GAO-03-779R Human Capital 

United States General Accounting Office 

Washington, DC 20548 

Comptroller General

of the United States

May 22, 2003 

The Honorable George V. Voinovich 

Chairman 

The Honorable Richard J. Durbin 

Ranking Minority Member 

Subcommittee on Oversight of Government Management, 

 the Federal Workforce, and the District of Columbia 

Committee on Governmental Affairs 

United States Senate 

The Honorable Jo Ann Davis 

Chairwoman 

The Honorable Danny Davis 

Ranking Minority Member 

Subcommittee on Civil Service and Agency Organization 

Committee on Government Reform 

House of Representatives 

Subject: Posthearing Questions Related to Strategic Human Capital Management 

On April 8, I testified before your Subcommittees at a hearing on “The Human Capital 

Challenge: Offering Solutions and Delivering Results”.1

 This letter responds to 

requests from Chairman Voinovich, Chairwoman Davis, and Senator Carper that I 

provide answers to follow-up questions from the hearing. The questions, along with 

my responses, follow. 

Questions from Chairman Voinovich

1. In your testimony, you discuss the need to preserve and share an agency’s 

institutional knowledge in light of the impending retirement wave by using 

various means of “phased retirement.” Proposed in my Federal Workforce 

Flexibility Act are provisions to make it more desirable for individuals to 

work part-time at the end of their career. What other options might 

Congress consider to ease this transition? 

There are a variety of options that should be considered; however, they all require 

further analysis to ensure they would be cost-effective in retaining the institutional 

knowledge of key employees as they approach and become eligible for retirement. 

 

1

U.S. General Accounting Office, Human Capital: Building on the Current Momentum to Address 

High-Risk Issues, GAO-03-637T (Washington, D.C.: Apr. 8, 2003). 
Page 2 GAO-03-779R Human Capital 

For example, one option would be to allow retirement eligibles to continue working 

after retirement eligibility on a part-time basis and factor in that service when making 

pension calculations. However, for those employees who are under the Civil Service 

Retirement System, legislation would be needed to remove the so-called penalty on 

their retirement annuity for working part time. Another option would be to allow 

certain employees to retire and receive their annuity and continue to work part time 

for up to a stated period of time (e.g., 1 – 2 years) without a pension offset. Both of 

these options would help agencies address succession planning and knowledge 

transfer challenges. In all cases, however, Congress should consider placing certain 

criteria along with numerical or percentage of workforce caps on agencies’ use of 

such authorities to prevent abuse. 

2. GAO has been successful in implementing personnel reforms that clearly 

emphasize the importance of human capital. Part of your success has been 

achieved through GAO-specific legislation, but your agency also has been 

successful in implementing governmentwide reforms. Unfortunately, other 

agencies have not been as successful. As agencies begin to consider the 

governmentwide flexibilities included in last year’s homeland security 

legislation, please discuss in a bit more detail how GAO has been successful 

in the past. 

As noted in my statement for the hearing, we have reported on the capabilities that 

agencies need to have in place to effectively use the human capital flexibilities and 

authorities that Congress has provided.2

 Our own approach to the use of the 

authorities that Congress has provided us has been consistent with the practices of 

leading organizations, as shown in figure 1. 

 

2

U.S. General Accounting Office, Human Capital: Effective Use of Flexibilities Can Assist Agencies 

in Managing Their Workforces, GAO-03-2 (Washington, D.C.: Dec. 6, 2002). 
Page 3 GAO-03-779R Human Capital 

Figure 1: Key Practices for Effective Use of Human Capital Flexibilities 

In our specific situation, we developed data-driven business cases to demonstrate the 

need for the authorities, how they would be used, and took steps to assure that 

safeguards were in place to ensure their proper and fair use. We also have involved 

our employees at all levels in the development and implementation of our human 

capital policies and programs to improve the quality of those policies and programs 

and build GAO-wide ownership for the changes we are making. Further, we have 

used our human capital initiatives as part of, and consistent with, broader efforts we 

have underway to instill a more results-oriented culture throughout GAO. Finally, we 

monitor and evaluate our efforts and publicly report on our use of the authorities 

both to assure our own accountability as well as to provide lessons for other 

agencies. 

