FOREIGN AFFAIRS 

MANAGEMENT

State Department Has 

Strengthened Foreign 

Service Promotion 

Process Internal 

Controls, but 

Documentation Gaps 

Remain

Report to Congressional Requesters

July 2013

GAO-13-654

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-654, a report to 

congressional requesters.

July 2013

FOREIGN AFFAIRS MANAGEMENT

State Department Has Strengthened Foreign Service 

Promotion Process Internal Controls, but 

Documentation Gaps Remain

Why GAO Did This Study

State’s Foreign Service promotion 

process follows an up-or-out principle, 

under which failure to gain promotion 

to higher rank within a specified time 

leads to mandatory retirement for 

personnel in certain occupational 

categories. State’s OIG and the 

Foreign Service Grievance Board 

identified procedural concerns relating 

to the process in 2010. 

GAO was asked to review the Foreign 

Service promotion process. This report 

examines (1) State’s process for 

ranking and promoting Foreign Service 

personnel, (2) procedural changes

State has made to its Foreign Service 

promotion process in response to 

identified concerns, and (3) the extent 

to which updated procedures were 

consistently followed in 2011 and 2012 

and whether any notable concerns 

about the promotion process remain. 

GAO reviewed laws and procedures;

analyzed selection, performance 

standards, and reconstituted board 

files as well as grievance case files for 

the 2011 and 2012 promotion cycles;

interviewed State officials; and 

contacted 2011 and 2012 board 

members to offer them an opportunity 

to comment on the process.

What GAO Recommends

GAO recommends that State take 

actions to ensure full implementation of 

promotion process internal controls. 

State concurred with GAO’s

recommendation.

What GAO Found

The Department of State’s (State) Foreign Service promotion process includes

convening several types of boards to evaluate candidates for promotion and 

identify other candidates for possible separation from the Service. State has a 

separate process to address related grievances. Selection boards review all 

candidates and sort them into one of three categories: promotable, mid-ranked, 

and low-ranked. The selection boards produce rank-ordered lists of those 

candidates recommended for promotion, and a “cut line” is subsequently 

determined based on the number of available promotion slots. Before 

announcing promotions, State vets all recommended candidates to determine 

whether there are outstanding issues, such as a pending investigation, that can 

lead to their removal from the promotion list. Subsequently, State convenes 

performance standards boards to assess low-ranked candidates for possible 

separation from the Service. There are several mechanisms to address 

grievances relating to the promotion process. For example, State may initiate

reconstituted boards to reassess candidates if a board failed to follow the 

procedures or if the underlying performance information contained omissions or 

inaccuracies. Employees not satisfied with grievance outcomes can file an 

appeal with the Foreign Service Grievance Board.

In response to concerns identified by the Office of Inspector General (OIG) and 

Foreign Service Grievance Board in 2010, State has taken a number of actions 

to strengthen its Foreign Service promotion process internal controls. For 

example, in response to concerns about improper introduction of information 

about candidates, State instituted a requirement that board members sign an 

oath to adhere to the promotion criteria and protect the confidentiality of board 

materials. State also revised its procedures governing recusal requests, thereby 

broadening the provisions under which a candidate can request an individual 

board member’s recusal from reviewing their file. In addition, State updated its 

reconstituted board procedures, outlining a set of required documents, such as 

signed board member score sheets, to be included in each board’s official 

record. In addition to actions taken in response to others’ identified concerns, 

State initiated other practices to strengthen promotion process safeguards, such 

as including selection board and reconstituted board member recusal memos in 

the final board report.

GAO found that Foreign Service selection boards, performance standards 

boards, and reconstituted boards complied with many of State’s updated 

procedures in the 2011 and 2012 Foreign Service promotion cycles, but some 

board reports had documentation gaps for certain internal controls. For example, 

all 41 selection board reports we reviewed included a signed memo certifying 

final results. However, only 29 of 41 selection boards had signed oaths from all 

board members, and 45 of 122 required oaths were missing from 2012 selection 

board reports. In addition, some board reports lacked documentation of some 

recusal requests. The absence of a fully documented system of controls 

increases the risk that intentional or unintentional failures to implement 

safeguards, by board members or State Human Resources staff, may go 

undetected and uncorrected. Such a failure to implement safeguards, in turn, 

increases the risk that the integrity of promotion results could be intentionally or 

inadvertently compromised. 

View GAO-13-654. For more information, 

contact Michael J. Courts at (202) 512-8980 or 

courtsm@gao.gov.
Page i GAO-13-654 Foreign Affairs Management

Letter 1

Background 2

The Foreign Service Promotion Process Includes Several Boards 

That Evaluate Promotion Candidates 5

State Has Developed Procedural Changes to Address Identified 

Concerns with the Foreign Service Promotion Process 12

State Complied with Many Updated Procedures in 2011 and 2012, 

but Some Documentation Gaps Existed 16

Conclusions 22

Recommendation for Executive Action 22

Agency Comments and Our Evaluation 23

Appendix I Objectives, Scope, and Methodology 24

Appendix II Comments from the Department of State 30

GAO Comment 32

Appendix III GAO Contact and Staff Acknowledgments 33

Table

Table 1: Summary Data for 2011 and 2012 Foreign Service 

Selection Boards 10

Figures

Figure 1: Key Steps in Department of State’s Foreign Service 

Promotion Process 6

Figure 2: 2011 and 2012 Selection Board Compliance with Internal

Controls 17

Figure 3: 2011 and 2012 Performance Standards Board Compliance 

with Internal Controls 18

Figure 4: Reconstituted Board Compliance with Internal Controls 

from October 2011 to April 2013 19

Contents
Page ii GAO-13-654 Foreign Affairs Management

Abbreviations

AFSA American Foreign Service Association 

HR Bureau of Human Resources

State Department of State

OIG Department of State Office of Inspector General

Director General Director General of the Foreign Service and

Director of Human Resources

EER Employee Evaluation Report

FAM Foreign Affairs Manual

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-654 Foreign Affairs Management

441 G St. N.W.

Washington, DC 20548

July 18, 2013

The Honorable Ed Royce

Chairman

The Honorable Eliot L. Engel

Ranking Member

Committee on Foreign Affairs

House of Representatives

The Honorable Ileana Ros-Lehtinen

House of Representatives

The Department of State (State) assessed more than 8,500 Foreign 

Service personnel performance files for the 2012 promotion process. 

State’s Foreign Service promotion system follows an up-or-out principle, 

under which failure to gain promotion to a higher rank within a specified 

period for certain personnel leads to mandatory retirement. Key aspects 

of State’s promotion process include the annual convening of selection 

boards, State’s processing of selection board results, and the convening 

of performance standards boards to determine whether “low ranked”

officers should be recommended for separation from the Foreign Service. 

