Farm Credit Administration

Office of Inspector General

Inspection Report 

The Identification and Mitigation 

Efforts for Key Position and 

Personnel Dependencies at the 

Farm Credit Administration

I-23-03 

February 20, 2024
1501 Farm Credit Drive, McLean, VA 22102 703-883-4030 www.fca.gov/about/inspector-general

February 20, 2024 

The Honorable Vincent G. Logan, Board Chairman and Chief Executive Officer 

The Honorable Jeffery S. Hall, Board Member 

The Honorable Glen R. Smith, Board Member 

Farm Credit Administration 

1501 Farm Credit Drive 

McLean, Virginia 22102-5090 

Dear Chairman Logan and Board Members Hall and Smith: 

The Office of Inspector General (OIG) completed an inspection, The Identification and Mitigation Efforts 

for Key Position and Personnel Dependencies at the Farm Credit Administration (FCA). The objective of 

this inspection was to analyze FCA’s efforts to identify dependencies in key positions and personnel 

and mitigate the risks associated with those dependencies. We found that all FCA offices identified key 

position and personnel dependencies in some way, and some offices documented their efforts in 

succession plans or lines of responsibility. 

However, the OIG found inconsistencies in how the Agency and FCA offices identified, 

documented, and mitigated the risk of key position and personnel dependencies. Specifically, the 

Agency has opportunities to promote knowledge transfer and improve employee development 

by providing and updating Agency-wide guidance. Finally, the OIG found that while FCA offices 

generally had a structure and grade distribution that mitigated key position and personnel 

dependencies, there are opportunities for improvement. 

The OIG made five recommendations to improve FCA’s process for succession planning and the 

identification and mitigation of key position and personnel dependencies. The recommendations 

focus on developing guidance for the identification of key position and personnel dependencies, 

leadership and executive development training, and analyzing how offices can improve their 

mitigation efforts and promote consistency in the Agency. FCA management agreed with, and 

provided responsive corrective actions for, all recommendations made in the report. 

We appreciate the courtesies and professionalism extended by FCA, especially the Office of Agency 

Services and the Chief of Staff, to our staff during the inspection. If you have any questions, we would 

be pleased to meet with you at your convenience. 

Respectfully, 

Sonya K. Cerne 

Assistant Inspector General for Audits, Inspections, and Evaluations 
EXECUTIVE SUMMARY

The Identification and Mitigation Efforts for Key Position and 

Personnel Dependencies at the Farm Credit Administration 

Report No. I-23-03 February 20, 2024

Objective 

The objective of this inspection was 

to analyze the Agency’s efforts to 

identify dependencies in key 

positions and personnel and mitigate 

the risks associated with those 

dependencies.

Recommendations

The Office of Inspector General made 

five recommendations to improve 

FCA’s process for succession 

planning and the identification and 

mitigation of key position and 

personnel dependencies. The 

recommendations focused on 

developing guidance for the 

identification of key position and 

personnel dependencies, leadership 

and executive development training, 

and analyzing how offices can 

improve their mitigation efforts and 

promote consistency in the Agency.

Agency Response

Management agreed with and 

provided responsive corrective 

actions for all recommendations 

made in the report.

Why We Did This Inspection

The Farm Credit Administration (FCA or Agency) is an independent 

federal agency responsible for regulating and supervising the Farm 

Credit System (System). With a significant portion of its staff eligible to 

retire in the coming years, succession planning is one of the highest 

risks facing the Agency. We conducted this inspection to ensure FCA’s 

process for the identification and mitigation efforts for key position and 

personnel dependencies was implemented in an effective and efficient 

manner.

How We Did This Inspection

We reviewed Agency positions and personnel by office. We reviewed 

and analyzed Agency data by grade level and office to determine 

impacts of retirement eligibilities through December 31, 2023, and then 

by December 31, 2030. We also reviewed office succession planning 

materials and identifications of key position and personnel 

dependencies, where applicable. We analyzed the techniques used by 

each FCA office to mitigate the risks associated with key position and 

personnel dependencies. The OIG analyzed employee job series, 

positions, and leadership and compared the results with office functions 

and staffing levels. 

What We Found

The OIG found that all FCA offices identified key position and personnel 

dependencies, and some offices documented their efforts in succession 

plans or lines of responsibility. However, while each office identified key 

positions and personnel, there was a lack of consistency in the positions 

and personnel identified and documentation of dependencies. 

Additionally, the OIG found a wide variance in how the Agency and FCA 

offices individually mitigated the risk of key position and personnel 

dependencies. Specifically, the Agency has opportunities to promote 

knowledge transfer and improve employee development by providing 

and updating Agency-wide guidance. Finally, the OIG found that while 

FCA offices generally had a structure and grade distribution that 

mitigated key position and personnel dependencies, there are 

opportunities for improvement. 
TABLE OF CONTENTS

Background.................................................................................................................................... 1

Farm Credit Administration .................................................................................................................................... 1

Emphasis on Personnel and Succession Planning Risks .............................................................................. 1

Strategic Planning.................................................................................................................................................. 1

Enterprise Risk Management ............................................................................................................................ 2

Strategic Human Capital Management Plan ............................................................................................... 2

Guidance on Succession Planning ....................................................................................................................... 3

Standards for Internal Control .......................................................................................................................... 4

Human Capital Framework................................................................................................................................. 4

Continuity of Operations .................................................................................................................................... 5

Prior OIG Reports........................................................................................................................................................ 5

Objective, Scope, and Methodology ........................................................................................... 6

Objective........................................................................................................................................................................ 6

Scope............................................................................................................................................................................... 6

Methodology................................................................................................................................................................ 6

Inspection Results ......................................................................................................................... 8

Agency Risk................................................................................................................................................................... 8

High Risk Examples ............................................................................................................................................ 11

Process to Identify Key Position and Personnel Dependencies............................................................. 11

Succession Planning .......................................................................................................................................... 12

Mitigation Efforts for Dependencies ................................................................................................................ 12

Skills and Abilities Identification ................................................................................................................... 13

Knowledge Transfer and Employee Development................................................................................. 13

Office Structure.................................................................................................................................................... 16

Root Causes ............................................................................................................................................................... 17

Control Structure ................................................................................................................................................ 17

Cost and Availability of Training Opportunities...................................................................................... 18

COVID-19 Pandemic.......................................................................................................................................... 18

Impact.......................................................................................................................................................................... 19

Recommendations .................................................................................................................................................. 19
FCA Response ........................................................................................................................................................... 20

OIG Response............................................................................................................................................................ 20

Management Comments ............................................................................................................ 21

Acronyms ..................................................................................................................................... 23
1 

BACKGROUND

Farm Credit Administration 

The Farm Credit Administration (FCA or Agency) is an independent federal agency responsible for 

regulating and supervising the Farm Credit System (System). The Agency is responsible for 

ensuring that all System institutions are safe, sound, and dependable sources of credit and related 

services for all creditworthy and eligible persons in agriculture and rural America. In order to 

achieve this mission, FCA needs a reliable, trained staff to perform mission-related and support 

activities for the Agency. 