3. You have recommended the creation of a nonpolitical chief operating 

officer at federal agencies. While your roundtable discussion did not achieve 

consensus on the concept, it did lay out three “themes” that should be 

considered. Would you like to elaborate a bit more on these themes and 

what more Congress and agencies can do to facilitate this discussion? 

GAO convened a roundtable on September 9, 2002, to discuss the Chief Operating 

Officer (COO) concept and how it might apply within selected federal departments 

and agencies as one strategy to address certain systemic federal governance and 

management challenges. We reported that there was general agreement that the 

following three themes provide a course for action.3

 

3

U.S. General Accounting Office, Highlights of a GAO Roundtable: The Chief Operating Officer 

Concept: A Potential Strategy To Address Federal Governance Challenges, GAO-03-192SP 

(Washington, D.C.: Oct. 4, 2002). 
Page 4 GAO-03-779R Human Capital 

 

• Elevate attention on management issues and transformational change. 

• Integrate various key management and transformation efforts. 

• Institutionalize accountability for addressing management issues and leading 

transformational change. 

The participants also offered a number of ideas to help address agencies’ 

management weaknesses and drive transformational change. First, while there is no 

“one size fits all” solution to address the challenges agencies face, the critical point is 

to craft an approach in each case that (1) sets responsibility and accountability for 

functional management issues and transformational change at an organizational level 

appropriate for the types of reforms that are needed and (2) creates integrated 

leadership responsibility in a single organizational position for key management 

functions such as human capital, financial management, information technology, 

acquisition sourcing strategies, and performance management as well as for 

transformational change initiatives, if appropriate. 

Second, participants suggested that Congress should make clear in statute the broad 

responsibilities and qualifications for at least the senior official responsible for 

management and transformation. Congress has taken this general approach with 

other important management legislation, such as the Chief Financial Officers Act 

(CFO), which requires CFOs to “possess demonstrated ability in general management 

of, and knowledge of and extensive practical experience in financial management 

practices in large governmental or business entities” and clearly lays out the CFOs’ 

responsibilities. By establishing the broad CFO responsibilities in statute, Congress 

created a number of important advantages: unambiguous expectations for the 

position, a professional approach, and an implicit set of qualification standards and 

expectations. 

Third, participants also widely agreed that augmented accountability mechanisms are 

needed to help assure the success of key management and transformational change 

efforts. To help provide the continuing focused attention essential to successfully 

completing multiyear transformational change, the important role that congressional 

oversight has played and can play in fostering improvements was acknowledged at 

the forum. Likewise, public reporting, such as the annual performance plans and 

performance reports required by the Government Performance and Results Act and 

audited financial statements under the CFO Act, can provide useful information on 

agencies’ progress in meeting goals and addressing mission-critical management 

challenges. The use of performance contracts for senior leaders was also recognized 

as being a potentially important mechanism for clarifying expectations, monitoring 

progress, and assessing accountability. 

Questions from Chairwoman Davis

1. Far too often, when agency budgets are short, training is the first item cut. 

The world’s top companies have a commitment to training because training 

helps ensure the skills and performance necessary for an organization to 

meet its goals. The Federal Workforce Flexibility Act, which was introduced 

by both Senator Voinovich and myself, enhances the institutional manner in 

which employees are trained in the federal government. How critical is 
Page 5 GAO-03-779R Human Capital 

employee training to attract, retain and improve the performance of the 

federal workforce? 

A strategically sound training and development program is critical to both building 

and retaining an effective federal workforce. Initiatives such as the Federal 

Workforce Flexibility Act that Chairwoman Davis and Chairman Voinovich have 

introduced are evidence that this area is beginning to receive the increased emphasis 

and attention it warrants. 