Subsequent to previous allegations of improprieties in the process, 

State’s Office of Inspector General (OIG) reviewed State’s Foreign 

Service promotion process and concluded, in March 2010, that it was 

fundamentally fair and trustworthy.1

You asked us to examine State’s Foreign Service promotion process in 

light of previously identified concerns. This report addresses actions 

taken by State since March 2010 to help ensure the Foreign Service 

promotion process operates with fairness and integrity. Specifically, this 

report examines (1) State’s process for ranking and promoting Foreign 

Service personnel, (2) procedural changes State has made to its Foreign 

Service promotion process in response to identified concerns, and (3) the 

Nonetheless, the OIG identified areas 

of concern and made recommendations to strengthen the process, which 

State agreed to implement.

 1

United States Department of State and the Broadcasting Board of Governors Office of 

Inspector General, Review of the Integrity and Fairness of the Foreign Service Selection 

Board Process, ISP-I-10-47 (Washington, D.C.: March 2010). The report focused on the 

2004 to 2008 promotion cycles.
Page 2 GAO-13-654 Foreign Affairs Management

extent to which updated procedures were consistently followed in 2011 

and 2012 and whether any notable concerns about the promotion process 

remain.

To review State’s process for ranking and promoting Foreign Service 

personnel, we reviewed relevant laws, regulations, and procedures 

governing State’s promotion and grievance processes, and interviewed 

officials from State’s Bureau of Human Resources (HR). We reviewed 

State data on the 2011 and 2012 Foreign Service promotion cycles. We 

reviewed how these data were collected, entered, and checked for 

accuracy, and determined them to be sufficiently reliable for our 

purposes. To examine the procedural changes State has made to its 

Foreign Service promotion process, we reviewed concerns identified by 

the OIG and State’s Foreign Service Grievance Board and whether they 

had been addressed. We determined whether State’s responses had 

been incorporated into its operating procedures, policies, and supporting 

documentation by reviewing relevant agency documents. To determine 

whether procedural changes were consistently followed and appropriately 

documented, we reviewed relevant grievance files and selection board, 

performance standards board, and reconstituted board records—referred 

to as board reports. To determine whether additional notable concerns 

remain, we reviewed all 2011 and 2012 selection board reports, 

specifically these boards’ written concerns and recommendations on how 

to improve the promotion process, as well as all grievances filed after the 

2011 promotion cycle was completed, which were recorded by grievance 

staff as those related to promotion, low ranking, performance standards 

boards, or separation. We also administered an online data collection tool 

to members of the 2011 and 2012 selection boards, performance 

standards boards, and reconstituted boards to determine whether they 

had any concerns with the operations of their boards.

We conducted this performance audit from July 2012 to July 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Further details on our scope 

and methodology can be found in appendix I.

State’s Foreign Service promotion process is governed by the Foreign 

Affairs Manual (FAM), the Foreign Service Act, and the Procedural Background
Page 3 GAO-13-654 Foreign Affairs Management

Precepts for the Foreign Service Selection Boards—referred to as the 

procedural precepts.2 The procedural precepts are negotiated each year 

between State and the American Foreign Service Association (AFSA)3

The decision criteria for promotion in the Foreign Service, also known as 

the core precepts, provide the guidelines by which selection boards 

evaluate Foreign Service personnel for promotion. At least every 3 years, 

State and AFSA negotiate the core precepts. The core precepts define 

specific skills and levels of accomplishment expected at different grades 

and across the core competencies of Foreign Service personnel. These 

competencies include leadership skills, management skills, interpersonal 

skills, communication and foreign language skills, intellectual skills, and 

substantive knowledge—the skills, knowledge, and ability an employee 

applies to the job.

, 

and establish the scope, organization, and responsibilities of the Foreign 

Service selection boards that evaluate candidates for promotion. The 

procedural precepts cover areas such as the conditions for eligibility for 

promotion, guidance for boards on evaluating candidates, and the 

information boards are required to submit to the Director General of the 

Foreign Service and Director of Human Resources (Director General). 

The procedural precepts are provided to all selection board members at 

the convening of the boards and, according to State officials, are made 

available to all Foreign Service personnel worldwide.

State’s Foreign Service promotion system follows an up-or-out principle, 

under which failure to gain promotion to higher rank within a specified 

period in a single salary class leads to mandatory retirement for 

personnel in certain occupational categories. State’s FAM outlines the 

time-in-class and time-in-service limits for specific occupational 

categories.4

 2

According to the Procedural Precepts for the 2012 Foreign Service Selection Boards, the 

regulatory language in the procedural precepts is considered governing if it varies from 

that in the Foreign Affairs Manual or Foreign Affairs Handbook. 

3

AFSA serves as the exclusive bargaining agent for Foreign Service personnel. 

4

Department of State, Foreign Affairs Manual, 3 FAM 6213.3.
Page 4 GAO-13-654 Foreign Affairs Management

Various offices and entities play key roles in the Foreign Service 

promotion process. 

• HR, under the direction of the Director General, has authority over the 

Foreign Service promotion process.

• The Office of Performance Evaluation, within HR, manages the 

promotion process, including recommending selection board 

members and processing final promotion results and other selection 

board outcomes. The office also provides various types of assistance 

and services related to the promotion process, such as guidance to 

employees in preparing their evaluation materials and monitoring of 

selection board activities.

• Grievance staff, also within HR, process grievances relating to the 

Foreign Service promotion process or underlying performance 

information relied upon by the selection boards or performance 

standards boards.

• The Foreign Service Grievance Board provides an appeal mechanism 

for employees not satisfied with the outcome of grievances at the 

agency level. The board currently consists of 20 members. Each 

member, as well as the chairman, is appointed by the Secretary of 

State for a term of 2 years, subject to renewal.

• AFSA provides Foreign Service personnel guidance in preparing 

evaluation materials. In addition, AFSA attorneys provide assistance 

to staff who file a grievance with State or the Foreign Service 

Grievance Board.
Page 5 GAO-13-654 Foreign Affairs Management

State’s Foreign Service promotion process includes several types of 

boards that evaluate and rank order candidates for promotion, identify 

other candidates for possible separation from the Service, and address 

promotion process-related grievances. Foreign Service selection boards 

identify certain candidates for promotion, “low rank”5 others, and make 

other determinations. Performance standards boards then review lowranked candidates for possible separation from the Service.6 There are 

several mechanisms to resolve grievances relating to the promotion 

process, including through the convening of reconstituted boards.

State carries out several key steps prior to convening the Foreign Service 

selection boards. Selection boards then evaluate and rank order 

candidates for promotion. Next, HR officials process board outcomes 

before announcing promotions. Figure 1 provides information on key 

steps of the promotion process.

 5

The procedural precepts state that, with certain exceptions, selection boards are required 

to place 2 percent of assessed candidates in a given competition group in the low-rank 

category.

6

The procedural precepts state that employees low-ranked by two different selection 

boards during a 5-year period in which the officer was rated by at least two different 

supervisors are administratively referred to a performance standards board. Selection 

boards can also directly refer an individual to a performance standards board, regardless 

of whether that individual has been previously low ranked.