FCA is facing a substantial risk relating to human capital due to the significant portion of the 

workforce’s retirement eligibility. Due to this risk, part of effective management is identifying risks 

relating to key positions and personnel and appropriately addressing the risks associated with 

potential dependencies and succession planning needs. 

FCA’s Office of Agency Services (OAS) manages and delivers human capital, operational, and 

workforce development services for the Agency; however, every office and office director have a 

responsibility to ensure that their respective offices remain operationally efficient and effective. 

Emphasis on Personnel and Succession Planning Risks

Strategic Planning 

In its Strategic Plan for Fiscal Years (FYs) 2022-2026, FCA reinforces its commitment to human 

capital management. Specifically, in addition to other mission-related goals and objectives, FCA 

aligns efforts through Stewardship Objective 1: Ensure a well-trained, engaged, and diverse staff 

working effectively in a safe, efficient, and modern workplace. FCA also noted in the Strategic Plan 

that the Agency will strengthen its human capital initiatives that support succession management, 

employee development, and organizational effectiveness. 

FCA defined key person dependencies in its Strategic Human Capital Plan for FY 2014-2018; 

however, it is unclear whether this definition is still applicable as it is not in the current Strategic 

Human Capital Management Plan for FY 2020-2024. The Strategic Human Capital Plan for FY 

2014-2018 states the following: 

“Key personnel are employees who are critical to the success of the Agency. If key 

personnel have roles that are not easily filled and bench strength is insufficient to fill 

these roles, then a KPD [key person dependency] exists, and business continuity and the 

successful accomplishment of the Agency’s mission may be at risk. KPDs typically exist 

where employees possess unique leadership or subject-matter expertise that is not easily 

transferable, make decisions that directly affect the success of the Agency, and may 

possess significant tenure and institutional memory. KPDs are usually associated with 

mission-critical positions, but they may also involve positions that provide essential 

specialized support.”
2 

Enterprise Risk Management 

FCA also addressed succession planning and the risks facing the Agency through its Enterprise 

Risk Management program. FCA outlines the top risks facing the Agency and identifies each risk, 

primary office with responsibility for the risk, scores, and whether a risk is increasing. The Agency 

designated three areas as high risk, with one noted as succession planning. The detailed 

succession planning risk contains the following description, “Key business functions could be 

negatively affected if there is no strategy for employee transition and knowledge transfer. If key 

leadership and technical positions do not have sufficient bench strength, knowledge transfer or 

access to talent pools, FCA will not be able to fulfill its mission effectively. In addition, retention 

and recruitment in a tight labor market also impacts the Agency's succession management 

efforts.” The following are noted as mitigation strategies to the risk:

• Assess FCA workforce to identify most vulnerable risk areas; 

• Develop an Enterprise Succession Plan that outlines strategies and actions to improve 

succession that may include, but is not limited to, knowledge sharing, transition plans, 

leadership profiles, targeted training and hiring, or early retirement incentives; 

• Continue to develop current employees to ensure their readiness to assume leadership 

roles as they become available; 

• Continue to offer internal mobility opportunities through our expressions of interest 

process; 

• As it relates to recruitment and retention, continue to research, develop and implement 

enhanced benefits which are proven to be effective in meeting the needs of our 

employees, as well as match the needs of potential employees (candidates); and

• Continue to leverage results from the recruitment & retention workgroup.

Strategic Human Capital Management Plan

FCA has also emphasized the human capital risk facing the Agency in its development of a

Strategic Human Capital Management Plan for FY 2020-2024. The plan establishes the human 

capital goals and strategies that support FCA in achieving its mission, goals, and objectives. 

Specifically, the plan outlines the strategic drivers, workforce analysis, findings and themes, human 

capital goals and strategies, and methods to monitor and evaluate progress.

Although the Agency had not finalized the plan or fully implemented the items, the plan identified 

several strategies for achieving human capital goals and objectives. The Strategic Human Capital 

Management Plan strategies that could reduce the risk facing the Agency in regard to key position 

and personnel dependencies and succession planning include:

• Develop a cross-agency rotational program to provide opportunities for experienced staff 

and supervisors to broaden their functional, technical, and leadership skills; 

• Implement a leadership readiness program to provide aspiring leaders the necessary skills 

and experiences in preparation for team lead, supervisory, and management positions; 
3 

• Provide developmental opportunities and training to current supervisors and leaders to 

enhance their skills; 

• Develop and implement a comprehensive, agency-wide succession management process; 

and

• Expand team-based developmental learning to build knowledge across offices and 

provide experiential learning opportunities to staff to broaden and deepen expertise.

The Strategic Human Capital Management Plan explains that the implementation of its strategies 

“will help to ensure that FCA is hiring the right candidates, training them in the most effective way 

possible, managing them as competent and capable employees, upgrading their skills to fulfill the 

future mission of FCA, and establishing conditions which aid in retention of essential personnel.” 

The plan also includes benchmarks for each of the strategies to help FCA measure, monitor, and 

evaluate progress. 

Finally, the Strategic Human Capital Management Plan also highlights the need for succession 

planning by stating, “Leaders noted that while current succession planning processes have been 

working, especially for filing vacancies, FCA lacks a comprehensive and proactive approach that 

would build long-term capability.”

