etc. 

• Management asserted that high-level analyses and comparisons with aggregate federal 

agencies do not provide specific, actionable recommendations or identify root causes; 

FEC management strategies developed from FEC-specific circumstances are more useful. 

• Management further opined that issues such as retention, succession planning, and 

acquisition of personnel, skills, and experience were addressed in relation to the prior 

OIG review of the FEC Human Capital Program. 

• In sum, “Management does not agree that information provided in the Evaluation 

supports the remediations described in Recommendation 1.” 

Management Comments to be Amplified 

The OIG thanks FEC management for the thoughtful feedback and response to the Draft 

Evaluation. We would like to emphasize a few areas raised in the Management Response. 

23 
 

FY 2023 and FY 2024 Budget Requests. The FEC budget requests for these two years represent 

requested annual increases of 9.6 and 14.5 percent, respectively, and mark a significant shift 

from requests in prior years. To illustrate how significant a shift this is, this two-year requested 

increase (FY 2023 and FY 2024) is larger than the combined requested increases of the 

preceding 13 years (FY 2010 to FY 2022).21 This may have been under-emphasized because this 

evaluation largely focuses on the seven year period ending September 2022 because FedScope 

staffing data was (and remains) incomplete for FY 2023. One additional objective of this 

Evaluation was to consider budget and staffing issues in tandem. Although the focus on FY 

2016 through FY 2022 ensured that analysis was consistent and complete for all years, it did not 

fully highlight the FEC’s FY 2023 and FY 2024 efforts to advocate for funding to develop 

agency capacity to meet growing workload. 

Human Resources Capacity at the FEC. As noted in the Management Response, the FEC 

conducted an assessment of Office of Human Resources capacity in FY 2022 and determined 

that the FEC should invest in additional capacity. The FEC, in part because of increased 

FY 2023 funding, was able to backfill a position, create and fill two additional positions, and 

(once adequate funding becomes available) will make one additional hire, bringing the total HR 

headcount to six. These activities fall outside the primary timeframe and were not fully captured 

as a result. We acknowledge this and hope this Evaluation corroborates and validates those FEC 

decisions. 

Planning and Implementation Challenges Related to Budget and Staffing. FEC management 

notes that the agency is expected to fully implement its budget regardless of the appropriation 

amount and when the agency receives it. We believe, if anything, the FEC understates the 

underlying difficulties in navigating this effort. Setting aside the nearly two-year lag between 

budget development and appropriation/use of funds (which itself is a significant challenge), the 

FEC is constrained to requesting budgets that are implementable under scenarios that range from 

a full-year appropriation to a series of persistent short-term continuing resolutions and/or 

government shutdowns. This particularly impacts hiring because prudence dictates that an 

assurance of future funding should precede executing a hiring decision. Moreover, budgets that 

are received mid-year limit the time the agency has both to conduct hiring actions and to 

subsequently utilize appropriated personnel budget for personnel costs. 

Issues Benefiting from Clarification 

There are several instances where the Management Response reflects an understanding of the 

Evaluation different than what was intended. Additional clarification where the OIG believes the 

disagreement stems from presentation rather than substance follows below. 

Role and Suitability of the Comparison Group of 32 Medium Independent Agencies. FEC 

management objects to a reliance on the comparison group of medium independent agencies. 

Management questions whether, because of agency-to-agency variation, constituent agencies can 

be comparable to the FEC and raises a broader issue of using aggregate numbers to determine 

specific goals and strategies. The OIG recognizes these issues and the corresponding limitations. 

For this reason, the Evaluation avoids terms such as “benchmark”, “standard”, or “normal” in 

21 The percentage increase in the FY 2024 budget request over the FY 2022 actual appropriation (two-year requested 

increase) is greater than the increase in the FY 2022 budget request over the FY 2009 actual appropriation (13 years). 

24 
 

 

 

 

 

reference to the comparison group. The OIG’s view is that comparison group characteristics are

primarily useful by providing context in conjunction with FEC-specific considerations. For 

example, comparison group statistics show that the increase in average GS-level of FEC general 

schedule staff is consistent with overall trends in federal employment. By contrast, the 

comparison group suggests that the decline in FEC staffing levels is atypical.22 

Value and Appropriateness of the Evaluation Methodology. FEC management states that the 

method of comparison to medium independent agencies cannot be “sufficiently informative to 

override the mitigation strategies Management has identified” or provide “uniformly actionable 

and specific takeaways.” The OIG agrees on both counts. It is not the intention of this 

Evaluation to override management’s risk mitigation strategies or to supplant operating 

processes. Rather, this Evaluation is intentionally high-level to consider broad trends and 

patterns and identify potential causes and relationships between them. 

Analysis Should be Based on All Staff Cohorts. The Management Response objects to the 

Evaluation’s focus on GS permanent staff (excluding Commissioners, Commission Staff, and 

Senior Leaders) on the grounds that all staff cohorts are integral to agency function and that, 

regardless, FEC management must budget for and support all cohorts. The OIG agrees that FEC 

management must plan for, budget, and support all staff cohorts. However, the OIG generally 

focused on GS permanent staff because the other cohorts differ significantly in areas as 

fundamental as how they are hired, how much they are paid, how long they remain at the agency, 

and so on. For example, when all staff are considered, the FEC attrition rate is over 10% per 

year – on par with the comparison group. When looking at GS permanent staff only, the attrition 

rate is only 8%, significantly lower than the comparison group. This difference is due to the very 

high attrition rate of commission staff – more than 20% per year, on average. As such, the 

inclusion of commission staff obscures, rather than informs, an important historical dynamic of 

FEC employment: that FEC career staff have lower turnover and remain at the agency longer 

than career staff in the comparison group of federal agencies. 

Responsibilities of FEC Management and the OIG. The Management Response notes that the 

FEC has previously considered and evaluated the primary concerns in Recommendation 1 

through its Enterprise Risk Management process, and that the resulting mitigation measures are 

“more accurate” and “more meaningful” than those proposed in the OIG recommendations. 

Management states that “enterprise risk management is ultimately a management responsibility.” 

It is not the intention of this Evaluation to assume risk management responsibility or to “override 

mitigation strategies” identified by FEC management. It nevertheless remains the responsibility 

of the FEC OIG “to provide leadership and coordination and recommend policies for activities 

designed to promote economy, efficiency, and effectiveness in the administration of...such 

programs and operations”23 so that management may “[use] the results of such evaluations,

including accompanying findings and recommendations, to monitor the design or operating 

effectiveness of these systems.”24 

22 Of the 31 non-FEC agencies in this comparison group, five had staffing level declines greater than the FEC (an 

average of 16.9% compared to the FEC’s decline of 11.5%). The remaining 26 agencies experienced an average 

staffing level increase of 4.7%. 

23 See 5 U.S.C. §402 Establishment and purpose of Offices of Inspector General. 

24 See OMB Circular A-123. 

25 
 

 

 

 

Areas of Disagreement 

The Management Response states that “Management does not agree that information 

provided in the Evaluation supports the remediations described in Recommendation 1.” Several 

reasons are cited for this conclusion and include: that the FEC already conducts strategic risk 

analysis along with personnel and budget planning, that high-level conclusions derived from this 

evaluation are less specific and actionable than management-developed strategies and processes, 

that other federal agencies do not provide suitable points of comparison, that aggregate statistics 

are less relevant than FEC-specific analysis, and that several elements of the recommendation 

were addressed through a prior OIG audit. Management also asserts that the development and 

implementation of management processes are its responsibility, not that of the OIG.25 

We understand based on management’s response to this and the prior Human Capital Audit

that management is skeptical of the value of implementing an integrated Human Capital Plan as 

provided in OPM’s Human Capital Framework.26 The OIG appreciates that such an 

implementation would come with costs that include time, energy, and focus. But the process 

could provide benefits that may be currently under-realized. For example: retirement forecasting 

at the departmental/functional level to develop targeted training and recruitment plans, key skill 

gap analysis resulting in long-term recruitment and development strategies, or 

management/performance/evaluation systems that span the strategic, operational, and employee 

levels. Further, although FEC management (correctly) states that a Human Capital Planning 

program does not ensure higher appropriation levels, it is the view of the OIG that such a 

program has the power to inform, refine, and improve the process and final product of the budget 

development and request process. 

Lastly, the objective of providing the information in this Evaluation is not to demand that the 

FEC request additional funding and increase staffing levels as management stated in its response, 

but rather to provide measures and descriptive statistics that relate to the declining staffing levels 

despite significant growth in federal campaign funding. Specifically, this Evaluation identifies 

factors that have adversely impacted the FEC’s ability to secure funding levels that would enable 

the agency to maintain adequate staffing levels. 

Recap of Recommendations Status 

Management agreement with the three recommendations in this evaluation can be 

summarized as follows: 

• Recommendation 1: Management does not concur. 

• Recommendation 2: Management partially concurs and has addressed the issue. 

• Recommendation 3: Management concurs, providing additional context and 

considerations. 

25 See footnote #23. 

26 See https://www.opm.gov/policy-data-oversight/human-capital-framework/. 

26 
 

 

 

 

 

 

 

 

 

 

Analysis and Methodology: Evaluation of Staffing, Budget, HR, and 

Workforce Risks at the FEC 

Introduction 

In January 2023, The Office of Inspector General (OIG) at the Federal Election Commission 

(FEC) initiated an evaluation of attrition, staffing and related issues at the FEC. This evaluation 

follows up on the OIG’s Audit of Human Capital Management Program for Fiscal Year 2022.27 

The backdrop for this evaluation is that staffing levels at the FEC have persistently declined 

despite significant growth in federal campaign funding and corresponding workload. Some 

indicators of potential challenges and risks to the FEC related to its workforce include: 

• The FEC has reduced several key performance benchmarks to align performance 

expectations with available capacity.28 

• The FEC ranked 26 out of 30 in the 2022 Best Places to Work29 rankings for small 

federal agencies.30 

• In the 2022 Federal Employment Viewpoint Survey (FEVS), 34.8% of responding 

FEC staff indicated that they are considering leaving the organization.31 Small agency 

respondents said yes to this question 22.5% of the time. 

This evaluation is based primarily on a review of quantitative data and focuses less on 

qualitative assessments of specific policies, procedures, or goals. The primary data source for 

this evaluation is the Office of Personnel Management (OPM) database of Federal Workforce 

Data (FedScope).32 This public database provides detailed visibility into most federal 

departments and agencies. 

This report also uses publicly available data in the form of public FEC documents and 

various governmental and private sector data sources. The only analysis driven by FECprovided information in this evaluation is the retirement eligibility discussion.33 

The primary goal of this evaluation is to produce specific measures and statistics for various 

aspects of the FEC’s overall HR, staffing, and demographic profile. These measures may serve

as confirmation of FEC accomplishments, indications that further work is needed, and/or 

27 https://www.oversight.gov/sites/default/files/oig-reports/FEC/IPA-Audit-Report-FEC-HCM-Program-42523.pdf 

28 See footnote 1. 

29 https://bestplacestowork.org/rankings/?view=overall&size=small&category=leadership& 

30 Note that the OPM “small agency” grouping used for the Federal Employee Viewpoint Survey is not identical to

the OPM “medium independent agency” grouping in FedScope. 27 of the 32 medium independent agencies in

FedScope are included as “small agencies” in FEVS data. 

31 Question language: Based on your work unit’s current telework or remote work options, are you considering leaving

your organization, and if so, why? 

32 https://www.fedscope.opm.gov/ 

33 A hiring action dataset provided by the FEC was also used to corroborate HR’s claim that the FEC’s use of OPM’s

HR Solutions services had improved the agency’s hiring process; we found that average time-to-hire has been reduced 

by approximately 37 days. 

27 
suggestions for future process improvements. The high-level set of questions this evaluation 

answers include the following: 

• What has driven the decline in FEC staffing levels? 

• What factors have contributed to personnel budget deficits? 

• What staff level is possible for FY 2024 under varying budget scenarios? 

• Is the FEC adequately resourced in terms of HR capacity? 

• Is FEC performance at risk because a significant portion of staff is eligible to retire? 

• Are there differences in position and responsibility associated with demographic 

factors such as gender or ethnicity/race? 

Staffing Levels at the FEC Have Persistently Fallen While Federal Campaign 

Fundraising Has Steadily Increased 

The staffing level of the FEC hit a 25-year low in September 2022 at 293 employees.34 This 

represents a 22.7% decline in staff level from the all-time high of 379 in 2005. Over the 20-year 

period from 2002, federal campaign fundraising has increased approximately four times and the 

number of contributions has increased exponentially to over a half-billion transactions per 

election cycle. 

34 Initial feedback from FEC management cautioned that this evaluation should maintain a clear distinction between 

“staffing levels” and FTEs. Staffing level refers to the number of employees on board at a given time. FTEs are a

budgetary measure for the actual number of hours worked divided by total annual scheduled hours (typically 2,080 

hours). The FY 2022 year-end staffing level of 293 at September 2022 illustrates this distinction. The FEC staffing 

level fell from 304 to 293 from September 2021 to September 2022. FEC management noted that the overall FTE 

level for FY 2022 was “closer to 296”. The first statistic is a point in time measure, the second is a period measure. 

28 
Chart 1: FEC Headcount and Campaign Contribution Volumes, 2002 through 2022 

The long-term decline in staffing and increase in fundraising volumes is well known and 

appears in various FEC publications and FEC OIG reports. The chart above presents the decline 

both in overall FEC staff (red) and GS permanent staff (blue). It also displays campaign 

contribution activity both in terms of dollars and transaction numbers. Contribution activity has 

increased dramatically since the 2016 presidential election cycle. 

This evaluation will focus on the period covering the 2016 presidential election to present –

specifically FY 2016 through FY 2022. This timeframe provides a balance between establishing 

longer-term averages and trends with specific current conditions and circumstances. This recent 

period is also most consistent with the current state of IT infrastructure, data management 

processes, and data warehousing and serving approaches. 

29 
 

 

 

Chart 2a: Medium Independent Agencies Have Not Had Corresponding Staffing Level Declines 

(Total Staff) 

The decline in staffing levels at the FEC is not typical of broader trends in federal 

employment among medium independent agencies. FedScope Federal Workforce Data includes 

an agency segment titled “medium independent agencies,” which are independent agencies with 

between 100 and 999 staff. Thirty-two agencies fall within this group and range in size 

approximately one-third the size to three-times the size of the FEC.35 

Total employment among medium independent agencies increased slightly over the period 

from FY 2015 to FY 2022 by 0.5% from 12,217 to 12,284 employees. Total employment at the 

FEC declined by 11.5% from 331 to 293 over this same period. If FEC staffing levels had 

matched the staffing level growth of medium independent agencies overall, it would have 

increased 0.5% from 331 staff in September 2015 to 332.8 in September 2022. The gray line in 

the chart illustrates what the FEC staffing levels would have been over this period if they had 

proportionally tracked the increases/decreases in medium independent agency staffing over this 

time period. 

35 For further discussion of composition of the group of medium independent agencies and methodological approaches, 

see Appendix B. 

30 
Chart 2b: Medium Independent Agencies Have Not Had Corresponding Staffing Level Declines 

(General Schedule Permanent Staff Only) 

FEC staff is predominantly composed of general schedule, non-seasonal full-time permanent 

employees (GS permanent). The FEC GS permanent staffing level decreased by 41 employees, 

or 13.5%, over the September 2015 to September 2022 timeframe. Medium independent agency 

GS permanent staffing fell 0.5% from 6,577 to 6,546 over this same timeframe. The FEC is one 

of the 32 agencies comprising the medium independent agency comparison group (see Appendix 

A for further discussion). If the FEC were excluded from the comparison group, the GS 

permanent staffing levels for medium independent agencies would have increased by 10 

employees. 

31 
Chart 3: FEC Headcount by Staffing Segment, FY 2015 through FY 2022 

 

Over the last seven years, the reduction in staffing levels at the FEC occurred entirely within 

the GS permanent segment of FEC staff. Non-GS permanent staff increased from 27 in 

September 2015 to 30 in September 2022. This evaluation focuses primarily on the GS 

permanent segment of FEC staff for this reason. There are additional benefits to prioritizing GS 

permanent staff in this analysis: 

• Commissioners are Presidentially Appointed and Senate-confirmed (PAS) positions 

provided by statute and thus fall outside of agency management. 

• Commission staff are a function of the number of commissioners, thus an extension 

of the same political framework. Commission staff are often not career federal 

employees and exhibit distinctive hiring and attrition patterns. 

• The number of Senior Leader (SL) positions has been relatively stable. Moreover, 

the SL category is the primary management staff type for just 19% of medium 

independent agencies (Senior Executive Service is more common). 

• GS permanent staff comprise approximately 90% of FEC staffing overall. 

• GS permanent staff are widely used at other independent agencies, allowing FEC 

staffing profiles and trends to be compared broadly against other agencies. 

• When FEC budget justifications call for changes in staffing levels at the FEC, these 

changes are targeted to the GS permanent staff type. 

• GS permanent staff are the segment that primarily conducts and supports the work to 

deliver on FEC mission objectives. 

From September 2015 to September 2022, GS permanent staffing declined 13.5% from 304 

to 263. A consequence of this is that the ratio of non-supervisory to supervisory staff fell from 

32 
 

 

3.5-to-1 in September 2015 to 3.0-to-1 in September 2022.36 The fact that the number of 

supervisors remained constant suggests that the number of organizational functions and 

processes did not decrease along with the reduction in staffing level. The decline in nonsupervisory staff indicates that there are fewer staff resources to “do the work” within these

processes and functions. 

An additional consequence of reducing the number of workers per supervisor by 0.5 from 3.5 

to 3.0 is that this inherently increases team-and mission-delivery pressures for supervisors. This 

situation may also increase the need for supervisors to perform tasks that would have been 

delegated had there been more personnel, which introduces organizational costs. Additionally, 

the situation introduces opportunity costs as supervisors have less time available to perform 

value-added activities such as strategic planning, training, recruiting, and performance 

measuring, and monitoring. 

The FEC Has a Below-Average Attrition Rate; Reductions in Staff Size are the 

Result of Even Lower Rates of Hiring 

Chart 4: Staff Attrition at the FEC is Low and is not the Primary Cause of Staffing Declines 

The decline in FEC staff size is not attributable to high rates of attrition. To the contrary, the 

FEC has experienced a below-average 8.0% annual rate of attrition for GS permanent staff over 

the period September 2015 to September 2022. Medium independent agencies, by contrast, 

experienced a corresponding10.4% average annual rate of attrition during this period. The FEC 

experiences approximately three staff departures for every four departures among the 

36 The number of permanent-staff supervisors at the FEC remained nearly flat – dropping from 74 in 2015 to 73 in 

2022. Non-supervisory staff dropped from to 257 to 220. 

33 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

comparison group. This includes separations of all types: retirement, transfer to another agency, 

termination, death, taking private sector employment, etc.37 

The FEC annualized rate of hiring was 6.3% for fiscal years 2016 through 2022. As a result, 

the FEC has not been able to backfill or replace staff at the same rate as staff depart the agency. 

The rate of hiring has been 1.7% lower per year on average than the rate of staff separations and 

this imbalance produces the decline in FEC staffing levels. Unlike the FEC, medium 

independent agencies have generally maintained parity between their rates of attrition and rates 

of hiring. The annual rate of hiring has averaged 10.3% per year at medium independent 

agencies, on par with the 10.4% rate of separations. 

FEC Budgets Have Not Kept Pace with Cost Increases 

FEC appropriations growth has not kept pace with inflation or cost increases, whether 

measured by the Consumer Price Index or by increases in the general schedule pay table for the 

Washington, DC locality. The FEC’s FY 2022 appropriation of $76.5 million was 10.4% greater 

than the $67.5 million appropriation for FY 2015. In FY 2016, the FEC received a 5.4% 

increase in appropriations from to $71.1 million from $67.5 million. The next five years saw 

average annual appropriations increases of just 0.1% to $71.5 million for FY 2021. FY 2022 

saw a 4.2% increase to $74.5 million.38 FY 2016 is the recent high-water mark for FEC 

appropriations when adjusted for costs.39 The FEC ended FY 2016 with 328 total staff and 303 

GS permanent staff. 