The Foreign Service 

Promotion Process 

Includes Several 

Boards That Evaluate 

Promotion Candidates 

Boards Evaluate Foreign 

Service Personnel for 

Promotion and Possible 

Separation

Selection Boards
Page 6 GAO-13-654 Foreign Affairs Management

Figure 1: Key Steps in Department of State’s Foreign Service Promotion Process

Key Steps before Convening Selection Boards

State carries out several key steps before convening selection boards.

• The Director General determines the number of available promotion 

opportunities, evaluating factors including vacancies, estimated 

attrition, and projected staffing needs.

• HR designates selection board members. After the Director General 

determines how many and what type of boards are needed, HR seeks 

to fill the boards by soliciting volunteers and recruiting members to 

meet specific needs in terms of rank or work experience. Each board 
Page 7 GAO-13-654 Foreign Affairs Management

typically has four to six members of the Foreign Service7 along with a 

public, or non-State, member.8 According to HR officials, public 

members can offer a different perspective than Foreign Service 

members, and can act as an additional safeguard over the integrity of 

the process. All selection board members must be approved by the 

Director General and cannot serve on a selection board for 2 

consecutive years. Selection boards include generalist and specialist 

boards.9

• HR office of performance evaluation staff present official performance 

folders for each candidate eligible for promotion. The Employee 

Evaluation Report (EER) is a key document used by selection boards 

to evaluate candidates, and includes sections on the candidate’s work 

requirements, performance, and areas for improvement. The EER is 

developed by the employee and the employee’s designated rating and 

reviewing officers, and is screened by a review panel that is to provide 

feedback on any technical mistakes that should be corrected before 

the EER is formally submitted to the office of performance evaluation. 

The folder also includes information on the employee’s training record 

and any commendations, official reprimands, or awards, among other 

information. Selection boards are to evaluate candidates based only 

Once board members are chosen, State announces them in 

a cable sent to posts worldwide, which includes instructions on the 

conditions under which promotion candidates can request certain 

board members be recused from reviewing their file. Board members 

can also recuse themselves from evaluating a candidate if they 

believe they may be unable to render a fair and unbiased judgment.

 7

According to the FAM, Foreign Service members of selection boards should, so far as 

possible, have a rank at least one class higher than that of the employees to be rated; 

have the depth and breadth of experience necessary to evaluate the employees 

designated for consideration by the boards; have a superior record of service; and have a 

reputation for unbiased judgment of personnel and for perceptive evaluation of 

performance. See 3 FAM 2326.1-2.

8

According to the FAM, public members of selection boards should, so far as possible, 

have gained prominence in a profession, in business, in labor, or in a nongovernmental 

organization or institution serviced by, or having an interest in the Foreign Service; have 

some overseas experience; be available to serve on a full-time basis during the entire time 

that the boards are in session; and not be employed in the federal service. See 3 FAM 

2326.1-2.

9

Foreign Service generalists serve in one of five career tracks: consular, economic, 

management, political, or public diplomacy. Foreign Service specialists provide technical, 

support, or administrative services in 19 career categories that include positions such as 

doctors, office management specialists, diplomatic security agents, and human resource 

specialists, among others.
Page 8 GAO-13-654 Foreign Affairs Management

on information in official performance folders, along with other 

employee records specified in the procedural precepts.

Selection Board Activities

Selection boards follow a series of steps to evaluate and rank order 

candidates for promotion and identify other candidates for possible 

separation from the Service.10 The boards first screen all candidate files, 

and sort them into one of three categories: promotion, mid-rank, or lowrank. Those candidates mid-ranked are generally not reviewed again for 

promotion by that board. Next, each board member ranks each 

promotable candidate using a forced distribution scale of 1-10. Any time 

there is a discrepancy between board members of at least four points in 

the ranking of a given candidate, the members must discuss the case 

and, if the discussion results in any changes, adjust rankings accordingly 

to comply with the forced distribution requirement. Each board has a 

chairperson responsible for leading such discussions and helping to 

ensure that board procedures are followed.11

• the rank-order list for each competition group of all candidates recommended for promotion;

Once all candidates have 

been considered and ranked by each board member, the board chair 

consolidates the scores for promotable candidates into one rank-order 

list. Once a final rank ordering is established, the board submits its final 

results as part of its official board report, which includes, among other 

elements:

• an alphabetical list of those mid-ranked;

• an alphabetical list of those low-ranked;

• an alphabetical list of any candidates referred directly to a 

performance standards board to be considered for possible 

separation; and

• recommendations concerning policies and procedures for subsequent 

boards and improvements to the performance evaluation system.

According to HR officials, the board report is the only document retained 

from each selection board. All other documents, such as notes and score 

 10Prior to the onset of board deliberations, HR trains members in selection board 

procedures and the roles and responsibilities of various parties involved in the process.

11In addition, each board has a designated advisor to facilitate operations and serve as an 

HR point of contact for board member questions or concerns.
Page 9 GAO-13-654 Foreign Affairs Management

sheets, are destroyed soon after the board’s dismissal. HR officials 

explained that these documents are destroyed to encourage open and 

frank discussions and note-taking during the board sessions.

Key Steps to Process Selection Board Decisions

After receiving the selection boards’ official reports, HR officials undertake 

several steps before announcing promotions. First, HR officials told us 

they draw a “cut-line” on selection boards’ ranked lists of candidates 

recommended for promotion based on the number of available promotion 

slots. Then, HR officials coordinate the vetting of candidates ranked 

above the cut line with several entities, including the Office of Inspector 

General, the Office of Civil Rights, the Office of Employee Relations, the 

Bureau of Diplomatic Security, and the Office of the Legal Adviser. These 

offices respond indicating whether there are any outstanding issues 

concerning individual candidates, such as a pending investigation or other 

matter, that could lead to their removal from the promotion list.12 In 

addition, in response to personnel changes, HR officials annotate the 

official board reports’ rank-ordered lists of candidates recommended for 

promotion, indicating which candidates have been permanently removed 

and lowering the cut line accordingly. Next, according to HR officials, 

several staff, including the director of HR’s Office of Performance 

Evaluation, review the revised list of candidates for promotion to ensure it 

accurately reflects changes due to vetting outcomes. State then publishes 

the list of promotions. Table 1 provides summary data for the 2011 and 

2012 selection boards.

 12Candidates can be temporarily removed for various reasons, such as due to an ongoing 

investigation, or permanently removed due to a change in personnel status, such as 

retirement or resignation. See 3 FAM 2327 and 3 FAM 2328.
Page 10 GAO-13-654 Foreign Affairs Management

Table 1: Summary Data for 2011 and 2012 Foreign Service Selection Boards

Year

Total number of 

boards

Total number 

of candidate 

files reviewed 

by boardsa

Total number 

of employees 

promoted

Total number 

of employees 

low- rankedb

2011 19 8195 1465 94

2012 22 8560 1481 107

Source: GAO analysis of State data.

a

The total number of candidate files reviewed includes some duplicates, as some candidates were 

reviewed by more than one board.

b

Number of low-ranked employees is a State-provided number as of June 2013 and not the result of 

GAO analysis.