A learning environment, with opportunities to update and enhance an individual’s 

skills and competencies, is an attractive feature for prospective and new employees 

as well as for current and long-time employees. People want to work where they will 

be able to continue to learn and grow as they develop their careers. As in the private 

sector, effective training and development opportunities are an important element in 

the package that the federal government needs to be able to offer in the “war for 

talent.” Once employees are onboard, strategic training and development efforts can 

help ensure that, as part of succession planning, new leaders are developed and ready 

to take on new roles and assume greater responsibilities. 

Training and development opportunities are also a tangible example of the need to 

invest in human capital, both in terms of time and budgetary resources. The Federal 

Workforce Flexibility Act calls for agencies to evaluate their training programs and 

plans to ensure that they are linked to strategic and performance goals and contribute 

to achieving the agency’s mission. This is a key step in making a business case and 

demonstrating that training and development efforts, like other strategic human 

capital management investments, are a vital and integrated part of agencies’ ability to 

marshal, manage, and maintain the human capital needed to maximize government 

performance and assure its accountability. 

2. At our hearing on April 1, we talked about the crucial importance of 

performance management improvements by federal agencies before a payfor-performance system will work well. At the same time, as the Deputy 

Director of the Office of Personnel Management (OPM) pointed out last 

week, the current system of lock-step raises provides no incentive for agency 

managers to devote their attention to the difficult job of improving their 

performance management. So we have a chicken-and-egg problem here. If 

we wait for better appraisals before we get to pay for performance, we may 

never get there. In your own experience at GAO, what amount of time 

separated the first pay raises under a banded pay system and the first 

appraisals under the new competency-based performance management 

system? What approach would you recommend for this problem? 

While there is growing agreement on the need to better link individual pay to 

performance, experience has shown that moving too quickly—and prematurely—

significantly raises the risk of doing it wrong, which could severely set back the 

current momentum. Thus, while it is imperative that we take steps to better link 

employee pay to performance across the federal government, how it is done, when it 

is done, and the basis on which it is done, can make all the difference in whether or 

not such efforts are successful. In our own case, we began making significant 
Page 6 GAO-03-779R Human Capital 

changes to our analyst performance management system in 2000 and made more 

direct links between performance and pay as a result of the 2002 appraisal cycle. It 

should be noted, that we had over a decade of experience in the use of pay banding 

before we undertook our recent changes, so much of the needed organizational 

infrastructure was already in place. With regard to executive branch agencies, the 

key to progress over the next year is to create performance management systems that 

are capable of supporting more performance based pay and other personnel 

decisions. Such performance management systems are based on the practices used 

by leading organizations to align individual performance with organizational success 

and have the institutional infrastructures that provide adequate safeguards, 

reasonable transparency, and appropriate accountability mechanisms.4

 The critical 

issue is not so much the length of time needed, but rather the extent to which agency 

senior leadership is willing to provide the priority attention and targeted investments 

needed to create and maintain a results-oriented performance management system. 

Finally, in our view, appropriate systems and safeguards should be in place before 

any additional pay for performance authority is actually implemented or 

operationalized under this approach. Congress could authorize such authority while 

providing that certain conditions must be met before the authority can be 

implemented or operationalized. 

3. Last week, when we asked the Deputy Director of OPM about the 

desirability of eliminating the General Schedule altogether, he testified that 

the Administration’s proposal for a $500 million Human Capital Performance 

Fund was a “downpayment” on pay reform. Would you agree that the Human 

Capital Performance Fund is a step in the right direction, if perhaps only a 

baby step? Do you think the executive branch is capable of doing a good 

enough job on performance appraisals to experiment on about one half of 

one percent of pay? Maybe this is a way to get some energy into the agencies 

when it comes to improving their performance management. 

Modern, reliable, effective, and, as appropriate, validated performance management 

systems with adequate safeguards, including reasonable transparency and 

appropriate accountability mechanisms, must serve as the fundamental underpinning 

of any successful results-oriented pay reform. Most executive branch agencies are a 

long way from meeting this essential test. 