37 In the OIG internal review of data and findings, one theory for the lower attrition rate at the FEC is that FEC staff 

are excepted service (not competitive service) and that this creates barriers for FEC staff seeking to transfer to other 

federal agencies where positions are largely competitive service. There is evidence that this is partly the case. Looking 

at FY 2020 through FY 2022, the FEC attrition rate for GS permanent staff was 7.7%. This is lower than the 8.8% 

attrition rate for medium independent agency GS permanent staff when narrowed to excepted service staff (excluding 

schedule C/pathways). Competitive service GS permanent staff at medium independent agencies experienced a 9.4% 

attrition rate over this period. At medium independent agencies, excepted service staff have a 0.6% lower attrition 

rate than competitive service. FEC staff (all excepted service) have a 1.1% lower rate of attrition than excepted service 

staff at medium independent agencies and a 1.7% lower rate than competitive service staff at medium independent 

agencies. This suggests (on preliminary investigation) that the excepted service could create an impediment to 

mobility (and thus reduce attrition) and may account for roughly one-third of the total differential between the FEC 

and medium independent agency attrition rates. 

38 The FEC appropriation for FY 2023 increased 9.6% over FY 2022 to $81.674 million. This increase is almost equal 

to the total seven-year FEC appropriation increase for FY 2015 to FY 2022. The FY 2023 appropriation is equivalent 

to $63.1 million FY 2015 dollars when discounted by the CPI, or $65.5 million FY 2015 dollars when discounted by 

increased in the GS pay table for Washington, DC. These are both lower than the $67.5 million actual appropriation 

for FY 2015. 

39 This is true even including the FY 2023 appropriation of $81.7 million which was a 9.6% increase over FY 2022. 

34 
Chart 5: FEC Appropriations, Inflation-Adjusted Appropriations, and Campaign Contribution 

Volumes, 2015 to 2022 

The general schedule, which establishes compensation rates for GS-level employees, 

increased 17.6% from September 2015 to September 2022. The FEC would have needed an FY 

2022 appropriation of $79.4 million to be at parity, when adjusted for general schedule increases, 

with the FY 2015 appropriation of $67.5 million. However, the actual funding level for FY 2022 

was $4.9 million less than this at $74.5 million. 

The FEC did receive a 9.6% increase in funding for FY 2023 from $74.5 to $81.7 million. 

This increase has helped reverse the long-term decline in cost-adjusted appropriations, but it did 

not fully bridge the gap. For FY 2023, the FEC would have needed $2.5 million more, or $84.2 

million, to maintain parity with its FY 2015 appropriation level after absorbing the 4.86% 

increase in the 2023 general schedule pay table for the Washington, DC locality. 

35 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Chart 6: The Decrease in the FEC’s Inflation-Adjusted Appropriation is Not Typical of Medium 

Independent Agencies. 

When adjusted for inflation, FEC appropriations fell 3.0% from FY 2015 to FY 2023.40 FEC 

appropriations increased 21.0% over these 8 years and did not keep pace with the 24.7% increase 

in the Consumer Price Index (CPI).41 The FEC’s decline in inflation-adjusted appropriations is 

not reflective of federal medium independent agencies overall. Medium independent agencies 

experienced an increase, on average, of 2.3% in inflation-adjusted appropriations from FY 2015 

to FY 2023.42 Smaller agencies within this group tended to have somewhat stronger 

appropriations growth levels. 

The total inflation-adjusted increase in appropriations for medium independent agencies was 

1.0%. To distinguish this statistic from the 2.3% above, the 1.0% increase represents the change 

in total aggregate funding for the for the collective group of medium independent agencies, 

whereas the 2.3% increase is the average of the agency-by-agency increases when adjusted for 

40 For this chart, FY 2023 (not FY 2022) was used as the final year. Although this Evaluation generally focuses on 

the period FY 2015 through FY 2022, it was important to include FY 2023 for this comparison because of the 9.6% 

increase the FEC received for FY 2023. For the period FY 2015 through FY 2022, the FEC’s inflation-adjusted 

appropriation fell 4.2%. 

41 CPI was used rather than GS pay table increases because the comparison group of agencies have a variety of levels 

of personnel costs in proportion to their overall budget. Over this 8-year period, general schedule increases totaled 

22.7%. CPI can be helpful because it potentially captures increases beyond compensation such as rising health 

insurance costs. Benefits costs at the FEC added just under 30 cents per dollar of employee compensation to the total 

cost of personnel in FY 2015, for example. By FY 2023, benefits added over 36 cents per dollar of employee 

compensation, increasing personnel costs beyond those driven by GS pay table increases alone. 

42 Four medium independent agencies were excluded because they either lacked a FY 2015 or FY 2023 appropriation 

number or are funded through other mechanisms. These include the Presidio Trust, the Federal Housing Finance 

Agency, the Judicial Branch (Executive Branch component in FedScope), and the Federal Retirement Thrift 

Investment Board. The Overseas Private Investment Corporation was also excluded because it is an outlier with a 

3.5-fold increase in appropriations. When OPIC is included, the average (equal agency weight) increase is 8.7% and 

the average (dollar-weighted) increase is 4.9% for the period. 

36 
 

 

 

 

 

 

 

 

 

 

 

inflation. The FEC decline in inflation-adjusted appropriations is not reflective of trends in 

either individual agency or overall agency funding. 

Actual Per-FTE Costs Have Been Higher than Budget Justification Estimates; 

Corresponding Actual FTE Levels Have Been Lower Than Projected 

The FEC submits budget justifications for each fiscal year that include an overall budget 

request amount and a projection for how many FTEs that amount would provide for.43 Over this 

seven-year period, the FEC has received nearly all the funds it requested but has fallen short of 

achieving the FTE target included within those budget justifications. Actual personnel costs (in 

compensation and benefits) on a per-FTE basis have consistently been greater than the per-FTE 

costs projected in the budget justifications. 

Table 1: Under-Estimation of per-FTE Costs and Over-Projection of Staff Levels 

Projected and actual change in FTEs, FY2016 through FY2022 

Projected increase in FTEs over prior year at full funding 24.4 

Actual FTE increase (decrease) (4.5) 

Difference (29.0) 

Projected and actual per FTE costs (compensation and benefits) 

Projected average cost per FTE in budget justifications $ 146,767 

Actual average cost per FTE $ 155,248 

Difference $ 8,481 

For the years FY 2016 through FY 2022, the FEC was appropriated 99.2% of its full budget 

request, on average.44 This would suggest that the FEC received budgetary resources sufficient 

to support 99.2% of the staff and program deliverables included within those budgets, including 

FTE levels. Actual FTE levels45 for FY 2016 through FY 2022 have not reached 99.2% of the 

levels articulated within FEC budget justifications. In fact, the average actual FTE level was 

43 FTE is used here as the technical budgetary measure defined by GAO as: “the total number of regular straight-time 

hours (i.e., not including overtime or holiday hours) worked by employees divided by the number of compensable 

hours applicable to the fiscal year, as defined by the Office of Management and Budget, Circular No. A-11...”

FedScope does not provide a direct measure of FTEs. 

44 We are excluding a $5.0 million lease expiration expense included for FY 2016 and an $8.0 million lease expiration 

expense included for FY 2017. 

45 The level of FEC FTEs has been estimated by taking the average quarterly staffing level in FedScope (calculated as 

beginning level + ending level / 2) and averaging the four quarters that comprise each fiscal year to estimate the actual 

annual FTE level. This approach will produce a close, but not precise, approximation of FTEs. For example, 

variations in onboarding/offboarding timing within a quarter will cause some variation in the FTE counts produced 

by this approach compared to those produced by summing total hours in FEC payroll records. These variations will 

be small, however: the average difference between quarterly beginning and ending staffing levels (4 employees) is 

1.3% of total staff (just over 300 employees). Thus, the approximated FTE level using FedScope will be 0.65% 

different than the beginning and ending quarterly staffing level values. 0.65% is the maximum potential error under 

the assumption that all personnel changes occur on either the first or last day of the quarter. To the extent average 

personnel changes occur throughout a quarter, the estimator becomes more precise – and to the extent that some 

estimates are high and some are low, these “come out in the wash” and increase the accuracy of the estimator yet 

again. 

37 
 

 

only 91.6% of the full-budget projection, 7.6% lower than the 99.2% (translating to 

approximately 23 FTEs). 

Take FY 2018 as an example. The FEC requested and received a $71.25 million 

appropriation. The budget justification stated: “The FY 2018 Funding request takes into 

account full year funding for up to 345 FTE for FY 2018.”46 Although the FY 2018 request was 

fully funded, the actual FTE count was approximately 315.47 A material factor in the decline in 

staffing levels is that the budget justification projected lower per-FTE costs than were actually 

incurred. 

The FY 2018 per-FTE cost (compensation and benefits divided by projected supportable 

FTEs) was $140,784. The actual per FTE cost (year-ending compensation and benefits divided 

by FTEs) was $147,245, which was $6,460 greater than the projected cost per FTE. These 

numbers are illustrated in the chart below, which present’s the FEC’s projected and actual costs 

per FTE for all seven budget justifications for FY 2016 through FY 2022. 

Chart 7: Historical Comparison of Actual and Projected per-FTE Costs 

Budget justifications are tools to quantify and articulate the need for requested budgetary 

funds to carry out agency mission priorities. Personnel are an essential component of this 

delivery and represent roughly 70% of the FEC’s budget. The average gap between budget 

46 Federal Election Commission Fiscal Year 2018 Congressional Budget Justification. 

47 The FEC staffing level in FedScope began at 322 in September 2017, falling by quarters to 319, 315, 313, and 

ending at 304 as of September 2018 for an average of 315. 

38 
 

 

 

 

 

justification FTE levels (desired staff level) and actual FTE levels (person-years worked) has 

been approximately 29 FTEs. 

Put another way, the FEC has typically employed 29 fewer full-time employees than were 

articulated in the corresponding budget justifications as the desired number to meet mission 

requirements. The follow three ratios will help to place this FTE shortfall within various 

components of the budgetary process: 

• Ratio of actual appropriation to requested appropriation – 99.2%. 

• Ratio of actual personnel budget (compensation/benefits) to requested personnel 

budget – 96.9%. 

• Ratio of actual FTEs to budget request level of FTEs – 91.6% (8.4% below full 

request level) 

The average 29 FTE difference between actual and requested FTE levels represents a 

shortfall of 8.4% of the total requested FTE level. Using the ratios above, we can segment this 

average 29-FTE shortfall into three categories: 

• Receiving less than full appropriations (calculated as the 0.8% less than full request) 

– 3 FTEs. 

• Allocating a smaller proportion of appropriated budget to personnel costs 

(compensation and benefits) than was articulated in the budget justifications 

(calculated as difference between 99.2% average appropriation and 96.9% average 

budget-to-justification level: 2.8%) – 8 FTEs. 

• Higher average actual costs than budget request cost projections (calculated as 

difference between 96.9% budget and 91.6% FTE level: 5.3%) – 18 FTEs. 

When comparing actual FEC staffing levels to prospective FTE levels in FEC budget 

justifications, the fact that actual per-FTE costs were higher than projected levels accounts for 

almost 65% of the overall 29-FTE difference.48 Agency decisions to allocate slightly more of the 

budget to uses other than personnel (compared to budget justification personnel/non-personnel 

proportions) account for approximately 25% of the total 29-FTE shortfall.49 Appropriation 

levels below the full request amount are least significant and account for the remaining 10%. 

It should be noted that budget request development is not fully within the control of FEC 

budget managers (OMB plays a role in budget development, for example). Additionally, there is 

a two-year lag in the budget development and submission timeline between each given request 

year and most recent complete fiscal year at time of budget submission. 

48 One explanation for this could be that future cost increases in GS schedule, staff structure, and benefits are not fully 

incorporated. The OIG recognizes the challenge in doing this, particularly given the budget request process’s twoyear lag between requested and last-final fiscal years. 

49 This could suggest that new or not-fully-anticipated priorities emerge between the time budget proposals are 

submitted and when the budget is implemented. Again, note the two-year time gap. 

39 
 

 

 

 

 

 

 

 

 

 

 

Personnel Cost Drivers go Beyond General Schedule Salary Increases 

If the FEC plans to retain (or grow) its staffing level, it is not sufficient to request budget 

increases that merely keep pace with increases in the general schedule. Cost drivers beyond the 

increases in the general schedule pay table have further reduced the number of staff the FEC is 

able to support. Three notable elements driving costs up are: increasing rates of benefit costs, a 

shift in the FEC workforce toward higher grade (more expensive) employees, and higher average 

step levels within grade that correspond with increases in average length of service of FEC 

employees. Each of these imposes additional personnel costs beyond general schedule increases. 

Table 2: Historical Growth of Overall and Per-FTE Personnel Costs FY 2015 to FY 2022 

Overall Growth of FEC Budget for Personnel FY 2015 to FY 2022 

FY 2015 FY 2022 Increase as % 

Total FEC Budget (actual) 67,251,547 74,173,320 

Personnel Costs 

Compensation (actual) 34,799,225 37,880,609 

Benefits (actual) 10,401,868 13,908,013 

10.3% 

8.9% 

33.7% 

Total Comp and Bens 45,201,093 51,788,622 

% of Benefits to Comp 29.89% 36.72% 

14.6% 

22.8% 

Growth of FEC Personnel Costs per FTE, FY 2015 to FY 2022 

Staff level (estimated FTEs)

50 326.4 296.4 -9.2% 

Avg compensation/FTE 106,614 127,702 19.9% 

Avg Benefits/FTE 31,868 46,923 47.2% 

Total Comp and Benefits per 

estimated FTE 138,484 174,725 26.2% 

Source: Yearly actuals as presented in FEC Budget Justifications to Congress and estimated 

fiscal year FTE levels in FedScope. 

FEC spending on compensation and benefits increased 14.6% from $45.2 million to $51.8 

million over the period FY 2015 to FY 2022. The overall FEC budget has increased only 10.3% 

over the same period – and the higher rate of personnel spending has been at the expense of nonpersonnel costs which have risen only 1.7% over this period from $21.3 million to $21.7 million. 

Benefits costs, as a percentage of compensation, have risen from 29.9% ($29.90 per $100 in 

compensation) in FY 2015 to 36.7% ($36.70 per $100 in compensation) in FY 2022. 

50 Estimated FTEs are calculated by taking the average quarterly number of employees (start + end / 2) in FedScope 

and averaging this for all four quarters in each fiscal year. FY 2016, for example, the employee headcount in FedScope 

was 331 at September 2015 and by subsequent quarters: 330, 321, 325, and finally 328 at September 2016. This yields 

an approximation of FTEs of 326.4. Similarly, the average of quarterly average employment levels for FY 2022 yields 

296.4 FTEs. FEC management provided informal feedback that the initial draft had not clearly distinguished between 

staff on board and FTEs, noting: “The total FTEs for FY 2022 is closer to 296” (as opposed to staff on board of 293).

The OIG acknowledges a degree of imprecision in FedScope-based estimates of FTEs but believes that the degree of 

imprecision is minor when compared to the magnitude of overall cost growth and does not alter analysis conclusions. 

40 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

On a per-FTE basis, the actual average FTE employee cost 26.2% more in FY 2022 than in 

FY 2015. Average compensation per FTE increased 19.9% (exceeding the GS increase of 

17.6%) from $106,614 to $127,702 and benefits per FTE increased 47.2% from $31,868 to 

$46,923.51 The total cost to maintain FY 2016 staffing levels (326.4 FTEs) at the FY 2022 cost 

level ($174,725/FTE) would be $57.03 million, $5.24 million more than the $51.79 million 

budgeted and spent to support 296.4 FTEs. The $57.03 million required to support the FY 2016 

FTE level of 326.4 given FY 2022 costs is 9.2% greater than the actual compensation and 

benefits budget for FY 2022. 

Impact of Compounding Components of Personnel Costs 

In thinking about overall personnel costs, it is helpful to distinguish between the following 

three factors that drive total costs: 

• General schedule pay table increases (using DC locality GS pay table). 

• Changes to the mix of positions and corresponding compensation costs. 

• Increasing level of benefits cost as a percentage of compensation. 

Chart 8: Components of Total Personnel Cost 

General 

Schedule 

Costs 

(+17.6%) 

 x changes in 

staff structure 

Direct 

Compensation 

Costs 

(+24.1%) 

x changes in 

benefit costs 

Total 

Compensation 

and Benefits 

(+30.8%) 

Note on methodology: The figures in this chart reflect GS permanent personnel cost 

increases from September 2015 to September 2022. This approach focuses on GS permanent 

staff52 and corresponds better to general changes in costs and how they may impact future 

budgetary planning.53 

51 Total benefits cost increases are the compounded product of the increase in benefits cost per dollar of compensation 

times the increase in compensation costs. Benefits cost 22.8% more per dollar of compensation in FY2022 compared 

to FY2015, and compensation increased 23.0%. In this case, 1.199 x 1.228 = 1.510 for a 26.2% increase per FTE. It 

is worth noting the various cost drivers multiply against each other (do not add) which increases the long-term impact. 

52 There are eight Executive Schedule positions at the FEC: six commissioners, general counsel, and staff director. 

These positions are critical to agency success, management, and governance, but have not seen increases in several 

years. This has been cited in recent OIG Management Challenges reports as potentially negatively affecting 

recruitment, retention, morale, and effectiveness. From a budgetary perspective, the 2022 commissioner salary levels 

were collectively $193,800 less than they would have been if they had experience agency-average increases over the 

seven years. This represents a full 0.5% reduction in overall agency compensation costs. 

53 The preceding section used actual full-year historical budget figures, which are helpful in understanding the history 

of FEC personnel funding costs from FY 2015 through FY 2022. However, there are idiosyncrasies in any given 

fiscal year that can materially affect full-year expenditures but that may not be generalizable. For example, the first 

quarter of a fiscal year uses a different pay table than the following three quarters (October-December 2021 use 2021 

pay tables while January-September 2022 use 2022 pay tables, for example). This can impact the full-year budget if 

41 
The GS pay table for Washington, DC increased 17.6% from September 2015 to September 

2022. Average GS permanent compensation increased 24.1% over this same period, from 

$99,920 to $124,079. This is a result of increasing average GS levels and higher pay steps 

within the GS permanent staff (further discussion follows) which increase average GS permanent 

compensation costs by 5.5%. This GS level/pay step increase is compounded with the 17.6% GS 

pay table increase. Finally, benefits increased from 29.9% to 36.7% of total compensation.54 

This results in an overall 30.8% increase in GS permanent compensation and benefits from 

September 2015 to September 2022. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Increasing Grade Levels at the FEC 

Three cost factors shape personnel compensation growth among GS permanent staff beyond 

increases in base pay tables: increases in average GS grade level (GS-13 vs. GS-12 for 

example), increases in average step within grade (step 6 vs. step 5 for example), and the capping 

of GS-15 staff at the statutory maximum annual compensation (this is a mitigating factor that has 

slowed growth of FEC personnel costs). These three factors combined to account for the sevenyear increase in per-employee compensation of 24.1% rather than 17.6% (per the general 

schedule). 

For the purposes of looking at grade, step, and GS-15 cap impacts on cost structure, we will 

narrow our focus to GS permanent staff based in Washington, DC.55 This group comprised 300 

of 331 staff as of September 2015 (90.6%) and 260 of 293 staff as of September 2022 (88.7%) 

and could be described as the FEC “workforce”.56 This approach excludes the following three 

segments of FEC staff: commissioners, senior leaders, and commission staff (temporary 

appointments).57 

the staff level is increasing (disproportionately in the higher pay table) versus decreasing (disproportionately in the 

lower pay table) because of the relative weighting of the lower-cost and higher-cost periods. 