Performance standards boards convene each year to assess low-ranked 

candidates for possible separation from the Foreign Service. According to 

HR officials, there are typically two performance standards boards 

convened each year—one for generalists and one for specialists. 

Performance standards boards are governed by a set of procedural 

precepts outlined in the FAM.13

Employees selected for separation from the Foreign Service have several 

remedial options. The Director General first sets a separation date. 

According to HR officials, employees can, until that date, choose to retire, 

if eligible; resign; grieve; or request a special review board, where the 

matter is adjudicated by a judge from outside the Department of State.

The boards review each employee’s file 

alongside no fewer than 10 randomly selected employee files from the 

same competition group and decide whether to recommend the employee 

for counseling or for separation. The board is required to submit a report 

to the Director General that includes a list of the members designated for 

separation along with individual statements justifying the board’s findings 

in each case. In 2011, 11 employees were designated for separation by 

performance standards boards. In 2012, 14 employees were designated 

for separation.

 13Each performance standards board should include at least three members who, to the 

fullest extent possible, are all career members of the Foreign Service, are knowledgeable 

about the occupational requirements of the categories of the members they review, and 

are at least one level above those individuals under review. See 3 FAM 6214.2.

Performance Standards Boards
Page 11 GAO-13-654 Foreign Affairs Management

Foreign Service personnel have several options to seek relief through the 

grievance process in response to promotion-related matters.14

Employees also have several options beyond the agency grievance staff. 

A member whose grievance is not resolved satisfactorily under the 

agency procedures described above can file an appeal with the Foreign 

Service Grievance Board no later than 60 days after receiving the agency 

decision. According to the director of the grievance staff, Foreign Service 

personnel can also file charges relating to prohibited personnel 

practices

Foreign 

Service personnel are encouraged to first attempt to resolve their 

concerns about their EERs with their supervisor at the post or bureau 

level. According to the director of State’s grievance staff, State does not 

track the number of grievances that are resolved between employees and 

supervisors at post or the bureau. Employees can also formally submit a 

grievance in writing to the agency grievance staff, providing information 

such as the nature of the grievance, its effect, which law or regulation the 

grievant believes was violated, and any relief requested. Grievance staff 

process these submissions and, according to the director of the grievance 

staff, will grant interim relief from separation at the agency level, if 

requested. According to the director of State’s grievance staff, grievances 

typically pertain to performance, discipline, or financial matters. 

Grievances relating to a low ranking typically pertain to the employee’s 

EER, or alleged errors in applying the applicable precepts. For example, 

in certain cases employees have alleged that their EERs contained 

falsely prejudicial information, or that selection boards misapplied the 

procedural precepts in arriving at a decision to low rank a candidate.

15 via the Office of Special Counsel at any point in the process.16

 14 In most cases, grievances must be filed within 2 years of the occurrence causing it. See 

3 FAM 4427.

15There are 13 prohibited personnel practices, such as discriminating against an 

employee or applicant based on race, color, religion, sex, national origin, age, 

handicapping condition, marital status, or political affiliation; or requesting or considering 

employment recommendations based on factors other than personal knowledge or 

records of job-related abilities or characteristics. These prohibited practices are defined 

and codified at 5 U.S.C. § 2302(b) .

16The U.S. Office of Special Counsel is an independent federal investigative and 

prosecutorial agency. Its primary mission is to safeguard the merit system by protecting 

federal employees and applicants from prohibited personnel practices.

Grievance Process Based 

on Multiple Adjudication 

and Resolution Options
Page 12 GAO-13-654 Foreign Affairs Management

Grievants may also appeal a decision of the Foreign Service Grievance 

Board by filing a complaint in federal district court.17

Reconstituted boards may be convened if HR officials or the Foreign 

Service Grievance Board determines a candidate was not properly 

reviewed or that the official performance folder contained incomplete or 

inaccurate documentation of performance.18 In 2012, State initiated 

reconstituted boards in response to 16 grievances. The members of a 

reconstituted board are to be chosen, to the extent possible, on the same 

basis as members of the original selection board, and, to the extent 

applicable, are to observe the precepts and procedures for the original 

board. Reconstituted boards review, in addition to the employee under 

consideration, the files of the four individuals immediately above the cut 

line for promotion as designated in the final board report for the 

competition group and the files of three individuals immediately below the 

cut line. The reconstituted board rank orders the files under review from 

one to eight. If the employee for whom the board was reconstituted is 

ranked by the reconstituted board among the top four files, he or she will 

be considered ranked for promotion.

Prompted by concerns identified by the OIG and Foreign Service 

Grievance Board in 2010,19

 17According to State, since January 2011, no State employee has filed a procedural 

complaint relating to State’s Foreign Service promotion process through the Office of 

Special Counsel, and one State employee has filed such a complaint through the District 

Courts.

State took a number of actions to strengthen 

procedures governing selection boards and reconstituted boards. For 

example, in response to concerns identified by the OIG, State revised 

procedures governing the improper introduction of information about 

candidates and recusal requests. State also updated standard operating 

procedures for reconstituted boards in response to concerns raised by the 

OIG and Foreign Service Grievance Board. In addition, State initiated two 

other practices to strengthen safeguards over the promotion process.

18Reconstituted boards are governed by a set of Standard Operating Procedures 

established by State in October 2011. 

19Foreign Service Grievance Board, Record of Proceeding, FSGB 2008-051 (July 14, 

2010). 

State Has Developed 

Procedural Changes 

to Address Identified 

Concerns with the 

Foreign Service 

Promotion Process
Page 13 GAO-13-654 Foreign Affairs Management

State developed a requirement that selection board members sign an 

oath in response to the OIG’s concerns about the improper introduction of

information about candidates during board deliberations. The OIG 

reported that it became aware of selection board members allegedly 

improperly removing documents from, or attempting to introduce 

information not already contained in, a candidate’s record. In response, 

State implemented a requirement that each board member sign an oath 

to protect the confidentiality of board materials and report any improper 

introduction of information about a candidate. The oath also addresses 

board members’ adherence to the procedural precepts and promotion 

criteria. A copy of each signed oath should be filed in the final board 

report.20

State revised its procedures governing candidate and board member 

recusal requests in response to OIG concerns about them. The OIG 

found the procedural precepts to be ambiguous regarding the allowable 

involvement by a selection board member who has voluntarily recused 

him- or herself from consideration of an individual candidate in other 

board deliberations, and also found the bases for recusal requests to be 

too limited. In response, State developed revised language covering 

selection board recusal requests, which was incorporated in the 2011 

procedural precepts. The revised language broadened the circumstances 

under which an individual under review may request a board member’s 

recusal. The revised precepts also describe the steps a board member 

should take to recuse him- or herself and make clear that, while this 

member will be excused from further consideration of the particular 

individual, the member will continue to participate in the other activities of 

the board.