Guidance on Succession Planning 

Agencies are required to have comprehensive management succession programs and to provide 

training to employees to develop agency managers. For example,

• Title 5, Code of Federal Regulations (CFR), section 412.201, Management succession,

requires that the head of each agency, in consultation with the Office of Personnel 

Management (OPM), ”develop a comprehensive management succession program based 

on the agency’s workforce succession plans, to fill agency supervisory and managerial 

positions.” It further explains that “the focus of the program should be to develop 

managers as well as strengthen organizational capability, and to ensure an adequate 

number of well-prepared and qualified candidates for leadership positions.” Succession 

management “programs must also be supported by employee training and development 

programs.” 

• Title 5, CFR, section 412.202, Systematic training and development of supervisors, managers, 

and executives, requires that “All agencies must provide for the development of individuals 

in supervisory, managerial and executive positions, as well as individuals whom the agency 

identifies as potential candidates for those positions, based on the agencies’ succession 

plans.” 
4 

Standards for Internal Control

The United States Government Accountability Office’s Standards for Internal Control in the Federal 

Government (Green Book) provide the overall framework for establishing and maintaining an 

effective internal control system.1 In the Green Book, Principle 4: Management should demonstrate 

a commitment to recruit, develop, and retain competent individuals, under the control environment 

component, addresses the attributes needed for an effective control system relating to succession 

and contingency plans. The chart below shows some of the specific attributes relating to these 

areas.

4.06 

Management defines 

succession and contingency 

plans for key roles to help the 

entity continue achieving its 

objectives. Succession plans 

address the entity’s need to 

replace competent personnel 

over the long term, whereas 

contingency plans address the 

entity’s need to 

respond to sudden personnel 

changes that could 

compromise the internal 

control system. 

4.07

Management defines 

succession plans for key roles, 

chooses succession candidates, 

and trains succession 

candidates to assume the key 

roles. If management relies on 

a service organization to fulfill 

the assigned responsibilities of 

key roles in the entity, 

management assesses whether 

the service organization can 

continue in these key roles, 

identify other candidate 

organizations for the roles, and 

implements processes to 

enable knowledge sharing with 

the succession candidate 

organization. 

4.08

Management defines 

contingency plans for 

assigning responsibilities if 

a key role in the entity is 

vacated without advance 

notice. The importance of 

the key role in the internal 

control system and the 

impact to the entity of its 

vacancy dictates the 

formality and depth of the 

contingency plan.

Human Capital Framework

OPM’s Human Capital Framework also provides comprehensive guidance on strategic 

human capital management in the Federal Government.2The Human Capital Framework guides 

agencies to effectively manage an organization’s talent by promoting the use of sound talent 

management practices. The Human Capital Management Framework explains that “Talent 

Management exists to ensure that organizations get the right people with the right skills into the 

right position at the right time so an agency can accomplish its mission.” The framework 

defines talent management as “a system that promotes a high-performing workforce, 

identifies and closes skills gaps, and implements and maintains programs to attract, acquire, 

develop, promote, and retain quality and diverse talent.” The talent management portion of the 

framework outlines the following: 

1 The United States Government Accountability Office’s Standards for Internal Control in the Federal Government, 

September 2014, https://www.gao.gov/assets/gao-14-704g.pdf. 2 OPM’s Human Capital Framework, http://www.opm.gov/policy-data-oversight/human-capital-framework/.
5 

1. Plan for and manage current and future workforce needs;

2. Design, develop, and implement proven strategies and techniques and practices to attract, 

hire, develop, and retain talent; and 

3. Make progress towards closing any knowledge, skill, and competency gaps throughout 

the agency. 

The Human Capital Framework also explains that succession management plans are a way to help 

facilitate leadership in the completion of human capital decisions and activities. Specifically, a 

succession management plan is used to communicate initiatives, programs, and activities 

associated with an agency’s succession management strategy. 

Continuity of Operations

While not considered a succession plan or guidance, FCA policy requires a comprehensive and 

effective strategy to ensure continuity of essential Agency functions under all circumstances. To 

support this policy, the Agency has implemented a Continuity of Operations Program which 

identifies essential functions and prioritizes them into National Essential Functions, Primary 

Mission Essential Functions, or Mission Essential Functions and specifies orders of succession and 

emergency delegations of authority.

As evidenced in the previous information, succession planning and the identification of 

dependencies is important. It is also important that the Agency does not create a biased approach 

to competition and respects the principles of Federal hiring. FCA must mitigate the risks of 

position and personnel dependencies without sacrificing competitive principles and human 

resource requirements. 

Prior OIG Reports 

The FCA Office of Inspector General (OIG) issued previous reports relating to key position and 

personnel dependencies, human capital management, and succession planning.

• Human Capital Planning at the Farm Credit Administration (February 29, 2016): The 

objectives of this audit were to assess the adequacy of FCA’s human capital planning and 

the effectiveness of its implementation. The audit focused on three areas of human capital 

planning: key person dependencies and succession planning, employee hiring and 

separation, and workplace diversity and inclusion. The OIG found that FCA had an 

adequate human capital strategy with opportunities to improve human capital plan 

implementation and processes. The OIG made 11 recommendations in the report. All 

recommendations were closed by September 29, 2016. 

• The Farm Credit Administration’s Employee Separation Process (February 9, 2021): The 

objective of the audit was to determine whether FCA has an efficient and effective process 

for separating employees. The audit found that while the Agency had established policies 

and procedures, established access controls for its exit questionnaire data, and performed 

an analysis in 2019 using exit survey data, there were opportunities to improve the overall 
6 

effectiveness and efficiency of the separating process. The OIG made six recommendations 

in the report. All recommendations were closed by March 25, 2021. 

• The Farm Credit Administration’s Examiner Staffing Program (January 30, 2023): The 

objective of this audit was to evaluate FCA’s examination staffing processes. The audit 

found the Agency devoted resources, and appropriately budgeted for, examination staff 

recruiting efforts. The Agency also implemented a variety of tools and processes to staff 

examination projects, and developed processes for scheduling, rotating, and retaining FCA 

examination staff. However, the audit identified opportunities to improve the examiner 

recruiting, scheduling, and staffing processes. The OIG made seven recommendations in 

the report. FCA Management closed five of the recommendations and two remained open 

as of the issuance of this report. 