54 Here is a practical example of the importance of accurately projecting benefits costs: The FEC FY 2024 budget 

justification used a benefits cost estimate equal to 32.8% of salary. FY 2020 through FY 2022 had actual benefits 

costs equal to 34.0%, 35.4%, and 36.7% of salary, respectively. These fiscal years were all complete before FY 2022 

budget request was submitted. Benefits increases are a long-term trend – rising from 29.9% of salary in FY 2015 to 

36.8% in FY 2022. The trend would suggest potential range of 37% to 39% for benefits as a percentage of 

compensation. This would require between $2 and $3 million in increased budget to fully fund this cost. 

55 This excludes SL management, commissioners, and commission staff. Although commission staff are paid in 

accordance with the GS pay table, they exhibit distinctive characteristics when compared to career staff. First, 

commission staff are all GS-15. Second, more than three quarters of commission staff are paid in steps 7-10 (GS 

schedule max). The mean step level (using step 7 as the max) is 6.7. However, the median length of service for 

commission staff is less than 2 years. Step 6.7 implies 8.4 years of service under the normal length of service step 

progression. Third, the number of commission staff has increased, whereas GS permanent staff have decreased over 

the seven year period. As such, commission staff are atypical and could skew the trends that are present among career 

GS permanent staff. The restriction to DC-based staff removes up to four staff (September 2022 had 303 GS 

permanent staff and 300 DC-based permanent staff, for example) and this exclusion is made to ensure direct 

comparability with DC-based staff within the medium independent agency comparison group. Source for pay and 

length of service data: FedScope. 

56 The segment of the staff that gets the day-to-day work done. 

57 Excluding commissioners and senior leadership should be intuitive because neither group is paid according to the 

general schedule or has a formalized “step” system of time-in-grade pay increases. Commission staff, though general 

42 
 

 

 

Table 3: Shift in Composition of GS Levels of FEC Workforce; Change in Average GS Level 

for GS Permanent Staff - 2015 to FY 2022 

GS Grade 

Level 

Sep 

2015 

Sep 

2016 

Sep 

2017 

Sep 

2018 

Sep 

2019 

Sep 

2020 

Sep 

2021 

Sep 

2022 

% 

Change 

4 1 1 1 1 1 1 1 1 0% 

5 6 6 4 4 4 2 2 2 -67% 

6 2 2 2 2 2 -100% 

7 22 22 20 16 13 14 15 11 -50% 

8 8 9 9 9 8 6 6 8 0% 

9 18 17 19 18 20 27 16 16 -11% 

10 n/a 

11 35 33 30 28 27 30 35 29 -17% 

12 39 38 36 32 32 31 31 31 -21% 

13 62 67 74 70 65 62 60 58 -6% 

14 73 71 70 72 78 80 74 71 -3% 

15 34 34 34 34 35 36 32 33 -3% 

Total 300 300 299 286 285 289 272 260 -13% 

Mean Grade 12.06 12.06 12.15 12.24 12.33 12.36 12.37 12.43 + 0.38 

The number of GS permanent staff decreased for all grades from September 2015 to 

September 2022. As the chart shows, staff reductions have been more pronounced at the lower 

GS levels, with particularly significant reductions occurring in the GS-5 to GS-7 range (and to a 

lesser extent, GS-11 and GS-12). Staff levels at GS-13 to GS-15 have declined only slightly and 

at a slower rate that GS permanent staff reductions overall. An impact of this has been to 

increase the average level of GS permanent staff from 12.06 in September 2015 to 12.43 in 

September 2022. 

There are multiple factors that may be influencing the shift to higher GS level positions. The 

first is that supervisory positions have been retained. Of the 31-person reduction GS permanent 

staff levels, one of these was among supervisory staff and 30 were among non-supervisory staff. 

This aspect of the staff reductions from 2015 to 2022 favors retention of higher-GS positions and 

thus contributes to the increase in average GS level. An additional factor is that the average FEC 

employee has a greater length of service in 2022 than in 2015, which correlates with increased 

experience and expertise as well as the ability to perform higher-responsibility work. These both 

correspond with higher GS level positions. 

The FEC has filled approximately three positions for every four staff departures over the 

2015 to 2022 period. This has resulted in less “new blood” at the FEC. The average age of GS 

permanent staff has increased as has average length of service. For contrast, consider an agency 

with stable staff level – hiring new staff at the same level as staff departures. Maintaining stable 

schedule, experience a high turnover rate, in part due to commissioner appointments, and do not exhibit in-grade step 

accretion in the same manner that career FEC workforce do. 

43 
 

 

 

staffing can provide constancy in terms of both the average age and length of service of the 

workforce. Veteran staff leave the organization and are replaced by younger, less experienced 

staff; this cycle repeats and the overall profile of the workforce is steady over time. 

An organization such as the FEC, which has experienced a long-term reduction in headcount 

because it has lacked the resources to fully backfill/replace vacancies created by the departure of 

experienced staff, will skew over time to older, more experienced staff. There are not enough 

junior staff entering the organization to maintain a stable demographic profile over time (new 

hires at the FEC are 10.7 years younger than the average FEC average age). Over the period 

from FY 2015 to FY 2022, the FEC average age has increased by 2.9 years (compared to 1.3 

years for medium independent agencies) and the average length of service has increased 1.7 

years from 15.8 to 17.5 (compared to an increase of 0.5 years for medium independent agencies). 

Finally, the shift to higher average GS levels may be part of a fundamental shift in federal 

employment. Medium independent agencies experienced a 0.47 GS-level increase from 2015 to 

2022. 

Higher Costs Accompany the Shift to Higher Average GS Level Staff 

Employees at higher GS levels receive higher salaries than employees at lower GS levels. 

These higher salaries compensate for the increased experience and responsibility requirements of 

higher GS level positions. Consider the difference between pay rates for GS 12 and GS 13 

employees. A GS 13 employee is paid 18.9% more than a GS 12 employee in the GS pay table. 

This is true across all locality pay tables. 

The 0.38 GS-level increase in average grade level that the FEC experienced (going from 

12.06 in September 2015 to 12.43 in September 2022) is equivalent to 38% of the full-step cost 

increase from GS 12 to GS 13This 0.38 GS-level increase implies an increase in average GS 

permanent salary of 7.2% (38% of 18.9%). Note that there is some variation between specific 

GS level increases (12 to 13 may not be equivalent to 13 to 14, for example). Also, there is a 

specific salary cap consideration with respect to GS-15 staff that will be discussed in detail 

below. When factoring in the specific GS permanent staff level increases, as well as the 

mitigating effect of the GS-15 salary maximum, the cost impact of the 0.38 increase in average 

GS level is somewhat lower at 4.1% over the seven-year period of 2015 to 2022. 

The shift to higher cost employees through higher GS positions is not necessarily a 

negative.58 Ultimately, the FEC needs to determine the optimal mix of roles (and corresponding 

GS level grades for those positions) to carry out its mission most effectively. For example, this 

change may reflect a shift away from clerical or manual review processes to automated 

technology-leveraged processes and higher per-dollar returns on personnel costs. What this does 

highlight, however, is that the evolution in FEC workforce tasks, roles, and grades has an impact 

on the long-term personnel cost structure of the agency. This impact should be anticipated at 

least two years in advance to make effective use of the federal budget and appropriations process 

58 The comparison group of medium independent agencies in Washington, DC (100-999 employees) shows an average 

0.47-grade-level increase over the same period – meaning the FEC shift to higher grade-level positions is aligned with 

an the overall trend in federal employment. 

44 
 

 

 

 

 

 

 

 

 

(because of the two-year lag between the budget year being requested and the most recent actual 

year-end financials). 

Increasing Average Length of Service Results in Higher Step-In-Grade Pay 

The federal general schedule pay system divides each grade level into ten pay steps (1 to 10). 

These go from 1 (lowest) to 10 (highest) with each successive providing a higher salary than the 

preceding step by an amount equal to 3.3% of the step 1 rate. Employees move up through the 

steps according to a schedule (so long as they receive satisfactory performance reviews). Step 

increases occur after one, two, and three-year periods of employment until an employee reaches 

step 10 (which corresponds to 18 years of satisfactory performance in grade).59 

From September 2015 to September 2022, the average length of service of the FEC GS 

permanent staff increased 1.7 years (from 15.8 to 17.5 years). For the last seven years, the 

average FEC employee has had three more months of experience than the year prior. As 

employees increase their length of service, one of two things happens: they are promoted to a 

higher GS level position, or they move to higher paid steps within their current GS level pay 

band. 

As a side note, the average age of FEC staff is also increasing. The average age increased 

2.9 years from an average of 45.7 years of age in September 2015 to an average of 48.6 years by 

September 2022. 

Table 4: Average Length of Service (LOS) and Step for GS Permanent Staff, 2015 to 2022 

LOS and Grade Level 

Sep 2015 to Sep 2022 

Sep 

2015 

Sep 

2016 

Sep 

2017 

Sep 

2018 

Sep 

2019 

Sep 

2020 

Sep 

2021 

Sep 

2022 Change 

Average Length of Service 15.8 15.8 16.1 16.2 16.5 16.4 16.8 17.5 + 1.7 years 

Average Step GS-1 to GS-14 6.55 6.55 6.59 6.75 6.85 6.64 6.65 6.78 + 0.23 steps 

Average Step GS-15* 6.08 6.69 6.33 6.12 5.93 5.94 5.88 5.72 -0.36 steps 

* Step has been calculated on an effective cost basis; GS-15 salary caps have reduced cost exposure and effective step 

With increasing length of service, employees earn more through promotion to higher grade 

levels, within-grade increases, or both.60 The average 0.23-step step increase for GS permanent 

staff (up to GS 14) adds 0.65% to the average salary of GS permanent staff. This 0.65% increase 

is cumulative, and compounds the increases driven by the general schedule pay table, employee 

benefits costs, and cost increases due to higher GS grade levels. The cost impact of step 

59 For more information, see the GAO information on “Raises and Bonuses” at https://join.tts.gsa.gov/compensationand-benefits/. 

60 As an employee spends time in grade (for example, as a GS 12), they move up through step increases. At one-year 

intervals, employees move up from step 1 into steps 2, then 3, and then 4. At two-year intervals, employees move up 

into steps 5, 6, and 7. Three-year intervals occur to step 10, which reflects 18 years of service in grade. Each step 

increase provides incremental compensation (cost to agency) equal to 3.3% of the step-1 pay rate. Note that staff can 

receive meritorious step increases in recognition of exceptional work, reducing the total time to reach step 10. 

45 
 

 

 

 

increases is the smallest factor identified in this report but does translate to approximately two 

staff positions at FY 2022 staffing levels. 

The Cap on Maximum GS Schedule Salaries Materially Reduces the Rate of 

Growth for Personnel Costs at the FEC 

General schedule salaries are by statute not allowed to exceed the rate set for level IV 

Executive Schedule compensation. The Executive Schedule (EX) is used for political appointees 

and in 2022, the EX-IV rate of $176,300 established the salary cap affecting GS employees at the 

high end of the GS play table. For the Washington, DC locality pay table, salaries are capped 

beginning at step 7 for GS 15 staff. Steps 8 through 10 receive no additional increases and are 

also capped at the $176,300 maximum rate.61 The rate at growth for the Executive Schedule has 

not kept pace with GS pay table growth. Nor does it include a locality pay adjustment. This 

impacts general schedule staff in high-cost localities such as Washington, DC. 

The EX-IV salary cap for general schedule staff has had the effect of slowing the long-term 

rate of salary growth for staff who have reached the salary maximum. From 2015 to 2022, for 

example, the maximum capped salary for the Washington, DC GS pay table increased from 

$158,700 to $176,300. This represents a seven-year increase of just 11.1% from the 2015 salary 

level, 6.5% less than the overall increase of 17.6% for the general schedule over this same 

period. 

The GS salary cap further suppresses salary growth and agency costs by eliminating 

incremental raises that would arise for step increases. Once a staffer has reached the statutory 

maximum rate, they do continue to progress through the pay steps, but without incremental 

increases in salary. For the Washington, DC locality pay table, salary is capped for GS-15 staff 

at beginning at step 7 and does not increase with steps 8, 9, and 10. The salary rate for General 

Schedule staff at step 10 is 8.3% higher than at step 7 for all non-capped GS levels. 

Because GS-15 staff are salary capped and do not receive increases through successive steps, 

they forego this 8.3% salary increase potential. This factor alone slows salary growth by 

approximately 0.9% per year (dividing 8.3% by the 9 years it typically takes to progress from 

step 7 to step 10). 

An increasing number of FEC GS permanent staff are becoming subject to this GS salary 

cap. Because the political appointee/EX-IV salary growth has not kept pace with the GS 

schedule, additional steps are falling into the step range affected by the salary cap level. For 

example, in 2015, the GS schedule for Washington, DC was capped for GS 15 steps 9 and 10 

only. By 2022, the cap applied to steps 7 through 10. For 2024, the capped salary rate is nearly 

identical (just 0.3% higher) than the step 6 pay rate and in 2025 step 6 will likely fall within the 

salary cap.

62 

61 https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/22Tables/exec/html/EX.aspx. 

62 In the highest locality pay areas, the EX-IV salary cap for general schedule employees has begun to impact staff at 

GS level 14. San Francisco GS Pay Table. 

46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In FY 2015, only 8 of 34 (24%) of the FEC’s GS-15 staff were subject to the salary cap. By 

FY 2022, 19 of 33 GS-15 staff (57%) were subject to the cap. 63 The percentage of all FEC GS 

permanent staff who are salary capped is 6.9% as of September 2022. In dollar terms, this group 

represents 8.4% of total agency compensation for GS permanent staff. 

Comparison of Salary Growth for the Various Segments of FEC Staff 

The discussion has centered largely on GS permanent staff, which comprises approximately 

90% of the overall staff for the agency. The chart below shows the average per-staffer cost and 

cost growth for each of the four cohorts of FEC staff: GS permanent staff (including a split for 

GS 1-14 and GS 15 staff), commissioners, commission staff, and senior level staff. It is notable 

that every staff cohort (other than the commissioners) has experienced total cost increases, when 

benefits are included, greater than the 17.6% increase in the Washington, DC GS pay table. 

The FEC commissioners are an outlier; annual commissioner salaries have been flat from 

2015 to 2022.

64 The GS permanent segment of the FEC very closely approximates the growth in 

personnel costs for the agency as a whole: 30.8% compared to 30.3%. 

Table 5: Average Salary and Salary Growth by Staff Cohort at the FEC 

FEC Staff Segment 

Average Compensation 

per Employee by Cohort 

Salary 

% Increase 

2015 to 2022 

Total 

% Increase 

Sep 2015 Sep 2022 w/ Benefits 

Workforce (GS permanent) 99,920 124,079 24.2% 30.8% 

GS-1 to GS-14 93,913 117,225 24.8% 31.5% 

GS-15 only 147,621 171,849 16.4% 22.6% 

Commissioners65 158,500 158,500 -0.0% 5.1% 

Commission Staff 141,483 172,165 21.7% 28.1% 

Agency SL Staff 163,232 184,038 12.7% 18.7% 

FEC Total 104,346 129,168 23.8% 30.3% 

63 10 of 13, or 76%, of commission staff are salary capped. For all GS staff at the FEC (permanent and commission) 

29 of 46 (63%) are salary capped and subject to lower-than average salary increases both through reduced increases 

in the EX-IV salary table and the inability to rise in step level pay. 

64 This issue is discussed in greater length in the OIG’s Management and Performance Challenges Facing the FEC for 

FY 2024. Commissioners are political appointees paid under the Executive Schedule at grade EX-IV. From 2010 to 

2023, the total 13-year increase in EX-schedule salaries has been 2% or approximately 0.1% per year. This presents 

unique potential organizational, recruitment and retention, and morale challenges. 

65 The FEC did not initially implement the pay freeze provisions of the Consolidated Appropriations Acts, 2014 to 

2018. As a result, during that time, FEC Commissioners received salary increases in excess of the Executive level IV 

pay schedule. That administrative error was corrected in 2019. Financial reports at the time showed $158,700 as 

commissioner compensation. This chart reflects the correct salary level of $158,500. 

47 
 

 

 

 

 

Summary and Conclusion of Personnel Cost Analysis 

The FEC has experienced a reduction in its staffing level because appropriations and 

corresponding agency budgets have not kept pace with cost increases driven by the general 

schedule pay table. This has been made worse by the fact that increasing benefits costs, 

structural changes in FEC workforce, and increasing length of service and corresponding step 

levels have all contributed, in a compounded fashion, to push incurred personnel costs even 

higher. The imbalance of personnel cost increases compared to available funding is illustrated in 

the following graphic: 

Chart 9: Illustration of Components of Personnel Cost Increases and Comparison with Increases 

in Available Personnel Funding 

The average cost in salary and benefits per GS permanent employee increased by 30.8% 

from September 2015 to September 2022.66 Available personnel budget grew by only 14.7% 

66 Source for employee salary data: FedScope. Benefits cost data is taken from annual financial statements. By 

applying the overall overhead rate (benefits as percent of compensation), it is possible to approximate actual peremployee benefits costs. The approximation will be very close because GS permanent staff make up approximately 

90% of overall FEC staffing – but is not precise. 

48 
 

 

 

 

 

 

over the same period. The gap between increased per-employee salary and benefits and 

available funds has forced the FEC to reduce overall staffing levels accordingly. 

The average GS permanent salary increased 24.2% from $99,920 to $124,079 over this 

seven-year period. Benefits costs have outpaced the rate of growth of compensation, rising from 

$29,876 per GS permanent employee in FY 2015 to $45,736 in FY 2022 – a benefits-cost 

increase of 53%. The 24.2% total growth in salaries and 53% total growth in benefits produce a 

30.8% overallincrease in personnel costs (salary and benefits). 

The increase in average GS permanent salary of 24.2% is higher than the corresponding 

increase in the GS pay table of 17.6% from 2015 to 2022. The difference is a consequence of the 

evolving structure of FEC GS staff which has slowly shifted to higher average GS levels and 

higher steps within grade (a function of increasing length of service among FEC employees). 

The increase in average GS level is typical of medium independent agencies overall. The 

increase in step level is not. 

FEC appropriations increased 10.4% from FY 2015 to FY 2022 and have not provided 

sufficient resources to maintain the FEC’s historical staff level. The FEC did create an 

additional source of personnel funding over these seven years by allocating a higher percentage 

of overall funding to personnel costs (at the expense of the non-personnel budget). Personnel 

costs (salary and benefits) increased from 67.2% of the total FEC budget in FY 2015 to 69.8% in 

FY 2022. 

By repurposing non-personnel funds to cover personnel costs, the FEC has been able to 

increase the total personnel budget by 14.7% over the seven years. This is well short of the 

30.8% per-employee average cost increase. However, the repurposing of non-personnel funds 

has mitigated some of the reduction in the FEC staffing level from FY 2015 to FY 2022. 

Unfortunately, shifting budget funding from non-personnel to personnel is not a sustainable tool 

in the long run.67 

The gap between increasing personnel costs and increases in available budget through 

appropriations over the FY 2015 to FY 2022 period supports two key observations. First, 

appropriations increases must at minimum keep pace with increases in the GS pay schedule if the 

agency is to have the financial resources to sustain its staffing level. Second, and perhaps more 

important, cost drivers beyond GS pay schedule growth significantly increase per-employee 

costs and must also be reflected in appropriations increases. 

To illustrate the impact of personnel cost increases above GS pay scale increases, consider 

that for every $1.00 of salary increase from the FY 2015 GS pay table to the FY 2022 GS pay 

table, an additional $0.64 was incurred through increased benefits, GS level, and step costs. 