 20The oath reads: “I, ______ _______ (print name), do solemnly swear (or affirm) that I 

will perform the duties of a member of a Selection Board faithfully and to the best of my 

abilities; that I will adhere to the Precepts; that I will apply the Precepts and promotion 

criteria without prejudice or partiality; that any introduction into board deliberations of 

nonrecord material will be reported to the director of the Office of Performance Evaluation, 

and that I will not reveal to unauthorized persons any information concerning the 

personnel records used or the deliberations and recommendations of the Board (so help 

me God).”

New Board Member Oath

Revised Recusal 

Procedures
Page 14 GAO-13-654 Foreign Affairs Management

State updated its procedures for reconstituted boards in response to OIG 

and Foreign Service Grievance Board concerns about the operations of 

these boards. The OIG reported there was no regulation in place 

establishing the conditions that cause a reconstituted board to be formed, 

its membership, purpose, or the outcome of its recommendations. In 

addition, the Foreign Service Grievance Board found serious deficiencies 

and irregularities in the operation of six reconstituted boards, including 

destruction of underlying board records; inability of board members to 

confirm that the results reported in the final reports accurately reflected 

the board’s decisions; evidence that the boards failed to incorporate the 

safeguards followed by regular selection boards; and lack of evidence 

that HR staff prepared board reports with sufficient attention to detail. In 

response, State negotiated and published updated standard operating 

procedures for reconstituted boards in October 2011. The updated 

procedures require documentation of steps associated with reconstituted 

boards. For example, the procedures call for HR to retain an official folder 

on each reconstituted board, which should include, among other items, 

documentation of the notification to employees of the names of board 

members; final board scoresheets that are signed or initialed by all board 

members; signed oaths;21 recusal forms, if applicable; and the final board 

report, signed by all members or their proxy.

State said it would place renewed emphasis on ensuring that all board 

members sign board results in response to an OIG concern regarding 

board result certification. The OIG reported that several former board 

members asserted that HR officials submitted to the Director General 

rank-ordered lists of candidates for promotion without those board 

members certifying the lists, or with results that differed from the 

members’ recollections. State responded that, while a certification 

requirement, by signature and initials, of board results was already in 

place prior to the OIG’s report, it would re-emphasize the need to ensure 

that this procedure is followed prior to remitting any board list to the 

Director General. An HR official noted that the use of proxy signatures for 

board members’ certification of results was considered acceptable, so 

long as signed by another board member and not by an HR official.

 21The language in the oath is the same as that for selection boards.

Updated Procedures for 

Reconstituted Boards

Renewed Emphasis on 

Certifying Board Results
Page 15 GAO-13-654 Foreign Affairs Management

State reported it discontinued annotating promotion lists in response to 

the OIG’s concern about this practice. The OIG reported that an existing 

practice of annotating candidate promotion lists—such as by computer, 

pen, or pencil—could be used to influence the board in favor of certain 

candidates, such as those who were nearly promoted in prior promotion 

cycles. According to HR officials, some HR staff had previously annotated 

promotion lists by noting employees who had the previous year received 

Meritorious Service Increases, which are given to some employees rankordered by selection boards but not promoted due to limited number of 

promotion opportunities. State reported that it ended this practice.

State said it would try to increase the number of nonspecialists on 

specialist boards—which evaluate Foreign Service personnel who provide 

technical, support, or administrative services—in response to the OIG’s 

concern about these boards’ composition. The OIG reported that, since 

specialist board members are drawn from a smaller universe than 

generalist boards, there is a greater possibility these members will 

personally or by reputation know the candidates being reviewed. State 

responded that it endorsed the OIG’s recommendation to include at least 

two nonspecialists on each specialist board. However, State noted that 

while it would seek to do so in the future, it needed to retain some 

flexibility to make exceptions in cases where two nonspecialists were not 

available.

The OIG reported there was no consolidated procedural manual for 

training new HR employees. State developed such a manual and 

distributed copies to staff. The manual includes information on 

procedures relating to the promotion process.

In addition to State’s actions taken in response to others’ identified 

concerns about the promotion process, we found that State initiated two 

additional documentation practices to strengthen promotion process 

safeguards. The first is to have selection board members, in addition to 

signing final board results, initial each page of the promotable, mid-rank, 

and low-rank lists in official board reports, thereby attesting to the 

accurate rank order of all candidates the selection board evaluated. The 

second is to include selection board and reconstituted board member 

recusal memos in each final board report.

Discontinued Annotation 

of Promotion Lists

More Nonspecialists 

to Serve on Specialists 

Boards

New Procedural 

Manual for HR Staff

Additional StateInitiated Practices to 

Strengthen Promotion 

Process Safeguards
Page 16 GAO-13-654 Foreign Affairs Management

We found that selection boards, performance standards boards, and 

reconstituted boards complied with many updated procedures in the 2011 

and 2012 Foreign Service promotion cycles; however, some selection 

boards and reconstituted boards had documentation gaps for certain 

internal controls.22 Our review of board files, related grievances filed since 

October 2011, and responses to an online data collection tool sent to 

2011 and 2012 board members revealed limited concerns about the 

operations of some boards.

Our review of 77 selection boards, performance standards boards, and 

reconstituted boards for the 2011 and 2012 promotion cycles found that 

board members and HR staff complied with many updated internal 

controls. For example, all 41 selection board reports we reviewed 

included a memo certifying final results signed by board members or by 

proxy, and documentation indicating that a public member served on the 

board. In addition, all 32 reconstituted board reports we reviewed 

included a statement describing the board’s purpose, a notification to the 

employee of the board’s composition, documentation indicating a public 

member served on the board, final board score sheets, and a final board 

report signed by all members or by proxy.

However, we found that some board reports, which constitute the master 

record of proceedings, had a number of documentation gaps. As shown 

in figure 2, there were several instances of missing oaths and incomplete 

documentation of recusals among the 41 selection boards we reviewed. 

For example, we found that 2012 selection board reports did not include 

45 of 122 required signed oaths from members, or nearly 40 percent of 

the required total. Subsequent to our file review, State officials provided a 

portion of these missing oaths and other missing documents from 

ancillary records.

 22We reviewed all selection and performance standards boards from the 2011 and 2012 

promotion cycles, and all reconstituted boards held after October 2011, when State issued 

new standard operating procedures for these boards, through April 2013. In this report, we 

refer to all three types of boards as part of the 2011 and 2012 promotion cycles. 

State Complied 

with Many Updated 

Procedures in 2011 

and 2012, but Some 

Documentation Gaps 

Existed

Selection Boards and 

Reconstituted Boards Had 

Some Documentation 

Gaps
Page 17 GAO-13-654 Foreign Affairs Management

Figure 2: 2011 and 2012 Selection Board Compliance with Internal Controls

a

The current director of HR’s office of performance evaluation noted that proxy signatures by other 

board members are acceptable. All discussions of “proxy signatures” in this report refer to signatures 

by one board member on behalf of another board member. 

We also checked for discrepancies between boards’ rank-ordered 

promotion lists and official promotion announcements and found a total of 

74 names recommended for promotion in 2011 and 2012 selection board 

reports that did not appear on corresponding promotion announcements. 