To build the necessary performance management systems within agencies and to 

create incentives for progress, I suggested in my testimony that Congress should 

consider establishing a governmentwide fund where agencies, based on a sound 

business case, could apply to OPM for funds to be used to modernize their 

performance management systems and ensure that those systems have adequate 

safeguards to prevent abuse. The basic idea is to provide for targeted investments 

needed to prepare agencies to use their performance management systems as 

strategic tools to achieve organizational results and drive cultural change. (If 

successful, this approach to targeted investments could be expanded to foster and 

support agencies’ related transformation efforts, including other aspects of the High 

 

4

U.S. General Accounting Office, Results-Oriented Cultures: Creating a Clear Linkage between 

Individual Performance and Organizational Success, GAO-03-488 (Washington, D.C.: Mar. 14, 2003). 
Page 7 GAO-03-779R Human Capital 

Performing Organization (HPO) concept recommended by the Commercial Activities 

Panel.) 

Congress should also consider providing the authority where whole agencies and/or 

employee groups move to a pay for performance approach only after it has been 

demonstrated to OPM that a modern, reliable, effective, and, as appropriate, validated 

performance management system with adequate safeguards, including reasonable 

transparency and appropriate accountability mechanisms, is in place to support pay 

and related personnel decisions. In any case, Congress should consider establishing 

statutory principles for the standards that an agency must have in place before OPM 

can grant additional pay flexibilities. OPM, working with the Chief Human Capital 

Officers’ Council, would issue guidance implementing legislatively-defined principles. 

As a first step, the Senior Executive Service needs to lead the way in the federal 

government’s effort to better link pay to performance. We have reported that there 

are significant opportunities to strengthen efforts to hold senior executives 

accountable for results.5

 

4. I notice in your testimony that you believe OPM should play an aggressive 

leadership role in the area of human capital management. If pay and 

performance management systems are handed over to individual agencies so 

they can tailor their systems to their particular needs and objectives, what 

role in setting compensation policy would you foresee for OPM? 

We have reported that OPM leadership is critical to accomplish its mission in a 

decentralized human capital environment in which direct accountability for strategic 

human capital management continues to shift to agencies.6

 In particular, as noted 

above, OPM should certify that an agency has a modern, effective, credible, and as 

appropriate, validated performance management system in place before the agency is 

granted the authority to better link pay to performance for broad-based employee 

groups. In addition, OPM should gather, assess, and disseminate leading practices 

from federal organizations on a full range of innovative human capital policies and 

procedures, such as pay for performance. Further, OPM should build on its White 

Paper to design and lead a broad research agenda to develop a more market-based 

approach to federal pay. 

5. What legislative changes do you think are most important for us to enact 

in this Congress to improve the government’s human resources management 

over both the short and long term? Or, if we could only get one change, what 

should that be? 

The need for results-oriented pay reform is one of the most pressing human capital 

issues facing the federal government today. As implied in our answers above, 

Congress could provide broad-based authority for broadbanding and pay for 

performance along with specific statutory standards that would have to be met 

 

5

U.S. General Accounting Office, Results-Oriented Cultures: Using Balanced Expectations to Manage 

Senior Executive Performance, GAO-02-966, (Washington, D.C.: Sept. 27, 2002). 6

U.S. General Accounting Office, Major Management Challenges and Program Risks: Office of 

Personnel Management, GAO-03-115 (Washington, D.C.: January 2003). 
Page 8 GAO-03-779R Human Capital 

before such authorities can be operationalized. An agency should have to 

demonstrate, and OPM should have to certify, that a modern, effective, credible, and, 

as appropriate, validated performance management system with adequate safeguards, 

including reasonable transparency and appropriate accountability mechanisms, is in 

place to support more performance-based pay and related personnel decisions, 

before the agency could implement a new system. OPM should be required to act on 

any individual certifications within prescribed time frames (e.g., 30-60 days). 

6. Similarly, where do you think we should most focus our oversight 

attention in the area of human resources management? 