67 First, the ratio of personnel to non-personnel budget is 2.3:1 as of FY 2022, meaning it would take a 2.3% reduction 

in non-personnel costs to make up a 1% deficit in personnel – and this imbalance will increase as budget share is 

shifted. Second, successive cuts in non-personnel funding will require de-funding increasingly high-priority 

objectives, ultimately reaching mission critical or obligatory costs (IT infrastructure, rent and equipment, etc.) without 

which FEC mission delivery is not possible. 

49 
 

 

 

 

 

 

 

 

These three factors have increased persistently over the seven-year period, and it is reasonable to 

assume that future increases will continue in the absence of evidence or factors to the contrary.68 

Recommendation 1 – Evaluate Long-Term Budget and Staffing Plans: 

The FEC OIG recommends that the FEC evaluate whether its human capital 

planning adequately forecasts long-term costs, contemplates budget 

uncertainty, and addresses retention, succession planning, development, and 

acquisition of personnel, experience, and skills essential to successful delivery 

of FEC mission priorities. 

68 The FY 2024 budget provides a practical example of this. The Office of Management and Budget Budget of the 

U.S. Government Fiscal Year 2024 outlines an increase of 5.2% for civilian and military personnel for 2024 (page 

51). However, a 5.2% increase in FEC appropriations for FY 2024 over FY 2023 would likely be insufficient to 

maintain FEC staffing levels at the FY 2023 level. Historically, the actual per-employee cost increase has been 1.64x 

the increase in the GS pay table – or approximately 8.5%. Unless the FEC FY 2024 appropriation increase were large 

enough to absorb both the increase in the GS pay table and the additional cost drivers of benefits, GS level, and step, 

the FEC will lack adequate funding to maintain its FY 2023 staffing level. 

50 
 

 

 

 

 

 

 

 

 

 

 

 

How FEC HR Staffing Compares to Medium Independent Agencies 

As of December 2022, the FEC had four HR specialists.69 There are two occupation codes 

for standard HR specialists: 0201s (HR Management) and 0203s (HR Assistance).70 The FEC 

ended 2022 with 298 staff. This provides the following ratios for total staff to HR specialists: 

• 4 HR Management Staff (0201) – ratio 74.5-to-1 employees per HR staff 

• 0 HR Assistance Staff (0203) – ratio n/a 

• 4 Total HR Staff (0201/0203) – ratio 74.5-to-1 employees per HR staff 71 

For comparison, we looked at HR specialist staffing at medium independent agencies in 

OPMs FedScope database. These are agencies with between 100 and 999 employees. The 

average ratio of staff to HR Specialists (0201s and 0203s) is 35-to-1 (the median is 37-to-1). 

Collectively, medium independent agencies had 2.1 times more HR specialists per employee 

than the FEC. 

Table 6: HR Total and Per-Employee HR Staff Levels, FEC and Medium Independent Agencies 

Staffing Level of 

0200 Series Occupation Codes 

(December 2022) FEC 

Medium 

Independent 

Agencies 

(100-999)72 

0201 Human Resources Management 4 331 

0203 Human Resources Assistance 0 20 

Total HR Staff 4 351 

Total Staff 298 12,319 

Total Employees per HR 

Specialist 

0201 Human Resources Management 74.5 37.2 

0203 Human Resources Assistance n/a 616.0 

Total 74.5 35.173 

69 December 2022 was used because the number of HR specialists (4) is the typical of FEC HR Specialist staffing 

level in recent years. In September 2022 the FEC had only three HR specialists because of a separation that had not 

yet been filled. 

70 Data in the HR notes derive from FedScope, though FEC HR staffing levels were confirmed by FEC HR. 

71 Four occupation codes within the 02xx occupation series are not used here: 0241, 0244, 0260, and 0299 which 

relate to Mediation, Labor Management, Equal Employment, and Interns. Occupation codes 0241 and 0244 are 

externally focused, mission-delivery roles unique to the National Mediation and Conciliation Service and the National 

Labor Relations Authority, respectively. Occupation code 0260 relates to Equal Employment Opportunity, and 0299 

(Interns) is only very rarely used. 

72 Staffing levels are totals across all 32 medium independent agencies. 

73 The median level total staff to HR Staff is 37:1 for medium independent agencies. 

51 
Specific Agency Benchmarks for Number of HR Staff and Ratio of Total Staff to 

HR Staff 

To better contextualize the FEC’s staff-to-HR ratio, we looked at individual agency-level 

data in addition to aggregate medium independent agency statistics. The chart below presents 

several data points simultaneously: 

• Total agency staff (gold bars) 

• Agency HR specialist staff (0201 and 0203, blue bars) 

• Ratio of total staff to HR specialists (fuchsia line) 

• Median ratio of total staff to HR specialists (blue line: 37-to-1) 

Chart 10: FEC Per-Staff HR Staffing Level and Comparison with Medium Independent 

Agencies 

Chart shows FEC and other medium independent agencies by staffing level, 

corresponding 0201/0203 HR staffing, and the ratio of total staff to HR specialist staff. 

Source: FedScope. 

52 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Of all the medium independent agencies,74 only one (the Armed Forces Retirement Home) 

has a higher ratio of total staff to HR specialists. Of the remaining 28 agencies,75 only three (US 

International Trade Commission, Judicial Branch, and US Holocaust Memorial Museum) have 

staff-to-HR-specialist ratios of greater than 50. The remaining 25 agencies have at least 50% 

more HR staff per employee than the FEC with a median and mean providing more than double 

the number of HR specialists per staffer. This supports the following conclusion: 

The FEC is an outlier with the second-lowest number of HR staff compared to all 

agencies within the medium independent agency category. The FEC has less than 

half the number of HR staff (0201/0203) than either the median or average 

medium independent agency. 

There is one additional consideration that is material to this comparison. The FEC engages 

OPM’s HR Solutions, which is a consulting entity to provide varied HR services to client 

agencies within the federal government. On a cost basis, these services are roughly equivalent to 

two in-house HR specialists. Additionally, there is a staff member in the Office of Staff Director 

who performs part-time HR-related functions and represents the equivalent of approximately 

one-half of a dedicated HR specialist. When these additional resources are included, this brings 

the overall dedication of resources to the HR specialization closer to 6.5 full-time employees. 

This produces an adjusted ratio of total staff to HR specialists of 45.8-to-1. 

This ratio would place the FEC at 25th out of the 30 medium independent agencies for HR 

specialist coverage – still well below average on either a mean or median basis, but within 20% 

of typical per-staff medium independent agency HR specialist levels. The OIG did not examine 

whether other medium independent agencies also engage external service resources to bolster 

their in-house HR capacity. To the extent other agencies do, the statistics cited above underrepresent the level to which FEC HR resources are below typical levels. 

One positive mitigating factor is that FEC HR expressed confidence that the OPM HR 

Solutions service contract provides greater capacity, flexibility, and expertise than would be 

possible with equivalent resources devoted only to in-house FEC staffing. Although the OIG is 

not able to quantify these benefits independently, we agree in principal that OPM’s HR Solutions 

has the potential to leverage the FEC’s investment in overall human resources capacity. FEC HR 

did cite a reduction in time to hire since HR Solutions was engaged in 2018 as specific evidence 

74 Agencies presented include (in order): Pension Benefit Guaranty Corporation, Peace Corps, Federal Housing 

Finance Agency, Railroad Retirement Board, Corporation For National And Community Service, Commodity Futures 

Trading Commission, Consumer Product Safety Commission, International Development Finance Corporation, 

National Foundation On The Arts And The Humanities, National Transportation Safety Board, U.S. International 

Trade Commission, Export-Import Bank Of The United States, Millennium Challenge Corporation, Farm Credit 

Administration, Federal Election Commission, Armed Forces Retirement Home, Presidio Trust, International 

Boundary And Water Commission, U.S. Section, Federal Retirement Thrift Investment Board, Office Of 

Administration, Federal Mediation And Conciliation Service, Merit Systems Protection Board, Selective Service 

System, Judicial Branch, Office Of Special Counsel, Federal Maritime Commission, Federal Labor Relations 

Authority, Surface Transportation Board, U.S. Holocaust Memorial Museum, and Defense Nuclear Facilities Safety 

Board. The U.S. Trade Representative and OMB are not included because they have no 0201/0203 HR staff listed in 

FedScope. 

75 30 (not 32) agencies are used for agency-specific comments and rank-ordering. Two agencies, the US Trade 

Representative and OMB, are not included because FedScope shows no 0201/0203 staff. 

53 
 

 

 

that HR Solutions services have improved FEC HR performance. The OIG was able to confirm 

that the average time to hire was reduced by 37 days from FY 2018/2019 to FY 2022/2023 with 

efficiency gains in hiring phases under both HR Solutions and FEC HR responsibility. FEC HR 

also indicated that the ability to use an array of specialists at HR Solutions has allowed in-house 

HR staff to concentrate on FEC intra-agency business and process needs. 

Nevertheless, the fact remains that the FEC has a lower level of HR Specialist staff and 

overall resources committed to human resources than medium independent agencies overall. 

The OIG is not in a position to quantify specific process challenges or opportunity costs that may 

arise from the FEC’s level of human resources investment but does cite the potential for both as 

areas of concern. 

Recommendation 2 – Evaluate HR Resources 

The FEC OIG recommends that the FEC evaluate the sufficiency of HR 

staffing levels and of overall HR resources available to the agency. The FEC 

should, as appropriate, increase resources to levels commensurate with other 

medium independent agencies and to provide capacity for HR-related 

strategic initiatives. 

54 
 

The FEC will Experience a Personnel Budget Deficit if the FY 2023 Budget Levels 

Continue into FY 2024 

If the FEC does not receive an increase over FY 2023 appropriation levels for FY 2024, the 

FEC will need to reduce staff levels to historic lows (287 staff), reprogram substantial funds 

from non-personnel to personnel ($2.99 million), or implement a mix of both. 

Chart 13: FY 2024 Personnel Costs and Deficit Compared to FY 2023 Budget Level 

In FY 2024, the following three factors provide the conditions for this shortfall: 

• The FEC entered FY 2024 with a 30-month high staffing level of 309. 

• The FY 2024 per-employee personnel cost will be materially higher than FY 2023. 

• The FEC’s appropriation level for FY 2024 may be flat (or lower) than FY 2023. 

The FEC enters FY 2024 with 309 staff as of September 2023. This is a 5.5% increase from 

the FY 2022 ending staffing level of 293. On an FTE basis, the FEC increased from 

approximately 296.4 FTEs in FY 2022 to roughly 300 FTEs for FY 2023 – an increase of 1.2%. 

The FEC budget for employee salaries increased 4.9% from FY 2022 to FY 2023 from $37.8 

million to $39.7 million. This 4.9% increase in compensation costs correlates with the 1.2% 

increase in FTE levels after 2023 pay-table increases are factored in (the GS pay table increased 

4.86% though some FEC staff received lower increases - or no in the case of commissioners, no 

increases). 

The discrepancy between the 5.5% September-to-September staff level increase and 1.2% 

FTE level increase is due to the fact that in FY 2022, staff levels were declining whereas in FY 

2023, staff levels were increasing. In FY 2022 staff levels fell from 304 at the start of the year to 

55 
 

 

 

293 at the end, and these staff levels rose to 309 by the end of FY 2023. The fact that the FEC 

enters FY 2024 at a relative staffing high has an important budgetary impact for FY 2024: the 

FEC begins FY 2024 with a higher base level for compensation and benefits. 

The FY 2023 ending staffing level of 309 is 3.0% greater than the approximately 300-FTE 

level for FY 2023. A shorthand description of this difference is that the FEC had an “average”

staffing level of 300 during FY 2023 but ended the year with 309 staff. The actual FY 2023 

budget expenditures correlate with the 300-FTE average staffing level. But the FEC enters FY 

2024 a baseline level of personnel costs that is 3% higher than the FY 2023 level because it 

enters with 3% more staff than the FY 2023 average. 

The FEC did not spend as much on personnel in FY 2023 than it had initially budgeted. The 

budget for compensation and benefits for FY 2023 was initially set at $56.3 million. Actual 

year-end expenses were $54.25 million, just over $2.0 million less than initially budgeted. This 

allowed the FEC to repurpose these unused personnel funds to investments in non-personnel 

activities: notably IT infrastructure, development, and services. The $2.0 million gap between 

budgeted and actual compensation and benefits also provides a cushion for FY 2024. This 

money, if re-applied in FY 2024 to personnel, provides a source of funding to allow the FEC to 

enter FY 2024 at the 309-staff level and absorb the added costs of a staff that is 3% larger than 

the FY 2023 average. 

Nevertheless, FY 2024 will have a significantly higher cost structure for personnel than FY 

2023. FY 2024 Q1 (October to December) compensation costs will be higher because of the 

4.86% increase in the GS pay table for 2023 versus 2022. Additionally, the president’s budget 

calls for a 5.2% increase in salaries for 2024 over 2023, which will affect Q’s 2-4 (January to 

September).76 Increases in benefits costs, GS level increases, and average step will add to this 

increased cost structure. 

A projection of FY 2024 personnel costs requires two assumptions. First, what will the 

staffing plan be for FY 2024 (i.e., how many staff on board and when), and second, what will the 

compensation and benefits costs be? 

For the staffing plan, this projection tests two cases: 

A. Flat staffing (309 staff): The FEC maintains a flat 309 staff level through FY 2024. 

B. No-hire scenario: The FEC suspends hiring for FY 2024. As staff separate, those 

positions are left vacant. Historical rates of attrition would reduce the FY 2024 yearend headcount to 287. 

76 Including locality costs, the actual increase in the GS schedule for FY 2024 is 5.31%. 2024 GS Pay Table for 

Washington-Baltimore-Arlington. 

56 
 

57 

Our projections assume that the FY 2024 per-employee personnel cost structure 

(compensation and benefits) will by 6.2% higher in September 2024 than in September 2023. 

The components of this cost increase include: 

+ 0.09% through GS step increases

+ 0.57% through GS grade level increases

+ 0.74% through increased benefits overhead

+ 4.73% through increase in average salaries77

= 6.20% total increase for FY 2024 

This total increase in personnel costs applies to both the flat staffing and no-hire scenarios. 

The assumptions above assume a continuation of average historical changes in year-over-year 

costs (other than the FY 2024 compensation change, which is specific to the president’s FY 2024 

budget). The increase in average per-employee cost structure will occur even if the FEC were to 

suspend any staff structure changes (i.e. lock in the current average GS level of staff, to include 

not moving lower-GS staff into acting positions after a vacancy is created). In a static staffing 

structure environment, increases in average pay step alone will produce this increase. For 

explanation, 38% of FEC staff will be eligible for a step increase in FY 2024. The average step 

increase will increase compensation by 2.95%, for a net cost to the agency of 1.14% by year end 

(38% of 2.95%). Because these steps are distributed throughout the year, the FEC will incur half 

of this expense on average, or 0.57%.78 Table 11 below illustrates FEC step increases for FY 

2024 in a static-staffing environment: 

Table 11: Calculation of GS Step Increase Costs for FY 2024 

Employee Segment

% of FEC 

FTEs

% Eligible 

for Step 

Increase

% of 

Total FEC 

FTEs

Average Cost 

of Salary 

Increase

Agencywide 

Compensation 

Increase

GS scale, steps 1 to 3 16% 100.0% 16.0% 3.22% 0.52%

GS scale, steps 4 to 6 28% 50.0% 14.0% 2.94% 0.41%

GS scale, steps 7 to 10 24% 33.3% 8.0% 2.70% 0.22%

GS step 10, non-GS 32% 0.0% 0.0% 0.00% 0.00%

Total Increase at YE 100% 38.0% 1.14%

Incurred (avg, 6 month) 0.57%

Under these assumptions, the direct personnel cost in compensation and benefits projects out 

in the following way for the two scenarios within Table 12. See Appendix C for more detail. 

77 OMB’s Budget of the U.S. Government for Fiscal Year 2024 provides “an average pay increase of 5.2 percent for 

civilian and military personnel” (p.51). The 4.73% figure used here is a dollar-weighted average of the various 

segments of the FEC staff adjusted for historical salary increases relative to GS schedule increases. For example, 

Commissioners have not received salary increases since FY 2015, salary-capped GS-15 staff historically receive 

increases equivalent to 63% of the GS increase, and 84% of the staff are non-capped GS employees and will receive 

the full 5.2%. The President’s budget can be found at:

https://www.whitehouse.gov/wp-content/uploads/2023/03/budget_fy2024.pdf 

78 It is a coincidence that this 0.57% coincides with the prior reference to 0.57% for GS level increases in the list 

above. 
 

58 

Table 12: Total Projected Personnel Costs for FY 2024 – Flat Staffing and No-Hire Scenarios

FY2024

Scenario A 

Flat Staffing 

(309 Staff)

Scenario B 

No-Hire 

End at 287 Staff

Beginning Staff Level 309 309

Change in Staff Level 0 -22

Ending Staff Level 309 287

Compensation 43,170,807 41,572,093 

Benefits 16,116,535 15,517,690 

Total Compensation and Benefits 59,287,342 57,089,783 

Implications for the FEC if FY 2024 Budget Levels are Carried into FY 2024 

 

If the FY 2023 funding level is carried over into the FY 2024 budget year, the FEC will have 

to make various operational and budgetary decisions that could include: 

a) Setting aside the FTE growth plan included in the FY 2024 budget justification. 

b) Pausing non-personnel systems development and investments outlined in the FY 2024 

budget justification. 

c) Electing to maintain the staff level at 309 employees by redirecting $2.99 million in nonpersonnel funds (12.2% of the FY 2023 non-personnel budget) to personnel use. 

d) Adopting a no-hire and no-promotion strategy to minimize incurred personnel costs, 

which would still require repurposing $790k (or 3.2%) of the FY 2023 non-personnel 

budget to personnel use. At historical rates, natural attrition would reduce the staffing 

level to 287 employees by September 2024. 

e) Implement a combination of these approaches or augment the above with additional staff 

and budget management approaches. 

The following table illustrates the basis for the assumptions for the flat-309 staff scenario 

(item c above) and no-hire scenario (item d above):

Table 13: Impact of Budget Shortfall in Personnel on Non-Personnel Budget, FY 2024 

Budget Scenarios

Scenario A 

Flat Staffing 

(309 Staff)

Scenario B 

No-Hire 

End at 287 Staff

FY2024 Budget = FY2023 Budget (Total) 81,674,000 81,674,000 

 FY2023 Compensation and Benefits Budget 56,299,580 56,299,580 

 Projected FY2024 Comp and Bens 59,287,342 57,089,783 

 FY2024 Compensation and Benefits Deficit (2,987,762) (790,203)

 FY2023 Non-Personnel Budget 24,383,883 24,383,883 

 FY2024 Non-Personnel after Reduction 21,406,121 23,603,680 

 % Decrease in Non-Personnel -12.2% -3.2%
 

59 

The scenarios outlined in the table above represent a continuation of FY 2023 funding into 

FY 2024. It is possible that the FEC’s FY 2024 appropriation will be lower than the FY 2023 

level. For example, draft language for the House Appropriations Finance Subcommittee was 

published on June 20, 2023, that provided $74.5 million for the FEC for FY 2024.79 (Senate 

draft appropriation language has provided for a continuation of the FY 2023 appropriation level 

at $81.7 million.)80 Media accounts indicate that a significant portion of the majority party in 

the House of Representatives is seeking a reduction in discretionary spending for federal 

agencies as part of the final budget. This would be consistent with the framework of the Fiscal 

Responsibility Act of 202381 and could result in a reduced full-year appropriation level and 

corresponding budgetary resources.82 

To the extent that the FEC’s FY 2024 appropriation is less than $81.7 million, the challenges 

outlined above will be exacerbated. The FEC is currently working under a continuing resolution 

that provides budget authority through March 8, 2024 at FY 2023 levels. If a full-year budget is 

ultimately passed that appropriates less than the FEC’s FY 2023 appropriation, any shortfall 

would need to be made up within the remainder of the fiscal year, magnifying the impact of that 

reduction on that portion of the fiscal year. 