OBJECTIVE, SCOPE, AND METHODOLOGY

Objective

The objective of this inspection was to analyze the Agency’s efforts to identify dependencies in 

key positions and personnel and mitigate the risks associated with those dependencies.

Scope 

The scope of the inspection was limited to the Agency workforce as of July 2023 and retirement 

projections through 2030. The inspection was conducted at FCA’s headquarters in McLean, 

Virginia from July 2023 to February 2024. 

Methodology 

The OIG took the following steps to accomplish the objective:

• Identified and reviewed applicable laws, regulations, guidance, and other background 

information applicable to the objective.

• Identified and reviewed applicable internal FCA policies and procedures.

• Reviewed prior FCA OIG and other external reviews related to the inspection objective.

• Conducted interviews with the Chief of Staff and Chief Risk Officer, the leadership of each 

office within FCA, and other individuals within OAS that are responsible for strategic 

planning and training. 

Tests Performed

The OIG performed the following tests to accomplish the objective:

 Reviewed the Employee Data Report for employee retirement eligibility, grade level, and 

offices. The Employee Data Report is an internal system utilized by FCA to track employee 
7 

information. The OIG received access to the information for this review and employee 

information was reviewed as of July 18, 2023. The OIG removed employees from the 

dataset that were designated as interns, temporary employees, and presidentially 

appointed positions. We also removed OIG and non-FCA personnel from the dataset. The 

OIG relied on the information in the Employee Data Report and did not perform 

independent testing of employee information, such as confirming the data through 

electronic personnel file testing. However, because we believe we can sufficiently rely on 

the information in an internally used system for this review, we will attribute the origin of 

the dataset to the Employee Data Report when making conclusions.

 Analyzed retirement eligibility based on employees’ date of eligibility in the Employee Data 

Report. The OIG reviewed and analyzed Agency data by grade level and office to determine 

impacts of retirement eligibilities through December 31, 2023, and then by December 31, 

2030. We selected these dates based on the projections through the year the review was 

conducted and through the end of the decade (2030) to understand the impact of 

retirements over a longer period of time. 

 Reviewed office succession planning materials and identifications of key position and 

personnel dependencies, where applicable. 

 Analyzed job series, positions, and leadership and compared the results with office 

functions and staffing levels. 

 Analyzed the techniques used by each FCA office to mitigate the risks associated with key 

position and personnel dependencies. Specifically, the OIG reviewed how the offices 

promoted knowledge transfer and leadership and executive development by conducting 

interviews with Office Directors. 

Quality Standards for Inspection and Evaluation

This inspection was performed in accordance with Council of the Inspectors General on Integrity 

and Efficiency’s Quality Standards for Inspection and Evaluation. These standards require that we 

plan and perform the inspection to obtain sufficient and appropriate evidence that provides a 

reasonable basis for our findings, conclusions, and recommendations. We assessed internal 

controls and compliance with laws and regulations to the extent necessary to satisfy the objective. 

Because our review was limited, it would not necessarily have disclosed all internal control 

deficiencies that may have existed at the time of our inspection. We assessed the information and 

data collected during the inspection and determined it was sufficiently reliable and valid for use 

in meeting the inspection objective. We assessed the risk of fraud related to our inspection 

objective while evaluating evidence and had no matters come to our attention indicating fraud or 

illegal acts were occurring. Overall, we believe the evidence obtained is appropriate and sufficient 

to provide a reasonable basis for our findings and conclusions based on the inspection objective.
8 

INSPECTION RESULTS

We determined that FCA had initiated certain efforts to identify dependencies in key positions 

and personnel and mitigate the risks associated with those dependencies. Specifically, the OIG 

found that:

• All offices have identified key position and personnel dependencies in some way; 

• Some offices had documented efforts, such as succession plans or lines of responsibility; 

• Offices generally had a structure and grade distribution that mitigated the risk associated 

with key position and personnel dependencies; and

• Some offices conducted skills inventories and had individual development plans for staff. 

However, the OIG found that there was a lack of consistency in the positions and personnel 

identified and the documentation of dependencies. Therefore, the Agency has opportunities to 

promote knowledge transfer and improve employee development by providing and updating 

Agency-wide guidance.

Agency Risk 

As noted above, FCA considers succession planning as one of the top risks facing the Agency. The 

need for succession planning at FCA is highlighted by the increasing number of retirement 

eligibilities among staff, especially when viewed at the office level and among leadership. 

As of July 18, 2023, FCA’s Employee Data Report included a total of 315 employees.

3 According 

to the information in the data report, of those employees, 63, or 20 percent, were eligible to retire 

in 2023,

4 and 98 employees, or 31.1 percent, were eligible to retire by 2030.5 When employee 

retirement data is broken down by office, the impact to FCA is more easily seen. Specifically, 4 of 

the 11 FCA offices have more than 35 percent of its staff as retirement eligible in 2023. Those 

offices include the Front Office6 (62.5 percent), Office of General Counsel (OGC) (38.5 percent), 

Office of Secondary Market Oversight (OSMO) (40 percent), and Office of Equal Employment 

3 The Employee Data Report is an internal system utilized by FCA to track employee information. We received access to 

the report for this review and employee information was reviewed as of July 18, 2023. We removed employees from the 

dataset that were designated as interns, temporary employees, and presidentially appointed positions. We also removed 

OIG and non-FCA personnel from the dataset. The retirement eligibility date in the Employee Data Report is not for 

retirement exceptions that may be available to certain employees, such as early retirement eligibility. The OIG relied on 

the information in the Employee Data Report for the analyses in this report. 

4 When referenced in this report as retirement eligible in 2023, we are referring to those noted with a retirement 

eligibility date through December 31, 2023.

5 When referenced in this report as retirement eligible in 2030, we are referring to those noted with a retirement 

eligibility date through December 31, 2030. 6 The OIG used the term “Front Office” for individuals assigned to the Office of the Board and the Office of the Chief 

Executive Officer – Chief Operations Officer. While the Employee Data Report included individuals from EEOI in this 

category, the OIG included EEOI as its own office for analytical purposes. 
9 

Opportunity and Inclusion (EEOI) (40 percent).7 Additionally, 8 out of 11 offices have a 2030 

retirement eligibility percentage of over 35 percent, as noted in the table below. 