State officials explained that these individuals were not included on 

promotion lists due to requirements outlined in the FAM relating to the (1) 

permanent removal of names from promotion lists due to personnel 

actions such as retirement, and (2) temporary removal of names from 
Page 18 GAO-13-654 Foreign Affairs Management

promotion lists due to outcomes of the vetting process described earlier. 

State provided documentation to account for each removed name.

Compliance with procedures was better, but still not complete, for 

performance standards boards and reconstituted boards. For example, 

some reconstituted boards lacked final board score sheets that were 

signed or initialed by all members, and some lacked signed oaths from all 

board members. Compliance for performance standards boards and 

reconstituted boards is shown in figures 3 and 4.

Figure 3: 2011 and 2012 Performance Standards Board Compliance with Internal 

Controls
Page 19 GAO-13-654 Foreign Affairs Management

Figure 4: Reconstituted Board Compliance with Internal Controls from October 2011 to April 2013
Page 20 GAO-13-654 Foreign Affairs Management

Our review of board files, related grievances, and responses to an online 

data collection tool sent to board members revealed limited concerns 

about the operations of some boards. Our review of selection boards’

observations about and recommendations for improving the promotion 

process revealed no concerns relating to the boards’ ability to adhere to 

core and procedural precepts. Our grievance file review revealed one 

allegation of bias concerning a board member, which was not sustained. 

Our online tool revealed a limited number of procedural concerns 

pertaining to a few specific boards.

The Director General requests that all selection boards provide 

observations about the promotion process and recommendations for 

improving it. Our review of the 41 selection boards’ observations and 

recommendations revealed no reported concerns relating to the boards’

ability to adhere to the core precepts and procedural precepts. However, 

we found that a number of boards provided observations and 

recommendations for improving the promotion process in several areas. 

For example, more than half of the 41 boards made observations and 

recommendations concerning the following:

• completeness, accuracy, or accessibility of the official performance 

folder;

• promotion criteria, policies, or related practices; and

• technological issues affecting board operations.

In addition, more than a third of the 41 boards made observations and 

recommendations concerning the following:

• uncertainty over how to interpret some performance appraisal 

information; and

• sufficiency or quality of promotion process guidance and training.

State’s HR staff review and respond to board-identified issues each year 

and discuss proposed solutions with the Director General. In both 2011 

and 2012, State issued worldwide cables with additional guidance to 

employees, raters, and review panel members to address key boardidentified issues. For example, with regard to observations and 

recommendations about promotion criteria, policies, and related 

practices, the guidance stressed that candidates (and raters) need to 

demonstrate the extent of work experience within their “cone” and 

whether they are serving in “stretch” positions above their current grade 

level. In addition, in response to board feedback, State has developed a 

process, which was implemented in 2013, whereby employees can selfLimited Concerns with 

Promotion Process Noted

Selection Board Reports
Page 21 GAO-13-654 Foreign Affairs Management

certify the accuracy of their eligibility for review and related performance 

information.

We reviewed all grievances related to 2011 and 2012 board actions and 

found that, with one exception, none alleged that any board or board 

member violated core integrity and fairness precepts such as the 

intentional introduction of extraneous material into the proceedings or 

overt bias toward an individual. The one exception was a case in which 

an employee alleged that a board member held a personal bias toward 

him and should have recused himself from considering the individual’s 

file. According to State officials, this grievance was denied at the agency 

level in April 2013. Grievances generally focused on a complaint that a 

board misapplied a given precept in arriving at a low-ranking decision. For 

example, some grievants alleged that a board relied on comments made 

in the Area for Improvement section of the EER to support a low-ranking

determination without corroborating evidence of poor performance 

elsewhere in the EER, as is required by the procedural precepts. We 

noted that HR officials often agreed with the grievant in low-ranking 

complaints and provided the requested relief of expunging the lowranking statement from the employee’s performance folder, along with 

related modifications to their “scorecard.” 

Our online data collection tool revealed a limited number of procedural 

concerns relating to the operations of three specific boards. Our online 

tool was designed to provide board members with an opportunity to 

identify whether they observed any actions, behaviors, or concerns that 

could have compromised their board’s integrity and fairness. Our online 

tool was sent to 293 of 298 members who served on the 2011 and 2012 

selection boards, 2011 and 2012 performance standards boards, and 

reconstituted boards since October 2011.23 We received 206 completed 

forms.24 From this total, two responses identified a total of four concerns 

with the operation of a board in 2011 or 2012. One response claimed that 

a board member had refused to follow precept instructions to consider 

candidate service in Afghanistan, Iraq, and Pakistan in a favorable light.25

 23We were unable to obtain contact information for five members. 

24We could not determine whether we received responses from 206 separate individuals 

because some board members responded anonymously. For more information, see 

appendix I.

25According to State, due to the scoring system, it is not possible for any single member of 

a board to make or block any board decision.

Grievance File Reviews

Online Data Collection Results
Page 22 GAO-13-654 Foreign Affairs Management

The same response noted that the board did not follow proper recusal 

procedures in all cases. The second response claimed that an “HR 

official” had inappropriately instructed a board member. The same 

response noted that the board did not follow proper recusal procedures in 

all cases. We obtained permission from one respondent to provide the 

respondent’s two concerns to State’s HR staff and the OIG for further 

review and follow-up as appropriate.

State’s Foreign Service promotion process is conducted within the 

context of an up-or-out system and the practice of identifying a set 

percentage of staff each year for possible separation from the Service. 

Within an organizational culture that emphasizes performance and career 

advancement, safeguards to ensure the fairness and integrity of the 

promotion process are of particular importance. While we found that State 

had responded to previously identified concerns about its Foreign Service 

promotion process and taken a number of actions to strengthen internal 

controls over the process, documentation supporting the full 

implementation of these controls was sometimes missing. For example, 

we found that many selection board member oaths were missing from 

2012 selection board reports and some boards did not include 

documentation of recusal requests. In the absence of a fully documented 

system of controls, there is a risk that intentional or unintentional failures 

to implement safeguards, by board members or HR staff, will go 

undetected and uncorrected. A failure to implement safeguards, in turn, 

increases the risk that promotion results could be intentionally or 

inadvertently compromised.

To improve and better document State’s compliance with key safeguards 

governing the Foreign Service promotion process, we recommend that 

the Secretary of State instruct the Director General of the Foreign Service 

and Director of the Human Resources Office of Performance Evaluation 

to take steps to ensure that selection board, performance standards 

board, and reconstituted board reports are complete and fully document 

compliance with internal controls, including but not limited to signed oaths 

and recusal memos.

Conclusions

Recommendation for 

Executive Action
Page 23 GAO-13-654 Foreign Affairs Management

We provided a draft of this report to State for its review and comment. 

State provided written comments, which are reprinted in appendix II. 

State concurred with our recommendation to ensure board reports are 

complete and fully documented. In particular, State noted that, during the 

course of our review, it examined areas we had brought to the 

department’s attention, and made adjustments in procedures for filing 

signed oaths, recusal memos, and board reports. State added that it 

would continue to improve record-keeping in this regard. State also 

provided technical comments, which we have incorporated throughout 

this report as appropriate.