Congress has no constraints with respect to the final FY 2024 budget and need not account 

for the fact that the FEC has spent a meaningful portion of FY 2024 operating under a 

continuation of FY 2023 appropriation levels. Congress is free to pass a budget with higher or 

lower spending levels as it sees fit. For this reason, it is worth considering the implications of a 

FY 2024 appropriation at the level included in the House draft language ($74.5 million for FY 

2024). 

79 https://docs.house.gov/meetings/AP/AP23/20230622/116153/BILLS-118--AP--FServicesFY24FSGGSubcommitteeMark.pdf (page 92)

80 A The FEC is currently under a continuing resolution to provide funding at FY 2023 levels through March 8, 2024. 

81 https://www.congress.gov/bill/118th-congress/house-bill/3746/text 

82 The Fiscal Responsibility Act of 2023 does not articulate a specific funding level for the FEC for FY 2024. Section 

101 Discretionary Spending Limits states that “for the revised non-security category; approximately $703.6B in new 

budget authority” is to be inserted into 2 USC 901(c). This replaces the prior value of $626.5B for fiscal year 2021 

(citation below). Although this has no direct bearing on the FEC’s appropriation, the broader context is that this 

overall appropriation level limits FY 2024 non-security spending to 12.3% over the FY 2021 level. The FEC’s budget 

for FY 2023 was 14.2% above the FY 2021 level and could be reduced if it were brought in line with the overall 

spending framework. If the FEC’s appropriation for FY 2024 conformed to the overall 12.3% increase over FY 2021, 

this would correspond to a total budget of $80.3 million – approximately $1.4 million less than the actual FY 2023 

level. This comparison is not meant to be predictive, but simply for context on the broader landscape for non-security 

agency funding for FY 2024. https://www.law.cornell.edu/uscode/text/2/901 
 

60 

Table 14: Impact on Non-Personnel Costs with Appropriation of $74.5 Million for FY 2024 

House Finance Subcommittee Markup

Scenario A 

Flat Staffing 

(309 Staff)

Scenario B 

No-Hire 

End at 287 Staff

Total Budget, FY2024 74,500,000 74,500,000 

 Compensation and Benefits 59,287,342 57,089,783 

 Transportation and Benefits, Former Staff 240,537 240,537 

 Premium Pay and Cash Awards (zero) 0 0 

 Available for Non-Personnel 14,972,121 17,169,680 

 Reduction from FY2023 level (9,411,762) (7,214,203)

 % Reduction -38.6% -29.6%

An appropriation of $74.5 million would have a drastic impact on agency staffing and 

operations, and neither of the scenarios above may prove feasible. Rent and IT contracts alone 

comprise $17.5 million in the FY 2023 budget, which is greater than the total available funding 

for non-personnel costs in either scenario. In this case, staffing reductions would provide the 

only source of funds to meet these required or essential non-personnel costs. 

The following table illustrates a scenario where layoffs are used to generate sufficient 

budgetary space for essential non-personnel costs.83 For the purposes of this illustration, a 70/30 

split is assumed for personnel and non-personnel costs. A flat reduction in agency staff for the 

whole of FY 2024 at approximately 272 total staff (251 non-commission staff) would allow a 

budget of $74.5 million to meet personnel costs at FY 2024 levels and provide 30% ($22.35 

million) for non-personnel costs. 

Table 15: Balanced Budget and Staff Level Assuming 70/30 Ratio of Personnel to NonPersonnel; $74.5 Million Appropriation for FY 2024 

FY 2024 Layoff Scenario, 272 Total 

Staff

FEC Appropriation at FY 2021 Level 74,500,000 

Personnel at 70% 52,150,000 

 Compensation (21 Commission) 3,716,741 

 Compensation (251 non-Commission) 34,257,482 

 Total Compensation 37,974,223 

 Benefits at 37.33% 14,175,777 

Total FEC Personnel Budget 52,150,000 

Non-Personnel at 30% 22,350,000 

Total FEC Budget 74,500,000 

 Non-Commission Staff Level +/- 251

 Total Agency Staff Level +/- 272

83 The FEC in its Management Response noted that furloughs are an additional tool to create personnel cost savings. 
 

61 

This scenario illustrates a case where 37 FEC staff would need to be laid off to achieve a 

personnel (compensation and benefits) level of $52.15 million. The cost structure above 

assumes those layoffs occurred on October 1 and were in effect for the full fiscal year. If a $74.5 

million appropriation were passed in March (with October-February personnel costs having been 

carried at FY 2023 continuation levels), the impact and level of layoffs would be increased. 

At present, there is no definite appropriation level for FY 2024 and the projections provided 

are merely illustrative of the range of challenges FY 2024 may present. It is clear, however, that 

the reality of increased personnel costs in FY 2024 in combination with the FEC entering FY 

2024 at a recent high staffing level (309 employees) creates a significant budgetary and 

workforce management challenges. If the FEC’s FY 2024 appropriation level is not adequate to 

sustain ongoing staffing or program levels at increased FY 2024 costs, then either staffing levels, 

non-personnel program implementation, or both will need to be reduced. 

The FEC OIG recognizes that appropriation levels (and in some respects, budget justification 

request levels) are not within the FEC’s power and authority to set or determine. Also, situations 

and external factors can influence or determine what the agency asks for and prioritizes. It is 

also true that the FEC for years had not requested sufficient budgetary resources to maintain or 

grow staff and programs.84 These factors underscore the need to articulate and support the 

connection between current and future appropriations levels and the agency’s ability to deliver 

on its mission priorities. 

Recommendation 3 – Evaluate Future Budget Justifications 

The FEC OIG recommends that the FEC evaluate data provided to OMB 

and Congressional appropriators to ensure budget justifications adequately 

communicate the agency’s personnel budget requirements. 

84 Over the 5-year period from FY 2016 to FY 2021, for example, the FEC requested, on average, only a 0.6% increase 

year-over-year. This included three years in which the agency requested either flat or reduced budget levels. The 

FEC received increases averaging 0.2% per year. Over this same period, the CPI increased 13.6% and the GS pay 

table for Washington, DC increased 12.5%. Even if the FEC had received its full budget requests for these years, 

appropriation level increases would have made up less than 25% of the increase in costs measured by either CPI or 

GS pay table. Sources: FEC Congressional Budget Justifications, Bureau of Labor Statistics CPI Tables, and OPM 

General Schedule Pay Tables. 
 

62 

A Majority of FEC Staff will be Eligible to Retire by 2025 85 

Fifty-one FEC staff were eligible to immediately retire with full benefits as of June 30, 

2023.86 This is 17%, or one-sixth of the 305 total staff as of June 30. An additional 24 staff, or 

8% of the total staff, were eligible to immediately retire with reduced benefits.87 As such, nearly 

a quarter of the FEC staff could voluntarily retire and immediately begin receiving benefits. By 

the end of FY 2028 (September 30, 2028), 112 current FEC staff will be eligible for immediate 

full retirement with another 18 eligible for immediate reduced retirement. These numbers 

represent 37% and 6% of current FEC staff, for a total of 43%. 

Chart 14: FEC Retirement-Eligible Staff by Segment Through September 2028 

In addition to immediate retirement-eligible staff, a substantial segment of FEC employees 

are eligible for deferred retirement. In general, deferred retirement applies to any federal 

employee with five or more years of service who separates and elects to wait until they are 62 

85 By November 2025, 154 (50.5%) of the current FEC staff will be eligible to retire in the following categories: 

immediate (79), immediate reduced (29), deferred with 30+ years of service (9) and deferred with 20-29 years of 

service (37). This does not include deferred with 5-19 years of service, early retirement through reductions in force, 

or disability retirement. A decision to include deferred retirement with 20 or more years of service stems from the 

fact that these retirements are both financially substantial and come with beneficial retirement start ages compared to 

deferred retirement with 5-19 years of service. 

86 This section relies primarily on data provided by the FEC: specifically, a retirement eligibility roster provided by 

FEC HR. This is the sole analysis in this evaluation not based on public-source data and information. 

87 Staff are eligible for immediate full retirement if they are 62 years old with 5+ years of service, 60 years old with 

20+ years of service, or have reached Minimum Retirement Age (MRA) with 30+ years of service. Immediate reduced 

retirement is available to staff with 20-30 years who have reached the MRA but are not yet 60, or staff with 10-20 

years who are not yet 62. The minimum retirement age is currently 56 years, 6 months and will increase to 57 years 

as of December 31, 2027. 
 

63 

years of age to receive benefits. This eligibility is overly broad for this discussion (all current 

FEC staff will qualify by June 2028, for example). 

There are currently 12 FEC staff who have 30+ years of service but are not yet at minimum 

retirement age (MRA). This could be someone who, for example, began work at the FEC at age 

22, has worked 30 years, is now 52 years old, and could retire with deferred benefits to begin in 

five years when they reach the MRA of 57. Staff with 20-30 years of service can retire and 

receive deferred benefits when they reach the age of 60. These two groups, in addition to being 

candidates for deferred retirement, also represent the cohorts of FEC staff who are nearing 

eligibility for immediate full retirement. 

Table 17: Number of Current FEC Staff Eligible to Retire through September 2028 

Retirement Category 9/30/23 9/30/24 9/30/25 9/30/26 9/30/27 9/30/28

Immediate Full 52 63 77 90 102 112 

Immediate Reduced 24 26 27 30 22 18 

Deferred 30+ Years LOS 12 13 9 7 9 7 

Deferred 20-30 Years LOS 44 40 38 40 40 50 

Total Immediate 76 89 104 120 124 130

Total All Types 132 142 151 167 173 187

The totals for each category of retirement-eligible staff are presented in the table above. 

Three groups are not included: deferred retirement with less than 20 years of service (cannot 

receive benefits until age 62), disability retirement-eligible staff (18 months of service), and 

early retirement. These are not included because they fall less within the framework of 

identifying and managing staff who are well-positioned to elect to retire.

88 

It is useful to know that 43% of current FEC staff will be eligible for immediate retirement 

by the end of fiscal year 2028 compared with 25% today. This does not mean that in 43% of 

FEC staff will be retirement eligible in September 2028, however. This is because some of the 

current (or newly) retirement-eligible staff will elect to retire in the interim period, reducing the 

number still with the FEC and retirement-eligible as of September 2028. 

Over the period FY 2015 through FY 2022, 16.2% of staff who were eligible for immediate 

full retirement did elect to retire each year. This means the typical FEC staffer who is eligible 

for immediate full retirement continues to work for approximately six years before retiring, on 

average. Other retirement types (disability, deferred, immediate reduced) historically account for 

an additional 0.13 retirements per single immediate full retirement – approximately one 

additional retirement for every eight immediate full retirements. 

88 For the three excluded groups, these are comprised of staff who would receive (deferred retirement) smaller benefits 

farther in the future, (disability retirement) benefits related to personal circumstances they do not choose, and (early

retirement) staff who are eligible for benefits only if the FEC elects to modify its workforce structure or specific 

position parameters.
 

64 

When this historical rate of retirement is applied to the current and projected future 

retirement-eligible staff at the FEC, future retirement numbers and retirement-eligible staff can 

be estimated as follows: 

Table 18: Projected Number of Retirements and Retirement-Eligible Staff Based on Historical 

Rates of Retirement

Projected Retirements FY2023 FY2024 FY2025 FY2026 FY2027 FY2028

Immediate Full 7.6 8.1 8.6 9.1 9.8 9.9 

Other 1.0 1.1 1.1 1.2 1.3 1.3 

Total 8.6 9.1 9.7 10.3 11.0 11.2 

Full Time Eligible 49* 52 58 62 64 64

Total Eligible, All Types 129* 130 129 135 130 133

Projection assumes historical average: 16.2% of immediate full retirement-eligible staff retire

each year (1.26% per month) with and all other retirements at +13.0% of immediate full.

*These figures differ slightly from those above because they incorporate projected retirements. 

The FEC will go from 49 immediate full retirement-eligible staff at the end of FY 2023 to 64 

by the end of FY 2028, an increase of 30%. Retirements themselves will increase proportionally 

from just under nine per year to slightly more than 11 by FY 2028. Note that this table assumes 

a steady rate of retirement that is consistent with the historical average. If that rate should 

change (staff could elect to retire sooner once becoming eligible for immediate full retirement, 

for example), this will impact both the rate and number of actual retirements. 

In general, for every FEC staffer who elects to take immediate full-time retirement during a 

given year, there are another 5.2 who are eligible and could do the same but choose to remain 

working. This suggests both a risk and an opportunity: a risk in that a negative change in agency 

morale, work, or conditions could accelerate departures of the agency’s most experienced staff, 

and an opportunity in being able to engage retirement-eligible staff on topics are varied as 

current and future work goals, succession planning, or departure timing and transition. 

Diversity, Equity, Inclusion, and Accessibility Needs Further Evaluation 

The FEC has implemented expanded Diversity, Equity, Inclusion, and Accessibility (DEIA) 

initiatives in the post-Covid environment. These include an agency-wide DEIA council and 

several affinity groups and sub-committees to pursue initiatives as broad as highlighting diversity 

within FEC staff, establishing employee resource groups to expand the sense of community and 

support opportunities, highlighting external events and resources, and exploring improvements to 

agency processes as fundamental as performance planning, evaluation, recruitment, and 

retention. 

A qualitative assessment of the thoroughness and effectiveness of these initiatives is beyond 

the scope of this evaluation, which is focused on developing baseline statistics and metrics that 

describe the trends and current state of the FEC as a potential aid to future planning and 

management. 
 

65 

Toward this end, this evaluation has developed some metrics that provide perspective on the 

following two questions: 

• Is the workforce of the FEC demographically representative?

• Are opportunity and responsibility distributed equitably? 

Chart 15: Distribution of FEC Permanent Staff by Ethnicity/Race89

The staff at the FEC is generally reflective of the overall ethnic/racial distribution of the 

federal workforce in Washington, DC. Although there is no absolute reference for what the 

distribution of FEC staff should be, a comparison can be made to the medium independent 

agencies used throughout this report. For this analysis, medium independent agency staff have 

been narrowed to Washington, DC in order to ensure that the comparison group reflects the same 

labor market as the FEC. 

89 This chart presents DC-based permanent (career) staff – which in the case of the FEC includes GS permanent and 

SL staff. Commissioners and commission staff are not included because of variations in how they are appointed/hired 

and rates of turnover. FedScope diversity data as of September 2022 shows that approximately four in five of the 

FEC’s 19 non-permanent staff were white. 
 

66 

Chart 16: Comparison of Average General Schedule Levels Among GS Permanent Staff

There is an unequal distribution of responsibility among ethnic/racial categories at the FEC, 

as measured by average GS levels. The average GS level for GS permanent staff at the FEC is 

12.4. Black/African American staff are noticeably lower with an average GS level of 11.3. This 

means that the average Black/African American staffer has 1.1 GS levels less responsibility, 

authority, and compensation than an average FEC staffer. Asian and White GS permanent staff 

at the FEC have above-average GS levels at 13.4 and 13.0, respectively. 

It is notable, as the chart shows, that the GS level disparity with respect to Black/African 

American staff is also present in the GS permanent staff at medium independent agencies in 

Washington, DC. 
 

67 

Chart 17: Average Time in Grade (Time Between Promotions) by Ethnic/Racial Segment

The average FEC GS permanent staffer is paid at step 6.7.90 This implies that the average 

FEC staffer has spent 9.6 years in their current GS level using the standard schedule for step 

level increases.

91 Black/African American staff are paid at an average step level of 7.4, which 

corresponds with 11.8 years in grade – 2.2 years longer than the FEC average. FedScope data 

cannot provide a definitive explanation for this discrepancy, but this finding is consistent with a 

lower rate of promotion for Black/African American staff to higher GS level positions. 

The average step at which GS permanent staff are paid at medium independent agencies is 

5.6 which correlates with an implied 7.2 years in grade. A similar step-level discrepancy, though 

much smaller, exists for Black/African American staff at medium independent agencies. The 

90 For any given GS level, there are 10 steps (1 through 10) that determine the specific salary of a GS employee. Each 

step provides increased salary equal to 3.33% of the step 1 base salary. An employee paid at step 2 makes 1.0333x 

(3.33% more than) a step 1 employee. Using this relationship, the average salary for any segment of the FEC within 

a single GS level allows the determination of the average step for that segment within that GS level. The average step 

provides an implied length of service within grade through the application of the schedule for step increases. 

91 The schedule for within-grade increases is found here. Employees can also receive step increases as a reward for 

exceptional or meritorious service. The FEC OIG acknowledges this and the consequence that the step level does not 

absolutely correlate with length of service within grade. As a relative measure of promotion frequency, however, the 

OIG feels confident in this approach on the grounds that the approach is unbiased. Step increases outside the standard 

schedule would only skew results if they were applied unevenly between racial/ethnic staff groups, and the OIG does 

not assume this is the case. 
 

68 

average Black/African American GS permanent staffer at medium independent agencies is paid 

at step 5.9. This correlates with 7.8 years in grade, 0.6 years longer than the medium 

independent agency average. This suggests that the FEC is exhibiting a characteristic that is 

present within the larger federal employment market, though potentially to a greater degree. 

One final note is that the FEC average pay step for GS permanent staff is 6.7 – 1.1 steps 

higher than the medium independent agency average. This suggests that the typical FEC staffer 

may have spent 2.2 years longer in grade, and this could be reflective of a less robust framework 

for promotion opportunities within the FEC staffing structure. 

Chart 18: Percentage of GS Permanent Staff and Percentage of Supervisors by Ethnicity/Race

Supervisory responsibility at the FEC is not equally distributed in proportion to the overall 

ethnicity/race of GS permanent staff. A disparity exists for Black/African American supervisors. 

Black/African American staff comprise 35.0% of the total GS permanent workforce at the FEC 

but account for only 23.2% of the GS permanent supervisors. As of September 2022, 13 of the 

56 GS permanent supervisors at the FEC were Black/African American. If Black/African 

American staff accounted for 35% of supervisors, in proportion to their share of the FEC GS 

permanent workforce, this would translate to a total of 19.2 supervisors.92 

The under-representation of Black/African American employees within supervisory ranks is 

also present among the comparison group of medium independent agencies, though the degree of 

under-representation at medium independent agencies overall is somewhat less (approximately 

two-thirds as great). 

92 The percentage distribution of staff differs slightly to the percentages cited in chart 15 because this chart considers 

GS permanent staff only (excluding Senior Leader). The Senior Leader cohort at the FEC exhibits less diversity than 

the overall staff: 10 of 11 are white and 8 of 11 are male. 
 

69 

The lower average GS level (chart 16), greater time between promotions (chart 17), and 

lower proportion of supervisory responsibility (chart 18) may be inter-related. 

Chart 19: Representation of Women in the FEC’s GS Permanent Staff and Supervisory Roles 

Supervisory representation by women is an FEC success story. It is also atypical of medium 

independent agencies in Washington, DC. 

The FEC has bridged the gap between the proportion of women in the GS permanent 

workforce and the proportion of those with supervisory responsibility. In September 2015, 

women made up 55% of the FEC’s GS permanent staff but comprised only 46% of the 

supervisory GS permanent staff. A woman was proportionally 30% less likely to be a supervisor 

than a man at the FEC in September 2015. The proportion of women supervisors to women staff 

has steadily increased through FY 2022. As of September 2022, the number of GS permanent 

women supervisors exceeded (for the first time) the proportion of women GS permanent staff at 

the FEC. 

Among medium independent agencies, the proportional disparity of supervisory women 

among GS permanent staff in Washington, DC had been the same as the FEC’s at 30%. By 

September 2022 this disparity has improved but remains substantial at 21%. The FEC is atypical 

in having fully bridged the disparity in supervisory representation among women. 

Observation 1 – Future Evaluation of Diversity, Equity, Inclusion, and Accessibility 

The FEC OIG plans to further examine issues related to DEIA at the FEC. 