Retirement Eligibility by Office for 2023 and 2030

Office

Percentage of 

Office 2023 

Retirement Eligible

Percentage of 

Office 2030 

Retirement Eligible

Front Office 62.5 percent 62.5 percent

EEOI 40 percent 60 percent

OAS 17.6 percent 47.1 percent

Office of the Chief Financial 

Officer (OCFO) 

27.3 percent 36.4 percent

Office of Congressional and 

Public Affairs (OCPA) 

16.7 percent 50 percent 

Office of Data Analytics and 

Economics (ODAE) 

30 percent 30 percent

Office of Examination (OE) 15.3 percent 22.4 percent

OGC 38.5 percent 53.8 percent

Office of Information 

Technology (OIT) 

17.6 percent 44.1 percent

Office of Regulatory 

(ORP) 

Policy 21.7 percent 30.4 percent

OSMO 40 percent 40 percent

7 Over the course of our inspection there were leadership and structure changes in OGC, OSMO, and the 

Front Office.
10

Another way we reviewed the retirement data is by grade distribution. In accordance with the 

Farm Credit Act of 1971, as amended,

8 the FCA Board Chairman sets and adjusts the rates of basic 

pay for FCA employees and provides such additional compensation and benefits as necessary to 

maintain comparability with the total amount of compensation and benefits provided by other 

Federal bank regulatory agencies. FCA utilizes the VH pay schedule for the compensation of its 

employees. The highest non-executive position in the VH pay schedule is VH 41, which would be 

equivalent to a 15 on the General Schedule. Executive positions on the VH pay schedule range 

from VH 42-45. 

The highest percentage of FCA staff retirement eligibility are at the VH 41-45 levels. This includes 

the VH 42 grade level with a current retirement eligibility above 66 percent and the VH 41 level 

with a current retirement eligibility above 42 percent. In 2030, those totals jump to almost 78 

percent for VH 42s and 57.1 percent for VH 41s. Because FCA’s highest concentration of retirement 

eligible employees are in executive and executive development positions, there is a risk that FCA 

could lose a significant portion of its senior staff at any time. This data also indicates an Agencywide need for succession planning, especially at the highest levels in the organization. 

Percent of

VH Grade

Retirement Eligibilities in 

2023 Retirement 

eligible 

each VH Level

2030 Retirement 

eligible 

VH 45 100 percent 100 percent

VH 44 37.5 percent 75 percent

VH 43 40 percent 60 percent

VH 42 66.7 percent 77.8 percent

VH 41 42.9 percent 57.1 percent

VH 40 23.5 percent 33.3 percent

VH 39 11.9 percent 28.8 percent

VH 38 21.2 percent 30.3 percent

VH 37 2.3 percent 4.5 percent

VH 36 10 percent 30 percent

VH 35 0 percent 0 percent

8 Section 5.11(c)(2)(A) of the Farm Credit Act of 1971, as amended (12 U.S.C. § 2245(c)(2)(A)). 
11

VH 34 6.3 percent 6.3 percent

VH 33 N/A N/A

VH 32 N/A N/A

VH 31 0 percent 100 percent

High Risk Examples

During our inspection, we reviewed the Agency’s data to identify specific potential high-risk areas 

for the Agency in terms of personnel, position, grade, and retirement eligibilities. We found the 

following key areas relating to the Agency:

• In OE, a high amount of retirement eligible personnel are in senior positions. Of the 183 

employees, OE has 18 people at the VH 41-44 levels, which includes their entire 

management team. 12 of the 18 senior leaders, or 66.7 percent, were eligible to retire in 

2023. Specifically, all employees at the VH 43-44 levels are currently eligible to retire and 

80 percent of the VH 42s were eligible to retire in 2023. OE’s employees at the VH 41 level 

have a 54.5 percent eligibility rate for retirement in 2023 and 63.6 percent by 2030. Given 

that the VH 41 level is a typical feeder pool into executive positions, this retirement 

eligibility data underscores the need for effective succession planning. 

• Agency-wide there are 58 persons, or 18.4 percent of the Agency, at the VH 41-45 levels. 

Almost half of the personnel at those levels, 27 of the 58 persons, were eligible to retire in 

2023 (46.6 percent), and more than half by 2030 (63.8 percent). 

• Of the executive level staff, which are those employees at the VH 42-45 levels, 12 out of 

23 executives, or 52.2 percent, are eligible to retire as of 2023 and 73.9 percent by 2030.

• There are currently 81 persons at the VH 40 level, or 25.7 percent of the Agency, which is 

good news for future, potential leaders. However, 19 of those 81 are eligible to retire by 

December 2023, and 27 of those 81, or 33.3 percent, are eligible to retire by December 

2030. The VH 40 level also is a potential internal candidate feeder pool for the higher grade

and executive level positions.

While these examples only show a part of the full FCA workforce, they highlight the succession 

risks at the Agency and the need to properly mitigate such risks to ensure leadership continuity.

Process to Identify Key Position and Personnel Dependencies

While the OIG found that all FCA offices identified key position and personnel dependencies in 

some way, FCA did not have a consistent approach to identifying or documenting such key 

position and personnel dependencies. While we understand the need for flexibility, it is important 

to ensure that the risks for the specific offices, and the agency as a whole, are known, 

communicated, and have been properly mitigated. It is also important that Office Directors do not 
12

create a biased approach to competition in the event of vacancies. FCA needs a fair and unbiased 

approach to succession planning that maximizes competition but mitigates the risks of position 

and personnel dependencies. 

Succession Planning 

The OIG found that FCA offices have all identified key positions and personnel, in some way,

despite a lack of overall Agency guidance. Additionally, some FCA offices have documented 

succession plans, position responsibilities, and lines of succession to help reduce risk. However, 

we found a lack of consistency among FCA offices in the positions and personnel identified and 

in the documentation of key dependencies. For example, documentation of key positions and 

personnel varied from office to office, with some offices having written succession plans that

outlined key dependencies and successors to others having no written succession plans. 