We are sending copies of this report to the appropriate congressional 

committees and the Secretary of State. In addition, the report is available 

at no charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-8980 or courtsm@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. GAO staff who made major contributions to this report 

are listed in appendix III.

Michael J. Courts

Director, International Affairs and Trade

Agency Comments 

and Our Evaluation
Appendix I: Objectives, Scope, and 

Methodology

Page 24 GAO-13-654 Foreign Affairs Management

This report examines (1) the Department of State’s (State) process for 

ranking and promoting Foreign Service personnel, (2) procedural 

changes State has made to its Foreign Service promotion process in 

response to identified concerns, and (3) the extent to which updated 

procedures were consistently followed in 2011 and 2012 and whether any 

notable concerns about the promotion process remain.

To review State’s process for ranking and promoting Foreign Service 

personnel, we reviewed relevant laws, regulations, and procedures 

governing State’s promotion and grievance processes, including the 

Foreign Service Act of 1980, the Foreign Affairs Manual, the Procedural 

Precepts and Core Precepts for the 2012 Foreign Service Selection 

Boards, and the training and information materials provided to 2012 

selection board members. To understand how these procedures are 

implemented in practice, we interviewed State officials within the Bureau 

of Human Resources (HR), including officials from the offices of 

performance evaluation and grievances. We also interviewed the 

president and several other officials from the American Foreign Service 

Association (AFSA), the exclusive bargaining agent for Foreign Service 

personnel, to understand AFSA’s role in the promotion process. We 

interviewed four public, or non-State, members of selection boards, which 

evaluate and rank order candidates for promotion. We reviewed State 

data on the 2011 and 2012 Foreign Service promotion cycles, and the 

number, resolution, and status of grievances filed by candidates who 

were “low ranked” by selection boards in 2011 and 2012. We discussed 

with State officials how these promotion process and grievance-related 

data were collected and checked for accuracy. State HR officials told us 

the promotion data were compiled by HR’s Office of Resource 

Management and Organizational Analysis. According to HR officials, HR 

staff members manually enter these data into a system referred to as the 

Board Maintenance Application. HR Office of Resource Management and 

Organizational Analysis staff members work with HR performance 

evaluation staff to verify the number of promotions, as well as the 

rankings of those promoted, and the number of those recommended for 

promotion but not promoted. These results are published annually, every 

spring. For grievance data, the director of State’s grievance staff told us 

grievance staff obtained the names of every person low ranked or 

referred to a performance standards board in 2011 and 2012 from HR 

performance evaluation staff, then cross-checked those names against 

the names of individuals who had filed grievances. Grievance staff then 

manually searched the grievance files to determine whether the 

individuals’ grievances involved low rankings, by year. We determined 

these data were sufficiently reliable for our purposes.

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 25 GAO-13-654 Foreign Affairs Management

To review the procedural changes State has made to its Foreign Service 

promotion process in response to identified concerns, we focused on 

concerns identified since March 2010, when the State Office of Inspector 

General (OIG) issued its Report of Inspection, “Review of the Integrity 

and Fairness of the Foreign Service Selection Board Process.” We also 

focused on State procedural changes made since March 2010. In addition 

to the OIG’s report, we reviewed the record of proceedings for the 

Foreign Service Grievance Board’s case 2008-051 from July 2010, which 

addressed concerns with State’s procedures governing reconstituted 

boards, which are convened if it is determined a promotion candidate was 

not properly reviewed. We also reviewed Foreign Service personnel 

grievance cases related to the promotion process, from 2011 through 

February 2013. In particular, we reviewed those cases the grievance 

office had categorized as one of the following grievance types: promotion, 

low-ranking, performance standards boards (which review low-ranked 

candidates for possible separation), or separation. We selected these 

categories after reviewing a spreadsheet State provided that listed all filed 

grievances by category, as we determined they were most applicable to 

our review of the promotion process, compared with other categories 

such as discipline, financial, and leave restoration. We also reviewed all 

Foreign Service Grievance Board filings related to the same universe of 

filed grievance cases. In addition, we reviewed selection board 

recommendations to the Director General from the 2011 and 2012 

promotion cycles, which we discuss further below. We also reviewed 

responses to our online data collection tool, discussed below, that was 

sent to 2011 and 2012 selection board, performance standards board, 

and reconstituted board members. To learn about State’s procedural 

changes developed in response to the OIG’s recommendations, we 

reviewed State and OIG documents showing actions taken by State to 

comply with the OIG’s recommendations. We also interviewed State HR 

officials and officials from the OIG. To examine State actions taken in 

response to selection board member recommendations to the Director 

General, we reviewed HR summary memos and cables explaining 

suggested actions, and interviewed HR officials to discuss the status of 

these actions. We further discuss these actions in our report’s third 

objective.

To review the extent to which updated procedures were consistently 

followed in 2011 and 2012, and whether any notable concerns about the 

process remain, we reviewed selection board and performance standards 

board records for 2011 and 2012 and reconstituted board records from 

October 2011 through April 2013. According to State officials, the official 

reports, referred to as board reports, from these boards are the only 
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-13-654 Foreign Affairs Management

records retained; the remaining records are destroyed as a standard 

practice. We reviewed the three types of board reports within the 

following timeframes:

• All 41 selection boards reports from 2011 and 2012, the 2 years 

subsequent to the Inspector General’s report, to enable us to assess 

the extent to which State had implemented and consistently followed 

changes made subsequent to that report. To ensure we reviewed the 

accurate universe of selection board reports, we compared the list of 

board reports provided against State cables announcing the results of 

the promotion process for 2011 and 2012, which also identified all 

boards convened in 2011 and 2012. This comparison identified no 

discrepancies.

• All four performance standards board reports from 2011 and 2012. 

There were two performance standards board reports each year for 

2011 and 2012, contained within a single folder for each year. We 

received both reports for each year.

• All 32 board reports for reconstituted boards—convened in response 

to grievances pertaining to selection board promotion or low-ranking 

determinations, and convened after October 2011, when State issued 

new Standard Operating Procedures for these boards, through April 

2013. To ensure we reviewed the accurate universe of reconstituted 

board files within this timeframe, we compared the files provided by 

State against an inventory list provided by State; identified several 

discrepancies and resolved them with HR officials; and presented a 

master list of reconstituted boards to State officials, who confirmed the 

list reflected all reconstituted boards relating to promotions within our 

requested timeframe. Near the conclusion of our engagement, we 

reviewed those reconstituted boards that had taken place following 

our initial file review.

To help conduct our review of the three types of boards, we developed a 

data collection instrument with data categories reflecting the information 

required and routinely captured in each type of report. To determine the 

data included in these reports, we reviewed applicable precepts and 

standard operating procedures outlining required information, reviewed a 

sample of the board reports, and discussed the reports with HR officials. 