Congress has had and will need to continue to have a central role in improving 

agencies’ human capital approaches. First and foremost, congressional oversight is 

important to ensure that agencies human capital plans and programs are integrated 

with program missions and goals. Too often in the past, agencies’ program initiatives 

were designed and implemented without due regard to the human capital 

implications that these program decisions entail. In addition, Congressional 

oversight is important to ensure that agencies effectively and properly use human 

capital authorities and flexibilities that Congress has provided, for example those in 

the Homeland Security Act. While agencies’ first priority should be to improve their 

human capital management by using the authorities already available to them, 

additional flexibilities may be appropriate where clear business cases have been 

established. 

Questions from Senator Carper

1. In recent years, Congress has granted agencies like the Internal Revenue 

Service and the Federal Aviation Administration some additional personnel 

flexibilities aimed at meeting agency-specific problems. Just this year, the 

National Aeronautics and Space Administration came to this committee with 

its own set of problems and suggested some reforms aimed at recruiting 

workers with advanced degrees in math and science. Would it be better for 

Congress to address human capital issues on an agency-by-agency basis 

rather than enacting broad reforms that may not be well suited for everyone? 

We strongly support the concept of modernizing federal human capital policies, 

including providing reasonable flexibility to management in this critical area provided 

adequate safeguards are in place to prevent abuse. In this regard, we believe that 

Congress should consider both governmentwide and selected agency changes to 

address the pressing human capital issues confronting the federal government. 

Agency-specific human capital reforms should be enacted to the extent that the 

problems being addressed and the solutions offered are specific to a particular 

agency (e.g., military personnel reforms for the Department of Defense). In addition, 

targeted reforms should be considered in situations where additional testing or 

piloting is needed for fundamental governmentwide reform. 

In our view, it would be preferable to employ a governmentwide approach to address 

certain flexibilities that have broad-based application (e.g., broadbanding, pay for 

performance, part-time employment, reemployment annuities) and serious potential 
Page 9 GAO-03-779R Human Capital 

implications for the civil service system, in general, and OPM, in particular. In these 

situations, it may be prudent and preferable for Congress to provide such authorities 

on a governmentwide basis and in a manner that ensures that appropriate 

performance management systems and safeguards are in place before the new 

authorities are implemented by the respective agency. This approach is not intended 

to delay action on any individual agency’s efforts, but rather to accelerate needed 

human capital reform throughout the federal government in a manner that ensures 

reasonable consistency on key principles within the overall civilian workforce. This 

approach also would provide agencies with reasonable flexibility while incorporating 

key safeguards to help maximize the chances of success and minimize the chances of 

abuse and failure. This approach would also help to maintain a level playing field 

among federal agencies in competing for talent and avoid a further fragmentation of 

civil service in key areas. 

However, in all cases whether from a governmentwide authority or agency specific 

legislation, in our view, such additional authorities should be implemented (or 

operationalized) only when an agency has the institutional infrastructure in place to 

make effective use of the new authorities. This institutional infrastructure includes, 

at a minimum, a human capital planning process that integrates the agency’s human 

capital policies, strategies, and programs with its program goals and mission, and 

desired outcomes; the capabilities to effectively develop and implement a new human 

capital system; and importantly, the existence of a modern, effective, credible, and 

validated performance management system that includes adequate safeguards, 

including reasonable transparency and appropriate accountability mechanisms, to 

ensure the fair, effective, and nondiscriminatory implementation of the system. 

2. In your view, how helpful can the streamlined hiring process authorized 

through the Homeland Security Act be in helping agencies address their 

personnel problems? How helpful can the other governmentwide personnel 

provisions included in the bill be? 

Much of the authority agency leaders need to manage human capital strategically is 

already available under current laws and regulations, especially in connection with 

modernizing existing performance appraisal and management systems.7

 In that 

regard, we believe that the hiring and other central provisions of the Homeland 

Security Act will serve as important tools for agencies to use to address their hiring 

and other human capital needs. For example, the Homeland Security Act included 

significant provisions relating to categorical ranking when considering applicants, 

direct hire authority, the creation of chief human capital officer (CHCO) positions 

and a CHCO Council, an expanded voluntary early retirement and “buy-out” 

authority, a requirement to discuss human capital approaches in Government 

Performance and Results Act plans and reports, and a provision allowing executives 

to receive their total performance bonus in the year in which it is awarded. 