OE and OCFO both had written succession plans that outlined key dependencies, identified 

successors, and listed retirement eligibilities for key dependencies. While ORP did not have a 

succession plan for the office, ORP Office Directive 1 outlined the line of succession for the Office 

Director, which identifies the Deputy Director and the VH 41 Team Leaders as potential successors 

in the event the Office Director cannot perform the role. In another approach, OCPA’s internal 

procedures identify the primary and secondary staff members responsible for all office-related 

tasks. However, OAS, ODAE, OGC, OSMO, OIT, and EEOI did not have any written succession plans 

or documentation of key position and personnel dependencies. 

Mitigation Efforts for Dependencies

Mitigation of key position and personnel dependencies focuses on preparing the Agency and 

individual offices for the loss of individuals. Thus, mitigation efforts focus on transferring the 

knowledge from those currently in the positions and developing the knowledge, skills, and abilities 

of possible successors.

The existence of key position and personnel dependencies is not inherently an adverse condition.

Given the size, complexity, responsibilities, and resources of FCA offices, key position and 

personnel dependencies are going to exist as they do in any workplace organization. It is how the 

risk of loss in these key positions is addressed and mitigated that is important. There are a wide 

variety of ways the Agency, and individual FCA offices, might mitigate the risk of key position and 

personnel dependencies and the loss of employees. The impact on the Agency from losing key 

personnel can vary office by office. Each office should identify their risks, prioritize their mitigation 

efforts, and design strategies that work for them, as long as the overall Agency risks are also 

addressed. 

One of the most mentioned mitigation factors for FCA is in its ability to attract and hire strong 

candidates. Several Office Directors discussed in our interviews that because FCA has a strong 

benefits and compensation package, the Agency is a very attractive employer for potential 

candidates. This can then correlate to good candidate pools when the Agency is hiring. This is 

especially important for offices that have skillset needs that are transferrable from other federal 
13

agencies, such as legal, financial management, human resources, and information technology

skillsets. 

Another important concept revealed through our interviewing was the focus some FCA offices put 

on future needs when hiring rather than just looking to replace current skill sets. For example, 

ODAE leadership talked about the importance of looking to the future and understanding not just 

what is needed currently, but what might be needed in the future. This focus emphasizes the value 

of offices that are readied for innovations that may be on the horizon.

Skills and Abilities Identification

For mitigation techniques to be effective, it is important to understand current knowledge, skills, 

and abilities of staff in order to develop plans to fill gaps either through the hiring process, crosstraining, or by developing current staff. However, the Agency has not required offices to identify 

the skills and abilities of their staff as a way to understand the gaps and risks in the offices. 

Although FCA does not have a documented approach to performing a skills inventory, there 

appeared to be some movement in this area. For example, over the course of this inspection, 

ODAE performed a skills inventory for its staff economists and data scientists that included a listing 

of each staff member’s education, experience, and technical skills. The ODAE Director stated this 

would aid in facilitating cross-training opportunities, balancing the skills and capabilities across 

domains in the team, and understanding whether the office has the expertise necessary to cover 

all the areas needed going forward. 

The Director of OE stated that OE also has listings of which staff have completed the requirements 

to become a commissioned examiner. Although this is different from ODAE, it is another approach 

to understanding offices’ current knowledge, skills, and abilities. 

Knowledge Transfer and Employee Development

The Agency has opportunities to promote knowledge transfer and improve employee 

development. During our interviews, several FCA Office Directors indicated that knowledge 

transfer was a way of mitigating key position and personnel dependencies. Generally, Office 

Directors provided examples of cross-training, shadowing, on-the-job training, rotational 

assignments, and mentoring as ways their offices promote knowledge transfer. 

Multiple Office Directors stated that there are FCA employees who have been in their current roles 

for a long period of time and have become Agency subject-matter experts. To reduce the risk that 

the Agency and the individual offices face from the departure of these staff members, it is 

important to ensure their knowledge is transferred to others in the Agency. 

We found that most FCA offices took steps to promote knowledge transfer among their staff. The 

Director of ORP stated that the office promoted cross training by providing staff members the 

opportunity to work on different ORP teams to gain specialized experience. OGC leadership 

explained that the office promotes knowledge transfer by assigning multiple personnel with 

varying levels of experience to an assignment as on-the-job training. This allows one person to 
14

be the expert and lead the assignment, while the other person gains new experiences in dealing 

with a particular subject matter. The OE Director explained that OE uses rotational assignments 

so that examiners can obtain training on the job ahead of possible job openings. The OE Director

explained that rotational assignments are internally announced, a selection panel reviews the 

applicants, and the panel makes a selection. OE also has a mentoring program for certain staff. 

The Director of OIT stated that the office promotes knowledge transfer by having certain senior 

staff members mentor junior staff members. Additionally, OAS has begun to promote coaching 

and mentoring by hosting training events for staff and supervisors. OAS has also begun

development of an internal site available to everyone in the Agency for leadership development, 

training, and resources.

While FCA offices each have their own processes for mitigating dependencies, there is an 

opportunity to improve how mitigation occurs and the extent to which it is offered amongst the 

offices. FCA could formalize knowledge transfer activities on an Agency-wide level by offering, for 

instance, additional Agency-wide rotational assignments, detail opportunities, and mentoring or 

coaching programs. Staff may miss opportunities for professional development because there is 

no program offered by their office. By formalizing knowledge transfer activities on an Agencywide level, the Agency could improve mitigation of risks relating to dependencies and succession 

planning. 

Individual Development Plans

Another way that some FCA offices promote knowledge transfer is through the use of individual 

development plans (IDPs). OCFO, OE, and ORP officials stated their offices utilize IDPs to track the 

training and development of their staff. The Director of OCFO stated that using IDPs has been a 

positive experience because the plans identify staff career goals and allows OCFO management 

to put staff in the position to achieve those goals. 