This is not a recommendation to the FEC but is noted here because of the 

importance of DEIA and equal employment opportunity to the overall health 

of the FEC workforce. 
 

70 

Summary and Review of Recommendations

This evaluation was conducted to generate specific metrics and statistics to support a better 

view of the historical decline in FEC staffing levels, the relationship of appropriations and other 

factors driving resource constraints, and potential risk factors for staff retention and 

organizational health. This evaluation specifically avoided a qualitative review of agency 

policies, procedures, or goals. The specific measures, statistics, and quantitative analyses are 

meant to support and bolster management processes and provide potential benchmarks and 

metrics to support further development of workforce planning and a strategic Human Capital 

Plan. 

Conclusions from this evaluation include the following: 

• FEC staff has persistently declined over 20+ years. 

o This decline has occurred among GS Permanent staff. 

o The decline is not attributable to attrition (which is low at the FEC) but to 

hiring. 

• Budgets have not kept pace with increasing costs through GS salary levels. 

o Additional costs beyond increases in the GS pay tables haver further 

contributed to the reduction in staff levels. 

o Budget justification cost projections for personnel have been lower than actual 

costs, leading to a shortfall in actual versus projected FTEs. 

o FY 2024 will be a challenging budgetary year, even with a full continuation of 

FY 2023 funding. The FY 2024 appropriation would need to increase beyond 

the level of FY 2023 to sustain staff and program levels. 

• Resources for HR at the FEC are proportionally lower than most medium independent 

agencies. 

• A significant portion of FEC staff is retirement eligible or will be within five years. 

• Further examination of DEIA is warranted. 

The FEC OIG makes the following three recommendations along with one observation: 

Recommendation 1 – Evaluate Long-Term Budget and Staffing Plans: The FEC 

OIG recommends that the FEC evaluate whether its human capital planning 

adequately forecasts long-term costs, contemplates budget uncertainty, and 

addresses retention, succession planning, development, and acquisition of 

personnel, experience, and skills essential to successful delivery of FEC mission 

priorities. 

Recommendation 2 – Evaluate HR Resources: The FEC OIG recommends that 

the FEC evaluate the sufficiency of HR staffing levels and of overall HR 

resources available to the agency. The FEC should, as appropriate, increase 

resources to levels commensurate with other medium independent agencies and to 

provide capacity for HR-related strategic initiatives. 
 

71 

Recommendation 3 – Evaluate Budget Justifications: The FEC OIG recommends 

that the FEC evaluate data provided to OMB and Congressional appropriators to 

ensure budget justifications adequately communicate the agency’s personnel 

budget requirements. 

Observation 1 – Further Evaluation of DEIA and EEO: The FEC OIG has initiated an 

audit of DEIA as well as EEO programs at the FEC. This audit is informed in part by data 

derived in this evaluation but is separately supported through various survey, employee 

satisfaction, and risk assessment processes.
 

72 

Appendix A: Medium Independent Agency Comparison Group

FedScope Federal Workforce Data93 divides agencies into four categories: cabinet level 

departments and large, medium, and small independent agencies. Medium independent agencies 

are those with 100 to 999 employees. The FEC ended September 2022 with 293 employees. As 

such, the medium independent agency category is comprised of agencies from approximately 

one-third to three times as large as the FEC, measured by employee count. The September 2022 

FedScope database categories 32 agencies as medium independent agencies. This list, along 

with their overall employee count as of September 2022, is as follows: 

• Pension Benefit Guaranty Corporation (963) 

• Peace Corps (951)

• Federal Housing Finance Agency (843) 

• Railroad Retirement Board (760) 

• Corporation For National and Community Service (715) 

• Commodity Futures Trading Commission (705) 

• Office of Management and Budget (695) 

• Consumer Product Safety Commission (558) 

• International Development Finance Corporation (472) 

• National Foundation on the Arts and the Humanities (457) 

• National Transportation Safety Board (412) 

• U.S. International Trade Commission (401) 

• Export-Import Bank of the United States (400) 

• Millennium Challenge Corporation (319) 

• Farm Credit Administration (316)

• Federal Election Commission (293) 

• Armed Forces Retirement Home (289)

• Presidio Trust (282) 

• International Boundary and Water Commission, U.S. Section (263) 

• Federal Retirement Thrift Investment Board (255) 

• Office of the U.S. Trade Representative (247)

• Office of Administration (216) 

• Merit Systems Protection Board (200) 

• Federal Mediation and Conciliation Service (200) 

• Selective Service System (166)

• Judicial Branch (165) 

• Office of Special Counsel (132) 

• Federal Labor Relations Authority (127) 

• U.S. Holocaust Memorial Museum (126) 

• Federal Maritime Commission (122)

• Surface Transportation Board (120) 

• Defense Nuclear Facilities Safety Board (114)

93 https://www.fedscope.opm.gov/
 

73 

This group of 32 agencies comprises the comparison group and is used to produce 

comparative statistics to provide context for FEC-specific statistics. It should be noted that this 

group includes the FEC, but because the FEC comprises only 2.4% of the overall employment 

for the medium independent agency category, its inclusion or exclusion does not meaningfully 

effect differences between FEC and comparison group statistics or resulting conclusions.94 This 

does mean, however, that comparison group statistics do not represent statistics in contrast with 

the FEC, but rather statistics for medium independent agencies overall of which the FEC is a 

part. 

This report avoids the use of the word “benchmark” when presenting, analyzing, and 

contrasting medium independent agency comparison statistics because this could imply that the 

comparative statistics represent a standard or desirable outcome. If, hypothetically, the average 

FEC employee was 54 years old and the average at medium independent agencies was 50, this 

would not mean that the FEC is better or worse, or that it should seek to conform to the overall 

average. It merely identifies a point of difference. This does, however, not render the statistic 

un-useful. In this example, one conclusion might be that the average FEC staffer is closer to 

minimum retirement age and that there could be a benefit in increased attention to succession 

planning. 

94 For the purposes of defining the set of agencies in that form the comparison group, the idea of excluding the FEC 

from that group was considered. After evaluating a number of statistics where the FEC was either similar or 

substantially different than the comparison group, the impact of the decision to include/exclude the FEC was found to 

be minimis. This is a consequence of the fact that FEC employment comprises 2.4% of the total employment among 

medium independent agencies. Consider the example of HR Specialist staffing levels, where the FEC exhibits a 

significant difference: the FEC reached a low of 3 HR Specialist staff in September 2022. With an overall staff size 

of 293, this resulted in a ratio of staff to HR Specialists of 97.7-to-1 for the FEC. The ratio for the medium independent 

agency group including was either 35.9-to-1 or 35.4-to-1 depending on whether the FEC was included/excluded. 

These two comparative statistics demonstrate equally well that the FEC ended Fiscal Year 2022 with a significantly 

smaller ratio of HR Specialists than the comparison group of medium independent agencies. This decision necessitates 

a subtle distinction that the “comparison group” represents medium independent agencies overall, of which the FEC 

is a small part.
74

Appendix B: Comparison of Various Segments of Medium 

Independent Agency Staffing to Identify Whether One Segment is 

Better Suited to be the Comparison Group 

This report has focused primarily on issues relating to the General Schedule, non-seasonal 

full-time permanent segment of FEC staff (GS permanent staff). Accordingly, comparisons to 

the group of 32 medium independent agencies have also been narrowed to the GS, non-seasonal 

full-time permanent segment of staff within the comparison group medium independent 

agencies. Informal agency feedback indicated a concern that for some purposes, including 

comparing changes in overall staffing, this subset of medium independent agency staffing may 

be inappropriate as comparative measure. 

This appendix provides additional detail on various comparative segments of medium 

independent agency staffing. The purpose of this is to identify whether there is a material 

difference between using DC-based GS permanent staff, DC-based total staff, national GS 

permanent staff, or national total staff as the comparison group for hiring, attrition, and overall 

staff levels. This analysis will show that while there are differences between the various groups, 

these differences are small when compared to the significant difference that exists between FEC 

staffing trends and medium independent agency staffing trends (regardless of group). 

From September 2015 to September 2022, the total combined staffing level for the 32 

medium independent agencies increased from 12,217 to 12,284 or 0.5%. The overall FEC 

staffing level fell 11.5% over the same period from 331 to 293 – a difference of 12.0% from the 

medium independent agency increase of 0.5%. 

When narrowed to GS non-seasonal full-time permanent staff, the total combined staffing 

level for the medium independent agencies increased by 0.2% from 6,273 to 6,283 from 

September 2015 to September 2022. The FEC experienced a reduction of 13.5% in the GS nonseasonal full-time permanent staffing over the same period – 13.7% less than the 0.2% increase 

for medium independent agencies. 

When further narrowed to Washington, DC-based employment, the total combined staffing 

level at medium independent agencies increased by 0.6%. 
 

75 

Staffing Level Changes for Segments of Medium Independent Agency Staff. 

Medium Independent Agencies

By Location

September 

2015

September 

2022 Change

Percent 

Change

 DC-Based Staff 7,938 7,867 (71) -0.9%

 Non-DC-Based Staff 4,279 4,417 138 3.2%

Total 12,217 12,284 67 0.5%

By Pay Plan and Work Status

 GS Non Seasonal Full Time

 Permanent (GS NSFTP) 6,577 6,546 (31) -0.5%

 All Other 5,640 5,738 98 1.7%

Total 12,217 12,284 67 0.5%

Location & Pay Plan/Work 

Status 

 DC-Based GS NSFTP 4,442 4,424 (18) -0.4%

 All Others 7,775 7,860 85 1.1%

Total 12,217 12,284 67 0.5%

Federal Election 

Commission

Federal Election Commission

September 

2015

September 

2022 Change

Percent 

Change

 GS NSFTP 304 263 (41) -13.5%

 Commissioners, Commission

 Staff, and SL 27 30 3 11.1%

Total 331 293 (38) -11.5%
 

76 

Appendix C: Additional Detail for Projection of FY 2024 Budget

The information in this appendix is meant to provide additional visibility into the process, 

mechanics, and assumptions that underly the projections of the FY 2024 budget and 

accompanying scenarios. The overall process is to develop a projection basis for anticipated 

costs and staffing levels for FY 2024, and then reconcile this against alternative funding levels to 

identify the presence and extent of funding gaps for the various cases. This appendix is neither

meant to be exhaustive nor definitive. 

Ultimately, by exposing the process and assumptions, the interested reader can better 

understand the relationship between potential funding and staffing scenarios and the final 

budgetary conclusions and determine what aspects of the analysis may add value to their own 

practical planning and management. Please inquire with specific questions on data, process, and 

methodology that are not fully addressed here. 

The overall framework for this evaluation’s approach to the FY 2024 budget and staffing 

level analysis followed these steps: 

• Use FY 2023 year-end financials to identify year-end personnel and benefit costs. 

• Prepare an estimate of the extent and timing of personnel cost changes for FY 2024. 

• Prepare a schedule showing likely staffing levels for natural attrition based on 

historical averages. 

• Use the revised cost and staffing levels to prepare monthly and annual personnel cost 

projections for the two scenarios: flat staffing at 309 employees, and the no-hire 

reduction staff levels through natural attrition without backfilling. 

FY 2023 Projection 

The FEC ended FY 2023 with 309 staff. The estimated FTE level (equivalent full-year 

employees) was 300. 

Appendix Illustration 1: FY 2023 Personnel Costs 

FY2023 Beg 

Staff

End 

Staff Hours

Avg Mo 

Hourly Compensation

Benefits 

% (Cum) Benefits

Total Comp 

and Bens

Actual

Oct-Dec 2022 293 298 520 61.28 9,417,006 36.0% 3,390,122 12,807,128 

Jan 2023 298 298 176 65.36 3,427,904 36.5% 1,251,930 4,679,834 

Feb 2023 298 298 160 65.16 3,106,638 36.9% 1,145,449 4,252,087 

Mar 2023 298 296 184 64.77 3,539,638 36.9% 1,305,869 4,845,507 

Apr 2023 296 302 160 65.05 3,112,130 36.7% 1,142,354 4,254,484 

May 2023 302 305 184 64.28 3,589,833 36.9% 1,325,198 4,915,031 

Projected Staff 

@ Jul/ Aug 

Jun 2023 305 305 176 63.45 3,406,210 36.4% 1,241,364 4,647,574 

Jul ‘23 est. staff 305 306.3 168 63.41 3,255,949 36.7% 1,194,281 4,450,230 

Aug ‘23 est. staff 306.3 307.7 184 63.01 3,559,147 39.7% 1,413,162 4,972,309 

Sep 2023 307.7 309 168 62.93 3,260,161 35.2% 1,148,624 4,408,785 

FY 2023 Total 293 309 2,080 63.43 39,674,616 36.69% 14,558,353 54,232,969 

FY23 Budget 41,302,200 14,987,280 56,289,480 

Under Budget 1,627,584 428,927 2,056,511 
77

Cost Drivers in FY 2024

The historical annual rate of benefits growth is 0.74% per dollar of compensation. 

Alternatively, you could think of this as benefits costing $0.74 more each year per $100.00 of 

base compensation paid. The benefit increase generally takes effect at the beginning of the 

calendar year. For the first quarter of FY 2024, the 36.8% benefits overhead rate for 2023 will 

be applied, and this is projected to increase to 37.5% beginning in January. 

GS level and step increases average 0.66% per year. These are applied by increasing the 

average hourly rate for FEC staff by 0.05% per month, consistent with the FY 2023 projection 

approach. As mentioned in the report body, this level of cost increase will occur even if the FEC 

implements a no-promotion policy. In this case, sheer step-level increases effect a corresponding 

increase in compensation costs. 

The largest cost driver for FY 2024 will be the 2024 increase in basic compensation. The 

President’s budget includes an average increase of 5.2% across the civilian workforce 

(referenced in report body). There are two caveats to this. Historically, the Washington, DC pay 

table has increased more than the national average. The pay table incorporates overall GS 

schedule increases and a specific locality adjustment. For the sake of this projection, there is no 

assumption of increased costs specific to the FEC’s locality table, but it bears noting that the 

implemented increase could be higher. 

The FEC includes four distinct segments of personnel: commissioners, commission staff, 

senior leadership, and GS permanent staff (which can in turn be broken into two segments – staff 

at the statutory salary cap and staff below this cap). This projection assumes that each segment 

will receive a salary increase beginning January 1, 2024, in proportion to their historical salary 

growth relative to GS schedule increases. For the 261 staff who are GS permanent and below 

GS-15 step 7, a 5.2% increase is applied. GS permanent staff at step 7 and higher – and 

commission staff who are predominantly paid at the salary cap as well – are projected to receive 

an increase of 3.28% (63% of 5.2%). Senior Leadership is projected to increase 3.75%. 

Commissioners receive no increase. When weighted by the total dollar value of each segment’s 

compensation, the resulting increase for 2024 over 2023 is 4.73%. 

Staffing Levels for FY 2024

This analysis uses two scenarios for staffing: a) retaining the flat staffing level of 309 

employees throughout FY 2024, and b) implementing a no-hire policy for non-commission staff 

and allowing the staffing level to fall through natural attrition. 

The annual separation rate for GS permanent staff has been 8.0% per year over the period FY 

2015 through FY 2022. This corresponds to a 0.67% per month separation rate for GS 

permanent staff. 
 

78 

Appendix Illustration 2: Staffing Levels in FY 2024 By Month for Flat and No-Hire Scenarios

Flat Staffing No-Hire With Natural Attrition

Constant Staff Beg Staff End Staff Avg Staff

Oct 2023 309 309.0 307.1 308.0 

Nov 2023 309 307.1 305.1 306.1 

Dec 2023 309 305.1 303.2 304.2 

Jan 2024 309 303.2 301.3 302.3 

Feb 2024 309 301.3 299.5 300.4 

Mar 2024 309 299.5 297.6 298.5 

Apr 2024 309 297.6 295.7 296.7 

May 2024 309 295.7 293.9 294.8 

Jun 2024 309 293.9 292.0 293.0 

Jul 2024 309 292.0 290.2 291.1 

Aug 2024 309 290.2 288.4 289.3 

Sep 2024 309 288.4 286.6 287.5 

FY2024 309 309 287 298 

In the no-hire scenario, the FEC staffing overall level declines to 287 by the end of FY 2024 

through natural attrition. This represents a decrease of 8.0% in GS permanent staff and 7.4% for 

the overall for total agency staff level. 

Projected Personnel Costs for FY 2024: Flat 309 Staff and No-Hire Scenarios

The first scenario we consider is the flat 309 staff scenario where headcount is held constant 

throughout the year results in a total compensation and benefits cost of $59.29 million. This is 

$2.99 million more than the FY 2023 budget total of $56.30 million for compensation and 

benefits. 

Appendix Illustration 3: Detail on Flat-309 Staff Personnel Costs for FY 2024 

FY24 309 Staff Beg 

Staff

End 

Staff Hours

Avg 

Hourly Compensation

Benefits 

% Benefits

Total Comp 

and Bens

Projected, 309 Staff, Held Constant

Oct 2023 309 309 176 64.44 3,504,625 36.8% 1,289,702 4,794,327 

Nov 2023 309 309 176 64.47 3,506,377 36.8% 1,290,347 4,796,724 

Dec 2023 309 309 168 64.51 3,348,670 36.8% 1,232,311 4,580,980 

Jan 2024 309 309 184 67.59 3,842,621 37.5% 1,440,983 5,283,605 

Feb 2024 309 309 168 67.62 3,510,235 37.5% 1,316,338 4,826,573 

Mar 2024 309 309 168 67.65 3,511,990 37.5% 1,316,996 4,828,986 

Apr 2024 309 309 176 67.69 3,681,067 37.5% 1,380,400 5,061,467 

May 2024 309 309 184 67.72 3,850,312 37.5% 1,443,867 5,294,180 

Jun 2024 309 309 160 67.75 3,349,772 37.5% 1,256,164 4,605,936 

Jul 2024 309 309 184 67.79 3,854,164 37.5% 1,445,311 5,299,475 

Aug 2024 309 309 176 67.82 3,688,435 37.5% 1,383,163 5,071,598 

Sep 2024 309 309 168 67.86 3,522,539 37.5% 1,320,952 4,843,491 

FY 2024 Total 309 309 2,088 66.91 43,170,807 37.33% 16,116,535 59,287,342 

FY2024=FY2023 41,334,999 14,964,581 56,299,580 

(Over) Budget (1,835,808) (1,151,954) (2,987,762)

It is important to draw a distinction between two potential understandings of “flat 309 staff” 

throughout the year. The intended use in this analysis is that the actual staff on board be 309 
 

79 

throughout the year. Another interpretation could be: “we have 309 positions and fill as 

vacancies are created”. The second understanding results in a situation where the “target” 

headcount is 309 but the average actual headcount is approximately 302 (consistent with an FTE 

count of 302). 

The basis for this distinction is that given the average 8% attrition rate, and the reality that 

government hiring is slow (taking approximately 120 days to fill a position with an external 

candidate), there will be, on average, 7 positions that are open and being recruited into. In order 

to maintain an actual staff level of 309, the agency would need to at all times be proactively 

recruiting/hiring toward a rough level of 316 total positions. Or put another way, the agency 

would have 309 staff on board and be hiring into 7 additional positions under the assumption by 

the time hiring actions have been completed, corresponding vacancies have been created. 

Allowing vacancies to accrue without hiring is functionally equivalent to accepting a 302-person 

staff level. 

In the no-hire scenario, the FEC begins FY 2024 with 309 staff and allows the staff level to 

be reduced through natural attrition without backfilling or hiring into vacancies. This scenario 

does assume that commission and commission staff are maintained, but that career staff is 

allowed to shrink with separations. 