3. What are the specific safeguards against discrimination and abuse that you 

believe need to be in place before an agency can implement a “pay for 

performance” program? 

 

7

To assist agencies in identifying available human capital flexibilities, OPM has published Human 

Resources Flexibilities and Authorities in the Federal Government (Washington, D.C.: July 2001). 
Page 10 GAO-03-779R Human Capital 

At the request of Representative Danny Davis, we developed an initial list of possible 

safeguards for Congress to consider to help ensure that any pay for performance 

systems in the government are fair, effective, and credible: 

• Assure that the agency’s performance management systems (1) link to the 

agency’s strategic plan, related goals, and desired outcomes and (2) result in 

meaningful distinctions in individual employee performance. This should include 

consideration of critical competencies and achievement of concrete results. 

• Involve employees, their representatives, and other stakeholders in the design of 

the system, including having employees directly involved in validating any related 

competencies, as appropriate. 

• Assure that certain predecisional internal safeguards exist to help achieve the 

consistency, equity, nondiscrimination, and nonpoliticization of the performance 

management process (e.g., independent reasonableness reviews by Human 

Capital Offices and/or Offices of Opportunity and Inclusiveness or their equivalent 

in connection with the establishment and implementation of a performance 

appraisal system, as well as reviews of performance rating decisions, pay 

determinations, and promotion actions before they are finalized to ensure that 

they are merit-based; internal grievance processes to address employee 

complaints; and pay panels whose membership is predominately made up of 

career officials who would consider the results of the performance appraisal 

process and other information in connection with final pay decisions). 

• Assure reasonable transparency and appropriate accountability mechanisms in 

connection with the results of the performance management process (e.g., publish 

overall results of performance management and pay decisions while protecting 

individual confidentiality and report periodically on internal assessments and 

employee survey results). 

The above items should help serve as a starting point for Congress to consider in 

crafting possible statutory safeguards for executive agencies’ performance 

management systems. OPM would then issue guidance implementing the legislatively 

defined safeguards. 

4. What role should employees play in administering any “pay for 

performance” initiative tested or put into place at the federal level? 

We have reported that the involvement of employees both directly and indirectly is 

crucial to the success of new initiatives, including implementing a pay for 

performance system.8

 Performance management systems are more effective when 

employees perceive the process to be fair and the criteria to be clearly defined, 

transparent, and consistently applied. Leading organizations have found that by 

 

8

U.S. General Accounting Office, Results-Oriented Cultures: Insights for U.S. Agencies from Other 

Countries’ Performance Management Initiatives, GAO-02-862 (Washington, D.C.: Aug. 2, 2002) and 

Human Capital: Practices That Empowered and Involved Employees, GAO-01-1070 (Washington, 

D.C.: Sept. 14, 2001). 
Page 11 GAO-03-779R Human Capital 

actively involving employees, unions, or other employee associations when 

developing results-oriented performance management systems, employee confidence 

and belief in the fairness of incentive programs improves due to an understanding of 

why certain employees were rewarded. To involve stakeholders and employees 

when reforming their performance management systems, agencies should: 

• Consult a Wide Range of Stakeholders Early in the Process. 

• Obtain Feedback Directly from Employees. Directly asking employees to provide 

feedback on proposed changes in their performance management systems 

encourages a direct sense of involvement and buy-in, allows employees to express 

their views, and helps to validate the system to ensure that performance measures 

are appropriate. 

• Engage Employee Unions or Associations. Effective labor-management relations 

help to achieve consensus on planned changes, avoid misunderstandings, and 

assist in the expeditious resolution of problems. 

For additional information on our work on federal agency transformation efforts and 

strategic human capital management, please contact me on 512-5500 or J. Christopher 

Mihm, Director, Strategic Issues, at 512-6806 or at mihmj@gao.gov. 

David M. Walker 

Comptroller General 

of the United States 

(450218) 
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