Previously, the Agency required employees to complete an annual IDP in an Agency-wide 

database system that was coordinated with employees’ supervisors. This system helped 

employees create structured personalized training and career development plans. However, the 

most current version of Policies and Procedures Manual (PPM) 843, Training, Development, 

Professional Certifications, Licenses, and Membership Fees, dated March 10, 2015, states that Office 

Directors have the discretion, but are not required, to utilize IDPs in their offices. The guidance 

goes on to state the following: 

“IDPs should incorporate all aspects of employee development and experiences 

needed to meet employee career and organizational short and long-term 

objectives. It is the supervisor's responsibility under the guidance of their office to 

work with each employee to establish an IDP that outlines long-range career goals 

and short-range developmental objectives. The information on IDPs should be 

determined by the supervisor and the employee and reviewed by the Office 

Director (or designee) to ensure employee training and development will meet 

current and future Agency needs.” 
15

IDPs allow office leadership to set a training plan for staff members in order to help fill gaps 

created by key position and personnel dependencies. The IDP also assists office leadership in 

tracking the completion of training especially for those job functions that do not have continuing 

education requirements. One Office Director stated they frequently do not use their training 

budget because there are other priorities for staff. Another senior official stated that staff usually 

participate in conferences at the end of the year to complete professional requirements. More 

widespread use of IDPs could ultimately help promote knowledge transfer by placing an emphasis 

on knowledge transfer and employee development. 

Leadership and Executive Development

The development and training of future leaders within FCA is key to mitigating position and 

personnel dependencies. Having a strong leadership and executive development program will 

enable FCA to put its employees in the best position for future leadership roles in the Agency.

While the Agency promotes leadership and executive development, improvements to the process 

can be made. 

An OAS representative stated that FCA follows the guidance set out in title 5, CFR, part 412, 

Supervisory, Management, and Executive Development. At section 412.202, the regulation states 

that “all agencies must provide for the development of individuals in supervisory, managerial and 

executive positions, as well as individuals whom the Agency identifies as potential candidates for 

those positions based on agencies succession plans.” 

While FCA has utilized executive development programs, the nomination and selection process 

for those programs is unclear. An OAS representative stated that FCA encourages new executives 

(VH 42 levels and above) and potential executives (VH 40-41 levels) to attend an official executive 

development program. The OAS representative said that a call for nominations is announced by 

OAS, and Office Directors provide nominations. The selection of attendees is made by OAS and 

attendance is funded by OAS. OAS has a tracking system used to show which executives and 

potential executives have attended a course. However, the nominations and selection process for 

the executive development programs is not fully defined or documented. 

As an example, one year a call for nominations to the programs was announced at a senior staff 

meeting and one year there was no call for nominations because attendees (including one nonexecutive) had already been selected. There appeared to be some confusion in the process and 

one Office Director said that they would like their staff at the VH 41 grade level to attend an 

executive development program, but the Agency never offered the opportunity to staff in their

office. 

By not having a documented process for the nomination and selection of candidates for an 

executive development program and what programs are available to staff, the Agency risks a 

biased approach and inconsistency with the Agency’s human capital management goals. Without 

a clear process, the Agency may not be able to ensure the best candidates are being nominated 

and selected for executive development. This further puts the Agency at a disadvantage in 

mitigating key position and personnel dependencies. 
16

Office Structure

The functionality, size, and mission of each FCA office require flexibility in the structure and 

distribution of VH levels amongst FCA offices. While the OIG found that FCA offices generally had 

a structure and VH distribution that mitigated key position and personnel dependencies, there 

are opportunities for additional analyses in this area. The following chart shows the distribution 

of the Agency’s personnel by grade level. 

1

16

13

10

44

33

59

81

35

9

5 8

1

Agency VH Level Breakdown

VH 31

VH 34

VH 35

VH 36

VH 37

VH 38

VH 39

VH 40

VH 41

VH 42

VH 43

VH 44

VH 45

The office structure and VH distribution of some FCA offices inherently foster internal continuity 

and succession planning efforts. For example, OE, ORP, OAS, and OCFO have a VH 44 Director 

and VH 43 Deputy Director. The existence of the VH 43 Deputy Director in these offices may

provide a mitigation of the dependency on the Director position. OAS, OCFO, and ORP all have 

divisions that are managed by VH 41 staff that provide possible successors for the Deputy 

position. OE, based on its size, mission, and geographic distribution of examiners has multiple 
17

executive level positions that provide possible successors for the Deputy position, along with VH 

41 staff that provide possible successors for its other executive positions. 

For EEOI, ODAE, OSMO, and OIT, after the VH 44 Director, the next highest VH levels for these 

offices are VH 41 positions, with certain offices only having one VH 41 position. OIT has a staff of 

34 with three VH 41 level positions. OGC has a Deputy Director position (Deputy General Counsel) 

that mitigates the dependency on the General Counsel, as well as three non-supervisory VH 42 

positions. 

While it is important for the offices to remain flexible and have autonomy in decision making, it is 

also imperative for the Agency to mitigate key position or personnel dependencies. An analysis 

of the grade and supervisory roles in each office would reveal where, for example, leadership 

development skills and training may be needed to fill the gaps between the executive and staff 

levels at the Agency. 

Root Causes

While FCA identifies succession planning as one of the highest risks facing the Agency, no Agencywide guidance on succession planning or the identification of key position and personnel 

dependencies currently exists. Furthermore, while individual FCA offices took steps to promote 

succession planning and the identification of dependencies, the lack of consistency in the process 

can be attributed to a lack of overarching guidance. Additionally, outdated and underutilized

Agency policies make it difficult to discern the difference between the process outlined in the 

policy and those that are currently practiced by the Agency. Finally, the missions, functions, and 

structures of FCA offices, along with the Coronavirus Disease 2019 (COVID-19) pandemic, made 

the prioritization and establishment of succession planning difficult to accomplish.

Control Structure 

Inadequate controls contributed to inconsistencies in the identification and mitigation of key 

position and personnel dependencies at FCA. Specifically, there is no Agency-wide guidance on 

succession planning or the identification of key position and personnel dependencies. By not fully 

knowing the current knowledge, skills, and abilities along with the career goals and aspirations of 

its staff, FCA is not able to fully mitigate key position and personnel dependencies. As indicated 

in FCA’s Strategic Human Capital Management Plan FY 2020-2024, the inconsistent use of IDPs 

results in staff career goals not always being known to management, which ultimately affects 

succession planning and the mitigation of key position and personnel dependencies. Whether or 

not FCA uses IDPs or other methods, identifying employee career goals, developmental 

opportunities, and training needs could help build organizational capacity and enhance 

engagement.