Appendix Illustration 4: Detail on No-Hire Personnel Costs for FY 2024 

FY24 No Hire Beg 

Staff

End 

Staff Hours

Avg 

Hourly Compensation

Benefits 

% Benefits

Total Comp 

and Bens

Projected, No hiring other than 

commission, 8% separation rate

Oct 2023 309 307.1 176 64.44 3,493,639 36.8% 1,285,659 4,779,299 

Nov 2023 307.1 305.1 176 64.47 3,473,478 36.8% 1,278,240 4,751,718 

Dec 2023 305.1 303.2 168 64.51 3,296,468 36.8% 1,213,100 4,509,568 

Jan 2024 303.2 301.3 184 67.59 3,759,030 37.5% 1,409,636 5,168,667 

Feb 2024 301.3 299.4 168 67.62 3,412,380 37.5% 1,279,642 4,692,022 

Mar 2024 299.4 297.6 168 67.65 3,392,725 37.5% 1,272,272 4,664,997 

Apr 2024 297.6 295.7 176 67.69 3,533,821 37.5% 1,325,183 4,859,004 

May 2024 295.7 293.9 184 67.72 3,673,190 37.5% 1,377,446 5,050,636 

Jun 2024 293.9 292.0 160 67.75 3,175,708 37.5% 1,190,890 4,366,598 

Jul 2024 292.0 290.2 184 67.79 3,631,069 37.5% 1,361,651 4,992,720 

Aug 2024 290.2 288.4 176 67.82 3,453,240 37.5% 1,294,965 4,748,206 

Sep 2024 288.4 286.6 168 67.86 3,277,345 37.5% 1,229,004 4,506,349 

FY 2024 Total 309 287 2,088 66.81 41,572,093 37.33% 15,517,690 57,089,783 

FY2024=FY2023 41,334,999 14,964,581 56,299,580 

(Over) Budget (237,094) (553,109) (790,203)

Personnel costs (compensation and benefits) exceed the FY 2023 budget level by $790k in 

this scenario. It is worth noting that this scenario assumes a suspension of both hiring and 

internal promotion. To the extent that internal promotions or placing staff in acting positions 

results in higher compensation, this creates additional costs not contemplated in the table above. 

To the extent the organization would need to elevate staff to acting levels (at higher cost), this 

would increase the budget deficit outlined above. 

We present one final scenario. The FY 2024 budget justification had requested funds to 

achieve 340 FTEs. The scenario presented below looks at the required personnel cost 

(compensation and benefits) required to reach 340 FTEs by September 2024. We realize that the 
 

80 

FEC has been under a continuing resolution and will continue to be through March 8, 2024 

which does not allow the FEC to implement this staffing growth schedule. For this reason, this 

is illustrative only. 

One additional distinction must be made: the FY 2024 budget justification provides funding 

for 340 FTEs. Because an FTE is, for the sake of a shorthand description, the “average” staff 

level throughout the year, this staffing and budget schedule does not truly achieve 340 FTEs. 

Starting at 309 staff and growing to 340 is roughly consistent with an average staff level of 

324.5. But this scenario would have the virtue of placing the FEC, going into FY 2025, at a staff 

level of 340. 

Appendix Illustration 5: Detail Personnel Costs to Grow Staff Level to 340 

FY24 340 Staff Beg 

Staff

End 

Staff Hours

Avg 

Hourly Compensation

Benefits 

% Benefits

Total Comp 

and Bens

Projected, 8% separation rate, 

Increase Staff from 309 to 340

Oct 2023 309.0 311.6 176 64.33 3,513,390 36.8% 1,292,928 4,806,318 

Nov 2023 311.6 314.2 176 64.26 3,538,535 36.8% 1,302,181 4,840,716 

Dec 2023 314.2 316.8 168 64.19 3,401,681 36.8% 1,251,818 4,653,499 

Jan 2024 316.8 319.3 184 67.14 3,928,998 37.5% 1,473,374 5,402,373 

Feb 2024 319.3 321.9 168 67.06 3,612,439 37.5% 1,354,665 4,967,104 

Mar 2024 321.9 324.5 168 66.99 3,637,518 37.5% 1,364,069 5,001,588 

Apr 2024 324.5 327.1 176 66.92 3,836,993 37.5% 1,438,873 5,275,866 

May 2024 327.1 329.7 184 66.85 4,038,842 37.5% 1,514,566 5,553,408 

Jun 2024 329.7 332.3 160 66.77 3,535,885 37.5% 1,325,957 4,861,842 

Jul 2024 332.3 334.8 184 66.70 4,093,681 37.5% 1,535,130 5,628,811 

Aug 2024 334.8 337.4 176 66.63 3,941,904 37.5% 1,478,214 5,420,117 

Sep 2024 337.4 340.0 168 66.56 3,787,732 37.5% 1,420,400 5,208,132 

FY 2024 Total 309 340 2,088 66.22 44,867,599 37.34% 16,752,174 61,619,773 

FY 2024 = Budget Justification Amount 48,219,249 15,831,437 64,050,686 

Under (Over) Budget 3,351,650 (920,737) 2,430,913 

The FEC would require $61.6 million in compensation and benefits to grow the staff level to 

340. This is $2.4 million less than the budget justification amount of $64.05 million. One 

observation is that although the overall cost structure is below what was requested, the benefits 

cost is over budget. This is because the benefits cost (as a percentage of compensation) was 

32.8% in the budget justification. Benefits overhead has not been this low since FY 2019 and 

has been increasing year-over-year. Benefits cost was underestimated by approximately $2.2 

million in the FY 2024 budget request. 

A second observation is that the average hourly rate for FEC staff decreases month-to-month 

in this budget schedule. This is because by growing the staffing level, a disproportionate 

percentage of FEC staff are new. New employee costs are less expensive than the FEC average. 

New staff may come into positions at lower average GS levels. New staff also enter the pay 

schedule at pay step 1 which is less expensive that steps 5 and 6 which are more typical of FEC 

staff. A comparison of average per-employee compensation costs between FEC staff who are 

new (less than one year of service) and the FEC overall average shows that new staff cost, on 

average, approximately 80% as much as the FEC average. This creates the paradoxical result 

that total agency payroll costs trend up while per-employee costs trend downward. 
 

81 

Appendix D: Management Response to Draft Evaluation of 

Staffing, Hiring, and Retention at the FEC

The following attachment is the revised Management Response provided by FEC management in 

response to the draft version of this evaluation provided for their review. Other than updated 

pagination, the Management Response is presented in its entirety and without modification. 
 FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 

 

December 19, 2023 

February 5, 2024 

MEMORANDUM 

John Quinlan 

Chief Financial Officer 

Lauren Lien 

Director of Human Resources 

From: Dayna C. Brown 

Deputy Staff Director for Management & Administration 

To: Christopher Skinner 

Inspector General 

for LL

James Gerber 

Budget Officer JG

SUBJECT: Management Response to Report No. IE-23-01, Evaluation of Staffing, Hiring, 

and Retention at the FEC 

Following the December 19, 2023 submission of the initial Management Response, the Office 

of the Inspector General requested confirmation of Management’s concurrence status for each 

of the three recommendations stemming from the Evaluation. As such, Management is 

submitting this updated response on February 5, 2024, outlining the requested information. 

Management Response 

In January 2023, The Federal Election Commission’s Office of Inspector General (OIG) began 

“an evaluation of attrition, staffing and related issues at the FEC,” as a follow-up to the OIG’s 

Audit of Human Capital Management Program for Fiscal Year 20221

. The OIG’s primary 

method of evaluation was to compare publicly available data sets, specifically the FEC’s 

historical staffing data against composite data included in the Office of Personnel 

1 https://www.fec.gov/resources/cms-content/documents/FEC_HCM_Audit_Final_Report_4-25-23.pdf. 

82 (page 1 of 12 in Management Response)
 

 

Management’s (OPM) FedScope database under the category of “Medium Independent 

Agencies (100-999 employees).2 This Evaluation resulted in the following “main takeaways 

and observations”: 

• FEC staff has persistently declined over the last 20 years. 

• This decline has occurred among General Schedule (GS) permanent staff. 

• The decline is not [stet] attributable to hiring, not attrition (which has 

been low at the FEC). 

• FEC budget growth has not kept pace with increasing GS salary levels. 

• Additional costs beyond GS salary level increases have contributed to the 

reduction in agency staffing levels. 

• Actual per-staffer personnel costs have exceeded budget justification 

projections. 

• The FEC will experience a budget shortfall in personnel costs if the FY 

2023 appropriation level is carried over into FY 2024. 

• The FEC has fewer HR staff than comparable medium independent 

agencies. 

• A significant portion of FEC staff is retirement-eligible or will be within 

5 years. 

• Further examination of DEIA issues is warranted in light of potential 

disparities identified in this evaluation. 

Management shares many of the OIG’s concerns. The FEC’s funding levels have not kept up 

with the agency’s needs, and as a result, staffing levels have fallen over the past decade. 

Together, these factors have left the FEC challenged to meet its mission and complete its 

workload, which continues to grow as the level of campaign finance activity reported each 

election cycle continues to increase. During the past several fiscal years, the FEC was able to 

meet its statutory mission primarily due to efficiencies gained by reassigning staff using details, 

maximizing operational efficiencies through reorganizations, and improving technology and 

processes, among other efficiencies. However, in recent years the FEC has begun to exhaust 

the benefits that can be gained through such efficiencies and has, in some situations, reduced 

performance targets in response to these reductions in staffing amid increasing campaign 

finance activity. 

In recent years, the FEC has enumerated these challenges in Congressional Budget 

Justifications (CBJ) and other reports to Congress, making a strong case for increased funding 

above the levels recommended to federal agencies in annual budget guidance. As the OIG 

notes, for FY 2023 the FEC requested and received an appropriation representing a 9.6% 

increase over the funding level for FY 2022. At this increased funding level, the FEC set as a 

priority filling vacant positions and rebuilding staffing levels during FY 2023. As a result of 

this priority, the agency more than doubled its external hires as compared to FYs 2021 and 

2022, and FY 2023 ended with an approximately 5.5 percent increase over FY 2022 in the 

2 https://www.fedscope.opm.gov/datadefn/index.asp. 

83 (page 2 of 12 in Management Response)
 

 

 

 

number of employees onboard on September 30. Management agrees with the OIG that the 

FEC must continue to work to rebuild its staff, and the agency has requested a 14.5 percent 

increase in funding over FY 2023 levels for FY 2024. 

Management also appreciates the rigor of the data analysis presented by the OIG. In some 

cases, this analysis helps to confirm Management’s own assessments. For example, 

Management agrees the FEC will require continued funding increases across future fiscal years 

in order to keep up with rising personnel costs and increased campaign finance activity while 

rebuilding staffing levels to meet the agency’s workload. The OIG’s assessment of the effects 

of a proposed $74.5 million funding level for the remainder of FY 2024, representing a 9.6 

percent reduction from current funding, similarly confirms Management’s own assessment of 

the necessary staff-reducing measures the agency may be required to take under this scenario.3 

However, as discussed below, Management disagrees with the assertion in Recommendation 1 

that stagnant appropriation levels and the resulting staff reductions experienced by the FEC are 

a result of inadequate human capital planning and forecasting. Management also disagrees that 

root causes behind the FEC’s historical appropriation and staffing levels can be usefully 

identified through the methodology presented in this Evaluation. As discussed in further detail 

below, Management does not find observations from comparisons between the FEC’s topline 

staffing and funding levels and that of an aggregated data set composed of federal agencies that 

are between one-third and three-times the FEC’s staffing size sufficiently informative to 

override the mitigation strategies Management has identified through its own research. 

FedScope data is compiled by OPM, the federal agency charged with the mission of leading 

federal agencies in workforce policies, programs, and benefits.4 Grouping federal agencies 

according to the size of their workforces is consistent with OPM’s focus on workforce 

management. However, the agencies included in FedScope’s cohort of “medium independent 

agencies” must also meet their various mission objectives. As a result, while they may be 

somewhat comparable in staffing size, they may face different challenges to their missions over 

time, have vastly different budget compositions, receive several appropriations or multi-year 

funds or maintain significantly larger or smaller property portfolios. Congressional 

appropriations for these agencies reflect the agencies’ missions, which are not necessarily 

reflective of the size of their staff.5 In short, appropriation levels for a particular agency will 

3 Management notes that under this funding scenario the agency could take measures other than a reduction in 

force, such as furloughs, to reduce the number of staff workdays, and that cuts would be made to non-personnel 

spending as well. 

4 https://www.opm.gov/about-us/strategic-plan/mission-vision-values/ 5 For example, the FEC, which is categorized by FedScope as a medium independent agency, is funded by a single 

annual appropriation for salaries and expenses. Historically, approximately 70 percent of the agency’s budget is 

composed of expenses related to personnel, such as salaries and benefits costs. Of the agency’s remaining 

operational expenses, the largest categories are IT operations, including IT security requirements, and facilities 

rent. The FEC maintains a single headquarters located in Washington, DC. For FY 2022, the FEC received an 

appropriation of $74 million and ended the year with 293 employees on board. Another agency identified by 

FedScope as a medium independent agency, the Commodity Futures Trading Commission (CFTC), received a 

$318 million appropriation for salaries and expenses in FY 2022 (approximately 4.25 times that of the FEC) and 

84 (page 3 of 12 in Management Response)
 

 

reflect activity beyond personnel expenses, and agencies that are categorized together for 

purposes of staffing assessments should not necessarily be categorized together for the purposes 

of appropriation comparisons. As a result, while generally informative, Management does not 

find the comparisons gleaned from this high-level evaluation of data sets to provide uniformly 

actionable and specific takeaways. 

Recommendation 1 

Evaluate Long-Term Budget and Staffing Plans: The FEC OIG recommends that the 

FEC evaluate whether its human capital planning adequately forecasts long-term costs, 

contemplates budget uncertainty, and addresses retention, succession planning, 

development, and acquisition of personnel, experience, and skills essential to successful 

delivery of FEC mission priorities. 

Management shares the OIG’s commitment to ensuring the FEC's human capital management 

planning and budget development programs support the agency's success in meeting its mission 

and strategic objectives. Toward this end, Management has previously considered and 

evaluated the primary concerns raised by the OIG in this report through the agency’s regular 

planning and assessment processes. Based on these evaluations Management does not agree 

with the assertion in Recommendation 1 that improved human capital planning would result in 

Congress providing larger appropriations for the agency. 

The OIG’s Evaluation covers budget and staffing data and risks to the agency through the end 

of FY 2022 and identifies risks related to flat funding for the agency, reduced staffing levels 

and rising workloads resulting from significant increases in federal campaign finance disclosure 

activity. During FY 2022, Management also undertook an assessment of the agency’s 

enterprise-level risks. The FEC’s FY 2022 Enterprise Risk Management (ERM) assessment6 

identified the following risks regarding budget and staffing issues: 

• “Budget Constraints That Limit Hiring and IT Modernization Initiatives” was identified 

as a Very High inherent risk that is outside of Management’s control; 

• “Significant Increase in Federal Election Campaign Disclosure Activity” was identified 

as a Very High inherent risk that is outside of Management’s control; 

• “Multiple Acting Positions, Including Key Positions” was identified as a High inherent 

risk to be monitored; 

• “Attrition and High Volume of Retirement Eligible Employees” was identified as a 

High inherent risk to be mitigated through succession planning and employee 

engagement efforts; 

ended the fiscal year with 705 employees onboard (approximately 2.5 times that of the FEC). The CFTC maintains 

a facilities portfolio that includes four locations: Washington, DC, Kansas City, Chicago, and New York. They 

also sublease a COOP facility. 

(https://www.cftc.gov/sites/default/files/CFTC_FY_2024_President_Budget_Report.pdf). 6 https://www.fec.gov/resources/cmscontent/documents/FEC_FY_2022_Agency_Financial_Report_Final_11_15_22.pdf. 

85 (page 4 of 12 in Management Response)
 

 

 

 

• “Major Functions Performed by One Individual” was identified as a Medium inherent 

risk to be mitigated through cross training and process documentation. 

For each of these risks, Management has identified mitigation strategies and continues to 

pursue these mitigation strategies and other proposed actions at an enterprise-wide level, rather 

than focusing on one or two agency functions, such as budget development or human capital 

management. The risk assessment and proposed mitigation measures identified in the ERM are, 

in Management’s view, more accurate assessments and more meaningful measures than those 

proposed in the OIG’s recommendations. Management does not agree that the OIG’s high-level 

comparison of the FEC’s budget and staffing data to corresponding aggregate data included in 

the FedScope dataset of medium independent agencies provides “actionable indications of 

future steps” the FEC should take instead of, or in addition to, recent steps already taken by 

Management. Management looks forward to discussing these issues further with the OIG but 

notes that enterprise risk management is ultimately a management responsibility.7 

In addition to identifying these enterprise-level risks and their attendant mitigation strategies 

during FY 2022, Management undertook research to support development of the FEC’s FY 

2023 Congressional Budget Justification (CBJ), published in March 2022. In the FEC’s FY 

2023 CBJ, the agency requested—and ultimately received—a 9.6 percent increase in funding 

over FY 2022 levels. For FY 2024, the FEC requested $93.5 million in funds to support its 

operations during the 2024 presidential election year, representing a 14.5 percent increase over 

the agency’s enacted appropriation for FY 2023. In the FEC’s FY 2024 CBJ, Management has 

included in Section 3D: 1, Major Management Priorities, Challenges and Risks, a detailed 

analysis of challenges faced by the agency due to increasing workload coupled with decreasing 

staffing levels. The analysis published in the FEC’s FY 2024 CBJ, and the underlying data and 

research that supports it, “forecasts long-term costs” and “contemplates budget uncertainty,” as 

requested by the OIG in Recommendation 1. While Management understands that the process 

of forecasting and planning for budget and staffing can never be perfect or complete, 

Management does not agree that the information provided in the OIG’s Evaluation of Staffing, 

Hiring and Retention at the FEC provides more useful data for assessment than that already 

7 OMB Circular A-123, II D, Role of Auditors in Enterprise Risk Management, establishes Management’s and 

auditors’ respective roles in enterprise risk management: “Management is responsible for Enterprise Risk 

Management systems. Internal or external auditors conduct independent and objective audits, evaluations, and 

investigations of an Agency’s programs and operations, which includes aspects of the internal control and risk 

management systems. Management uses the results of such evaluations, including accompanying findings and 

recommendations, to monitor the design or operating effectiveness of these systems at a specific time or of a 

specific function or process. Auditors are also responsible for keeping management informed about risks that it 

detects, including fraud risks, and thereby provides information to management for use in the identification and 

assessment of risks. Management and external auditors might have different interpretations of risks based on their 

respective roles and responsibilities. The agency risk function should seek to coordinate their roles so that the 

independence and scope of the external auditor’s role is preserved while ensuring the continuing flow of risk 

information to the risk management function.” 

86 (page 5 of 12 in Management Response)
 

 

 

 

utilized by management.8 As a result, Management does not agree that the activities described 

in Recommendation 1 support the goal shared by FEC Management and FEC OIG: increasing 

agency funding and staffing levels. 

Managements’ assertion that its FEC-focused evaluation of the challenges facing the agency 

yields more actionable data than that offered in the OIG’s Evaluation is supported by the 

information provided in the OIG’s Evaluation. The OIG arrives at Recommendation 1 after a 

series of comparisons between the FEC’s publicly available staffing and funding data and 

similar data available for the group of 32 federal agencies included in the category of “medium 

independent agencies” by OPM in the FedScope database. The agencies included in 

FedScope’s group of “medium independent agencies” are agencies with between 100 and 999 

employees. While Management appreciates this opportunity to consider the FEC in the context 

of larger government-wide staffing trends, Management believes that steps to mitigate staffing, 

budget and workload trends at the FEC are most usefully developed based on the specific 

circumstances of the FEC. 

For example, in its Evaluation the OIG has chosen to focus on FEC staffing levels in the 

“permanent GS category,” in large part because this category represents the largest cohort of 

employees at the FEC, but also because “GS permanent staff are widely used at other 

independent agencies, allowing FEC staffing profiles and trends to be compared broadly 

against other agencies” and “Commissioners are Presidentially Appointed and Senateconfirmed (PAS) positions provided by statute and thus fall outside of agency management.” 