The analysts discussed the data categories with two research 

methodologists and a senior manager and reached agreement on them 

before coding the reports. For all reports, two analysts reviewed each 

report jointly. Another independent party reviewed the results of this 

process after the fact.
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-13-654 Foreign Affairs Management

To summarize and organize the selection boards’ written 

recommendations or observations to the Director General, two analysts 

read and entered this information into the data collection instrument. In 41 

selection board reports, the team identified 306 separate 

recommendations or observations. To analyze this written information, 

the two analysts developed a set of summary statements and higher-level 

categories to be used for reporting purposes. The summary statements 

provided a detailed explanation of the nature of the board 

recommendations or observations, including examples to illustrate what 

types of recommendations or observations would be coded under these 

statements. The higher-level categories served as abbreviated headings 

or titles of these more detailed statements. These statements and 

categories were based on an inductive exercise involving an in-depth 

reading and comparison of the board recommendations. The two analysts 

then tested these statements on an initial set of five board reports, by 

coding the text in them jointly. The statements and categories were 

developed iteratively, with modifications made as appropriate. The text 

was coded “yes” or “no.” If a segment of text was coded as “yes,” it 

indicated that the particular board had made one or more 

recommendation that fell into this category. If a recommendation 

addressed more than one of our categories, we coded it into all applicable 

categories. The analysts coded the remainder of the reports 

independently. Once concluded, the analysts met to discuss codes and 

reconcile disagreements as needed. The two analysts were able to 

reconcile all disagreements. A third party reviewer reviewed the team’s 

work and provided several suggestions, informed by discussions with 

team members, on revisions to some of the categories to more clearly 

capture how the team defined and interpreted them. Final tallies of the 

analysis were obtained by counting, for each statement, the number of 

“yes” and “no” responses and reflecting the number of times a category of 

recommendation occurred in the 41 reports.

To determine whether State was following its procedures for promoting 

candidates recommended for promotion by selection boards, we 

reconciled selection board report lists of rank-ordered candidates for 

promotion against State official promotion announcements. We first 

identified discrepancies between the two lists by reviewing selection 

board rank-ordered promotion lists against the State promotion 

announcements. We provided a copy of our list of discrepancies to HR 

officials, who provided lists explaining the reasons why certain candidates 

were removed from promotion lists. Through this process, State 

accounted for all missing names. To corroborate State’s explanation of 

why names were removed from promotion lists, we requested 
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-13-654 Foreign Affairs Management

documentation from State attesting to the reasons given for these 

removals for a selected number of these individuals. State provided us 

with this documentation, and therefore fully accounted for all 

discrepancies between selection board report lists of rank-ordered 

candidates for promotion against State official promotion announcements.

Similarly, we took steps to compare recusals we found documented in 

selection board reports against State’s master list of recusal requests. We 

cross-referenced State’s master list of recusal requests against the 

recusals documented in board reports. Through this process, we 

identified discrepancies, namely that four board reports had recusal 

information that was not reflected in State’s master list and that nine 

recusal requests included in State’s master list were not documented in 

the board reports. We discussed and provided specific information on 

these discrepancies with State officials. State subsequently presented 

copies of the nine recusal requests that were not initially documented in 

selection board reports.

To supplement our promotion process file review, we distributed an online 

tool to allow selection board, performance standards board, and 

reconstituted board members an opportunity to anonymously comment on 

any actions, behaviors, or other concerns relating to the board on which 

they served that they believed could have compromised the board’s 

integrity and fairness. The online tool’s intended use was to gather any 

information received from selection board members, and, to the extent 

possible, follow up on any concerns or allegations; it was not intended to 

present frequencies or tabulations based on the responses we received, 

or to report comprehensively on the attitudes of board members on the 

promotion process. We determined this type of online tool was 

appropriate for this case because of the prior allegations of improper 

behavior related to the process. Before distributing the online tool, we 

shared it with three selection board members and incorporated their 

comments, as appropriate. We also shared the online tool with State and 

AFSA. We received comments from both State and AFSA; incorporated 

some of their suggestions, as appropriate; and explained, where 

applicable, why we did not incorporate certain other suggestions. We 

requested that State provide us with email addresses for board members 

from the following board types and within the following timeframes: 

selection boards in 2011 and 2012, performance standards boards in 

2011 and 2012, and reconstituted boards from October 2011 to February 

2013, as we distributed the online tool in March 2013. State provided 

email addresses for all but several of these names; we obtained some of 

the missing email addresses through our own research and others from 
Appendix I: Objectives, Scope, and 

Methodology

Page 29 GAO-13-654 Foreign Affairs Management

AFSA. Through our own cross-referencing of State-provided lists of board 

members against our lists of boards and board members, we discovered 

that certain board member email addresses were missing. We requested 

that State provide email addresses for these names. Overall, we identified 

a universe of 298 individuals who served on the three types of boards 

within our specified timeframes. We were unable to contact five of these 

members for various reasons, including one retired board member for 

whom State had no email address, and several others due to missing or 

invalid e-mail addresses.

We sent an e-mail with a link to the online tool to 293 board members on 

March 11, 2013. Responses were accepted through April 7, 2013. We 

received 206 completed forms. We cannot report a response rate as it is 

possible that respondents submitted multiple forms or individuals 

responded who were not board members in 2011 or 2012. Board 

members could respond anonymously, and some respondents did not 

provide contact information. We reviewed written responses to identify 

any obvious or apparent duplicate or multiple entries, and identified one 

such entry. We reviewed all 206 completed forms and identified four 

responses indicating a concern or problem with the operation of a 

particular board. Two of these four responses constituted the one 

apparent duplicate entry, and pertained to a selection board convened in 

2009, which is outside the scope of this engagement. We nonetheless 

provided this concern to State’s HR staff and the OIG for further review 

and follow-up as appropriate. The remaining two responses, each of 

which identified two separate concerns, fell within our engagement’s 

scope and are discussed in the body of the report. We obtained 

permission from one respondent to provide the respondent’s two 

concerns to State’s HR staff and the OIG for further review and follow-up 

as appropriate. 

We conducted this performance audit from July 2012 to July 2013 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

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

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from 

the Department of State

Page 30 GAO-13-654 Foreign Affairs Management

Appendix II: Comments from 

the Department of State

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix.
Appendix II: Comments from 

the Department of State

Page 31 GAO-13-654 Foreign Affairs Management

See Comment 1.
Appendix II: Comments from 

the Department of State

Page 32 GAO-13-654 Foreign Affairs Management

The following is GAO’s comment on the letter from the Department of 

State 

1. This statement is incorrect. Although Figure 4 did note that State was 

able to locate some of the missing documentation in ancillary files, it 

did not note that this was due to the need to compartmentalize 

sensitive information.

GAO Comment
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-13-654 Foreign Affairs Management

Michael J. Courts, (202) 512-8980 or courtsm@gao.gov

In addition to the contact named above, Timothy J. DiNapoli (Director), 

Anthony Moran (Assistant Director), Joe Carney, Martin De Alteriis, Karen 

Deans, Etana Finkler, Ernie Jackson, Jill Lacey, Mike ten Kate, and 

Ramon Rodriguez made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(320930)
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