Having made the choice to focus on the most comparable datasets, and to exclude consideration 

of factors outside of Management’s control, the Evaluation does not give further consideration 

to commissioners and commissioners’ staff, which comprise more than 7 percent of the 

agency’s workforce. 

In contrast, Management’s more FEC-focused assessment of staffing risks takes into account 

all employee cohorts. Taking all types of employees into account surfaces the specific staffing 

risks to the FEC that result from the loss of a quorum of commissioners. As illustrated in the 

OIG’s Chart 3: FEC Headcount by Staffing Segment, FY 2015-2022, shown below, the FEC 

did not have a full complement of Commissioners between FY 2017 and FY 2021. 

Significantly, as noted in the OIG’s Evaluation, footnote 6, the FEC lacked a quorum of four 

commissioners for nearly all of FY 2020. 

8 Additional human capital management activities identified in Recommendation 1, such as “retention, succession 

planning, development, and acquisition of personnel, experience, and skills essential to successful delivery of FEC 

mission priorities” were discussed and addressed in greater detail as part of the OIG’s Audit Report of the Federal 

Election Commission’s Human Capital Management Program for Fiscal Year 2022. Management refers the OIG to 

that discussion. 

87 (page 6 of 12 in Management Response)
 

 

Without a quorum of at least four commissioners, the FEC cannot take any official actions 

except those enumerated in FEC Directive 10, Rules of Procedure of the Federal Election 

Commission Pursuant to 2 U.S.C. 437c(e), Section L. Specifically, under Directive 10 when the 

Commission is without a quorum it can only make acting or temporary appointments of staff at 

the GS 15 level or above and cannot appoint a permanent Staff Director, General Counsel or 

Chief Financial Officer.9 

In FYs 2020 and 2021, the FEC listed in its ERM “Absence of a Quorum/Confirmation of 

Commissioners” as a Very High or High risk that was outside of the agency’s control.10 

According to Management’s internal assessments, the lack of a commissioner quorum during 

part of 2019 and most of 2020, and the lack of a full complement of commissioners during FYs 

2017 and 2018, negatively impacted the agency’s staffing and budget planning in two ways. 

First, no permanent selections could be made at the GS 15 level or above, which left senior 

staff in acting positions and had a cascading effect on the agency’s ability to hire for permanent 

positions across GS levels. Second, the lack of a full complement of commissioners and 

commissioners’ staff during FY 2017 through FY 2020 reduced the year-over-year baseline for 

the FEC’s personnel costs, which is the starting point for future budget planning and 

forecasting activities under Office of Management and Budget guidance. Because the 

appointment and confirmation of commissioners and the timing of such appointments and 

confirmations are outside of Management’s control, Management necessarily included funds 

9 https://www.fec.gov/resources/cms-content/documents/directive_10.pdf. 10 https://www.fec.gov/resources/cms-content/documents/FY_2020_Agency_Financial_Report.pdf and 

https://www.fec.gov/resources/cms-content/documents/FY_2021_Agency_Financial_Report.pdf, 

88 (page 7 of 12 in Management Response)
 

 

 

 

 

 

for six commissioners and sixteen commissioner staff members when projecting future budget 

levels. In years where no commissioner confirmations occurred, the FEC filled staff positions 

with funds otherwise set aside for these leadership positions. When the FEC gained a full 

complement of commissioners and their staff, these personnel funds were no longer available 

for use by other offices and divisions. Although commissioners and their staffs represented a 

relatively small number of positions overall, the vacant seats were significant because of the 

relatively small number of employees at the FEC and the fact that these positions are at higher 

pay levels. Thus, in Management’s assessment of FEC staffing trends, an up-to 50 percent 

reduction in employees within the Commissioners cohort between 2016 and 2021, though only 

representing three employees, had an outsized effect on the agency’s staffing plans that is not 

captured in the OIG’s Evaluation and not easily resolved by a recommendation that focuses on 

retention and succession planning in the GS permanent cohort. 

In another instance, the OIG compares the FEC’s appropriations history over the past several 

years to that of the 32 agencies identified by OPM as “medium independent agencies” and 

notes that the FEC’s relatively flat funding levels over this period are not reflective of an 

overall trend across agencies. Management agrees that without sustained increases in funding 

levels, the agency will be significantly challenged to meet workload and mission requirements. 

However, as discussed above, Management questions whether the group of 32 agencies 

included in a dataset based on staff size remains a useful point of comparison when agencies are 

compared according to appropriation history. 

Moreover, when the OIG considers the FEC’s appropriation history it does not appear to 

similarly consider the timing of agency appropriations and the effects of continuing resolutions 

on the FEC’s ability to hire. The OIG began its Evaluation in January 2023, at the start of the 

second quarter of FY 2023. This was also when federal agencies received their FY 2023 

appropriations after spending the first quarter of the fiscal year under a series of continuing 

resolutions, some of which lasted only a week. With a single appropriation for personnel and 

non-personnel expenses, and approximately 70 percent of its annual budget dedicated to 

personnel costs each year, the FEC is particularly sensitive to the availability of funding when it 

chooses to hire. Although the agency was able to move quickly to hire once 2023 funds were 

released at the end of December, a quarter of the fiscal year had already elapsed. As the OIG 

notes in its Evaluation, Congress has since publicized a possible FY 2024 budget for the FEC 

that would represent a 9.6 percent cut from FY 2023 levels. Currently the FEC is again funded 

by continuing resolutions through the first quarter of the fiscal year, and in keeping with 

prudent management practices has slowed hiring while it awaits funding for FY 2024. Lengthy 

continuing resolutions that slow the pace of hiring during the fiscal year are among 

Management’s considerations when determining actual hiring number numbers during the year, 

as opposed to projected hires. Thus, in cases such as this, neither the agency’s hiring pace nor 

the upcoming level of funding for the agency requested in CBJs are a cause of the slow pace of 

hiring. 

89 (page 8 of 12 in Management Response)
 

 

 

The disparity between the types of concerns resulting from OIG’s high-level assessment of 

staffing, hiring and retention at the FEC and those resulting from Management’s assessment is 

most notable where the OIG posits potential causes for the FEC’s reduced staffing levels. For 

example, the OIG raises a concern that over time the FEC workforce has become more 

expensive to the agency, even beyond amounts attributable to increases in salaries and benefits 

costs, because more employees are at higher grade levels and more employees are at higher step 

levels within their grades. The OIG notes that, “this change may reflect a shift away from 

clerical or manual review processes to automated technology-leveraged processes and higher 

per-dollar returns on personnel costs.” Nevertheless, the OIG maintains that the shift toward 

higher-grade-level and higher step-level employees has raised the agency’s per-employee costs 

in a manner that negatively impacts overall staffing levels. 

Management agrees with the OIG that the agency’s staff has shifted toward higher grade-levels 

and step-levels within grade. However, Management points out that a reduction in positions at 

lower GS levels has been a response to, not a cause of, lower staffing levels. In recent years, 

given the percentage of obligations tied to personnel expenses, the FEC has critically 

considered every hire. Currently staffing planning is happening on a micro-level by the 

agency’s divisions, where workload, tools, mission and funding are taken into account with 

every request to hire. These requests are then prioritized at a macro-level by agency leadership 

and the Personnel Committee, budget permitting. Efficiencies employed by Management to 

maintain agency performance at lower staffing levels specifically include long-term plans to 

detail employees to high priority roles, implementing technological and automation efficiencies 

and pooling support services. Pooling support resources and cross training employees to 

perform major functions are also mitigation strategies identified in the FEC’s ERM to lower the 

risks stemming from a high volume of retirement eligible employees and major functions being 

performed by a single individual. Although these mitigations strategies have resulted in the 

FEC hiring and retaining staff at higher salary levels, they have also ensured that the agency 

continues to meet its mission with reduced staffing levels. 

Thus, while Management appreciates the context provided in this Evaluation and will continue 

to investigate the FEC’s staffing and funding posture in relation to that of other agencies of a 

broadly similar staffing size, Management does not agree that information provided in the 

Evaluation supports the remediations described in Recommendation 1. As such, Management 

does not concur with Recommendation 1. FEC’s practical approach to human capital planning 

and budget planning forecasts long-term costs within OMB instructions, contemplates and 

attempts to mitigate budget uncertainty, and addresses the stated HR management strategies 

with the goal of building a workforce that can successfully deliver FEC mission priorities. As 

outlined above, the robust and context-specific strategies and considerations used by the 

Agency to conduct this iterative work takes place on an ongoing basis. 

90 (page 9 of 12 in Management Response)
 

Recommendation 2 

The FEC OIG recommends that the FEC evaluate the sufficiency of HR staffing levels 

and of overall HR resources available to the agency. The FEC should, as appropriate, 

increase resources to levels commensurate with other medium independent agencies and 

to provide capacity for HR-related strategic initiatives. 

The FEC generally agrees with Recommendation 2 and has already undertaken the activities 

described in the recommendation. As described in responses to the OIG’s Audit of Human 

Capital Management Program for Fiscal Year 2022, the FEC performs evaluations of staffing 

for all divisions on a continuous basis. The evaluation period of the Special Review of Staffing, 

Hiring, and Retention was FY 2022, and since that time, the Office of Human Resources (OHR) 

and Office of the Staff Director (OSD) management reviewed and evaluated OHR staffing 

levels to determine the ongoing sufficiency of HR staffing levels and of overall HR resources 

available to the agency. As a result of this review, it was determined that OHR needed to 

prioritize backfilling a vacant HR Specialist position and created two new positions to fill gaps 

identified in the aforementioned evaluation. The FEC’s Personnel Committee supported OHR’s 

requests and approved filling all three positions as well as a backfill position created when an 

HR Specialist received an internal promotion. OHR permanently filled three of these positions 

in FY 2022 and FY 2023. While the fourth position has approval to fill, OHR currently cannot 

fill the position. As described in greater detail above, uncertainty regarding the timing and the 

level of funding for the FEC for the balance of FY 2024 has led to a pause in hirings, and OHR 

will seek to fill the position once hiring resumes. 

These additional hires bolster OHR’s workforce and capacity, while also significantly reducing 

the gap between the FEC’s per-employee HR staff levels and those at other medium 

independent agencies, noted by the OIG. The additional staff onboarded by OHR brings the 

office to a total of six employees,11 which is a 50 percent increase over previous staffing levels. 

With the agency’s current workforce of 307 employees, the per-employee HR staffing level is 

reduced from 74.5 employees per HR employee as cited in Table 6 of the Evaluation to 51.2 

employees per HR employee. Further, once OHR is able to hire for the seventh staff position, 

the per-employee HR staffing level would be further reduced. If the FEC maintains its current 

staffing level, the per-employee HR staffing ratio reduces even further to 43.9 employees per 

HR employee. This is very close to the average ratio of 35.1 staff per HR employee that the 

Evaluation cites for medium independent agencies. 

In addition, the agency continues to use OPM’s HR Solutions as a resource to further expand its 

capacity. While not factored into the per-employee HR staffing level, relying on this service 

allows the FEC access to increased staffing resources and to consult subject matter experts 

when needed. Benefits to FEC’s OHR include: 

11 Five of these employees are in Occupational Series Code 0201. 

91 (page 10 of 12 in Management Response)
 

 

 

• Access to higher-graded experts than what FEC has been historically able to recruit and 

retain in comparable subject matter areas; 

• The ability to scale up and scale down on a particular subject matter area, such as 

staffing, as workload dictates; 

• The ability to shift resources between HR specialties, such as move staffing to 

classification; and 

• Access to support for internal and external audits, government-wide best practices, and 

special/complex cases. 

Management appreciates the OIG’s agreement “in principle” that “OPM’s HR Solutions has the 

potential to leverage the FEC’s investment in overall human resources capacity.” Management 

intends to continue the FEC’s partnership with HR Solutions during the remainder of FY 2024 

and throughout FY 2025. 

Thus, Management partially concurs with Recommendation 2. While Management generally 

agrees with the recommendation and the important role HR plays in Agency administration and 

support, Management has already completed the evaluation activities suggested in the 

recommendation and has implemented multiple strategies to enhance HR resources available to 

the agency within current budget constraints. The FEC’s existing evaluation process paired with 

successfully implemented strategies demonstrates that FEC’s current approach to evaluating 

and monitoring the sufficiency of HR staffing levels and HR resources available to the agency 

is working effectively. As such, while Management’s current evaluation process will continue, 

it considers this recommendation closed. 

Recommendation 3 

Evaluate Budget Justifications: The FEC OIG recommends that the FEC evaluate data 

provided to OMB and Congressional appropriators to ensure budget justifications 

adequately communicate the agency’s personnel budget requirements. 

Management agrees with the recommendation and partially agrees with the conclusions reached 

by OIG through the analyses included in the report. The OIG Evaluation provides important 

historical context of FEC’s budgets. For much of the last decade, FEC’s budgets have been flat 

and likely decreasing in real terms once personnel and other inflation is considered. One 

consequence of this decrease in inflation adjusted budgets is lower staffing levels. 

Management intends to respond to Recommendation 3 by incorporating important pieces of the 

OIG analysis into its Budget document. These include the impact of mandatory pay and benefit 

increases on the topline FEC budget estimate. In recent years, FEC requested increases to 

support growth in personnel and non-personnel areas of the budget. For example, the FY 2023 

requested and enacted appropriation resulted in an over nine percent increase in the FEC 

budget. Utilizing the OIG material for future budgets will help clarify how higher personnel 

costs will grow budget need to maintain current service levels. 

92 (page 11 of 12 in Management Response)
 

 

 

While we agree with Recommendation 3, Management sees several additional aspects of the 

Federal budget cost estimating and approval process as predominant factors that determine 

ending budget figures and that were only partially considered in OIG’s conclusions. For 

example, an important perspective when analyzing FEC’s budget is its relatively small place in 

the structure of the larger Federal Budget process. For instance, like other agencies, FEC must 

generally follow OMB circular A-11 guidance for preparation of its budget. The current version 

of A-11 provides guidance and direction to forego budgeting for within-grade pay increases and 

incorporate savings from hiring lag times, leave without pay and filling vacancies at lower rates 

of pay. In addition, it provides guidance to budget at entry level salaries, when, for example, 

replacing employees who retire. While FEC maintains certain flexibilities through its 

independent budget bypass authority, it must be cognizant of the structure and format of 

information provided by other agencies to provide the most useful and compelling information 

for Congress and OMB. 

The OIG also rightly identifies the almost two-year time lag between initial budget 

development and enactment. During this time, Congress and OMB analyze individual budgets 

and often make decisions based the collective defense and nondefense discretionary and 

mandatory spending levels. These discussions can often take time and ultimately drive the 

specific funding levels for individual agencies, such as the FEC, as well the timing of 

appropriation enactment during the fiscal year. In addition, during this time, FEC’s operations 

and needs evolve, based on attrition of specific employees, technology trends and potentially 

because of policy changes. 

By its nature then, the FEC budgets are estimates that must incorporate some degree of possible 

future scenarios. This can be seen, for instance, in per employee costs estimated in FEC 

budgets. Much of the per staff, per year difference in budget calculations compared to the OIG 

analysis is likely due to when employees on-board, instead of specific cost drivers identified by 

OIG. These timing differences can lead to meaningful differences in budget execution. For 

example, a later enactment of an appropriation and consequently later initiation of hiring can 

create a funding balance at the end of the fiscal year. The one-year availability of FEC 

appropriations would then cause this funding to be “lost” and could harm the viability of future 

FEC requests. The reverse is also true, if enactment of an appropriation occurs before the 

timing estimates assumed in the initial budget. Given this, the FEC budgets take great care to 

estimate funds needed to support agency priorities, while also requesting levels that are 

executable within many possible future scenarios. 

93 (page 12 of 12 in Management Response)
 

Appendix E: Edits and Changes Between the Draft Evaluation 

Provided to Management and the Final Report 

The following list identifies all additions and revisions made to this report between the draft 

version provided for FEC management response and the final published version. 

• Accessibility content has been added in compliance with Section 508 Standards95 of 

accessibility to persons with disabilities. 

• The FEC Management Response was added in its entirety as Appendix D. 

• A summary of the FEC Management Response, including OIG observations, was added. 

• Summary section 12 on supervisory disparities was expanded to incorporate a chart 

showing that the FEC successfully bridged the supervisory gap that had historically 

existed with respect to women. This chart had previously appeared only in the evaluation 

body. 

• The first “not” was removed from the third bullet in the list of takeaways. “The decline is 

not attributable to hiring, not attrition (which has been low at the FEC).” now reads “The 

decline is attributable...”. 

• A statistic was introduced and used in the OIG discussion of the FEC Management 

Response. It had not been present in the Draft Evaluation reviewed by management and 

reads as follows: 

“Of the 31 non-FEC agencies in this comparison group, five had staffing level 

declines greater than the FEC (an average of 16.9% compared to the FEC’s decline of 

11.5%). These five are the Holocaust Museum, Surface Transportation Board, 

Railroad Retirement Board, Peace Corps, and Presidio Trust. The remaining 26 

agencies experienced an average staffing level increase of 4.7%.”

• The discussion of the databases that were utilized was revised to correctly identify 

retirement eligibility as the analysis derived from FEC-provided (not public) data. A 

footnote was also added referencing our use of HR-provided data to corroborate the 

impact of OPM’s HR Solutions services. 

• A footnote was added in the discussion of Chart 6, Decrease in the FEC’s InflationAdjusted Appropriations, to provide the inflation-adjusted decrease for the period FY 

2015 through FY 2022 of 4.2%. 

• The statement above Table 5 (on salary growth by staff cohort) that commissioner 

salaries had been reduced by $200 over the FY 2015 to FY 2022 period was corrected to 

95 https://www.section508.gov/ 

94 
 

 

indicate that commission salaries have been flat. The discrepancy stems from a payroll 

discrepancy that was subsequently corrected. 

• Paragraph five of “Specific Agency Benchmarks for Number of HR Staff and Ratio of 

Total Staff to HR Staff” was edited to provide improved clarity:

Original. “...we agree in principal that OPM’s HR Solutions has the potential to 

leverage the FEC’s investment in overall human resources capacity. One piece of 

evidence cited by HR to support this view is that the average time to hire at the FEC 

has decreased by 37 days since HR Solutions was engaged in 2018. 

Revised. “...we agree in principal that OPM’s HR Solutions has the potential to 

leverage the FEC’s investment in overall human resources capacity. FEC HR did cite

a reduction in time to hire since HR Solutions was engaged in 2018 as specific 

evidence that HR Solutions services have improved FEC HR performance. The OIG 

was able to confirm that the average time to hire was reduced by 37 days from FY 

2018/2019 to FY 2022/2023 with efficiency gains in hiring phases under both HR 

Solutions and FEC HR responsibility. 

• The actual 5.31% increase (as opposed to projected 5.2%) for 2024 in the GS pay table 

was referenced and footnoted after Chart 13. 

• The FY 2024 budget discussion was updated to reflect that the FEC is currently under a 

second continuing resolution expiring March 8, 2024. 

• Furloughs are referenced as a tool to reduce personnel spending in the section examining 

the implications of a FY 2022 ($74.5 million) appropriation level for FY 2024. This tool 

was highlighted by the FEC in its Management Response to the Evaluation draft. 

• Clarification was added for Chart 15 (proportion of FEC staff by race/ethnicity) that the 

data presented is based on DC-based permanent staff (career staff: GS permanent and 

SL). 

• Corresponding clarification was added for Chart 18 (proportion of FEC staff and 

supervisors by race/ethnicity) that SL staff were excluded. SL statistics are presented in 

the added footnote. 

Cover art: “Cherry Blossoms around the Tidal Basin in Washington, D.C.”

From the photographs in the Carol M. Highsmith Archive, Library of Congress, Prints and 

Photographs Division. Source. 

95