FCA policies and procedures describe a number of programs that could help the Agency promote 

knowledge transfer and improve the training and development of staff; however, some of these 

programs are not currently in use and the policies and procedures appear to be outdated. 

Specifically: 
18

• PPM 811 establishes the procedures for FCA’s Upward Mobility Program. The policy was 

last updated in 1990 and does not appear to represent the current process used in the 

Agency. Specifically, the PPM refers to offices that no longer exist in FCA and discusses

requirements for IDPs that are no longer required by FCA. Finally, there are no current 

employees formally attending the program.

• PPM 854 outlines the Agency’s Mentoring Program that provides mentoring opportunities 

to help address the professional development needs of employees. This PPM was last 

updated in 2003 and contains references to offices and processes that no longer exist at 

the Agency. There are no current employees formally attending the program.

• PPM 815 establishes the procedure for the Agency’s Long-Term Rotational Assignments 

Program. The PPM was last updated in 2008 and does not reflect the current processes 

used in the Agency. There are no current employees formally attending the program. 

• PPM 853 provides guidance on FCA’s Supervisory Development Program. The PPM was 

last updated in 2003 and does not appear to represent the current processes used in the 

Agency. Specifically, the PPM references FCA offices and activities that are no longer 

current in FCA. There are no current employees formally attending the program.

There is currently an Agency-wide effort underway to revise Agency policies and procedures. 

Additionally, the OAS Director stated that OAS personnel will be reviewing the foregoing PPMs, 

along with others, to revise, combine, or sunset, them as needed. 

Cost and Availability of Training Opportunities

The Agency has continued its practice of sending employees to leadership and executive 

development training. It is understood that executive and leadership development programs 

come at a cost to the Agency, and there are a limited number of spots available for the trainings. 

Because of these limitations, there is a need for guidance on the nomination and selection of staff

to ensure a fair and equitable approach. 

COVID-19 Pandemic 

Human capital strategies and initiatives identified in the Strategic Human Capital Management 

Plan for FY 2020-2024 were not prioritized due to the COVID-19 pandemic, which brought many 

new human capital management challenges to the forefront of the Agency. This included directing 

most of its workforce to telework; suspending business travel and in-person training; and 

developing, implementing, and managing a return-to-work process for FCA headquarters and its 

field offices across the United States. 

FCA’s response to the COVID-19 pandemic ultimately earned the Agency the highest score in the 

“COVID Overall” category across all federal agencies in the 2020 rankings for “Best Places to Work 

in the Federal Government.” As the Agency adjusts to the new-normal working environment, FCA 

has an opportunity to refocus planning for the future to include a prioritization of succession 

planning on both the Agency and individual office levels. 
19

Impact 

With a significant portion of its leadership and executive staff eligible to retire in the coming years, 

FCA has self-identified succession planning as one of the highest risks facing the Agency. While 

FCA offices are currently taking steps to promote succession planning and the mitigation of key 

position and personnel dependencies, a lack of consistency amongst the offices creates 

inefficiencies in the process. 

By providing guidance that documents how key position and personnel dependencies are 

identified and documented at the office and Agency level, FCA can better mitigate the risks facing 

the Agency and create efficiencies in the succession planning process. Specifically, a multi-layered 

approach to succession planning that starts with strategic alignment and identifies the knowledge, 

skills, and abilities of current staff will ultimately help the Agency identify gaps created by key 

position and personnel dependencies. The Agency can then plan for, manage, and promote the 

development of staff to address the gaps and reduce the risk associated with key position and 

personnel dependencies. 

Recommendations

To improve FCA’s process for succession planning and the identification and mitigation of key 

position and personnel dependencies: 

1. The Office of Inspector General recommends the Farm Credit Administration provide 

guidance to Office Directors on how to identify and mitigate key position and personnel 

dependencies to strengthen an Agency-wide succession program.

2. The Office of Inspector General recommends the Farm Credit Administration analyze 

whether the current office structures and use of grade levels allow for proper mitigation 

of succession risk.

3. The Office of Inspector General recommends the Farm Credit Administration analyze and 

update, rescind, or issue new guidance on training and development programs mentioned 

in the report, including setting forth the nomination, application, and selection criteria for 

leadership and executive development opportunities.

4. The Office of Inspector General recommends the Farm Credit Administration direct each 

office to identify skills and abilities in their offices to understand gaps, risks, and 

opportunities to assist in succession management activities where such identifications 

have not already been performed.

5. The Office of Inspector General recommends the Farm Credit Administration analyze 

whether individual development plans should be required or whether other methods 

could be employed to ensure that career goals, developmental opportunities, and training 

needs are addressed. 
20

FCA Response

FCA management agreed with the five recommendations and provided responsive corrective 

actions for all recommendations made in the report. Specifically, management stated they will:

• Develop a succession planning framework and provide guidance to FCA leadership to 

support the identification of key positions and personnel dependencies across the Agency; 

• Conduct a quantitative workforce analysis to identify trends and insights to help FCA 

identify key risk areas; 

• Make recommendations to the FCA Board that support organizational structures and 

staffing models that facilitate efficient and effective achievement of strategic objectives, 

including succession planning and appropriate risk mitigation;

• Conduct an organizational design review focused on the alignment of office structures, 

positions, and grade levels with overall Agency mission and strategic objectives; 

• Continue the agency-wide project focused on the review and update of internal policies 

and procedures. As part of this effort, FCA expects to analyze and update numerous 

policies and procedures, including those specifically mentioned in the draft report; and

• Explore whether individual development plans should be implemented agencywide.

Management estimated the actions would be completed by September 30, 2024.

OIG Response

OIG finds the actions responsive to our recommendations. Management comments can be found 

in the subsequent section of the report. The Agency waived an exit conference.
21

MANAGEMENT COMMENTS
22
23

ACRONYMS

COVID-19 Coronavirus Disease 2019

EEOI Equal Employment Opportunity and Inclusion

FCA or Agency Farm Credit Administration

FY Fiscal Year

IDP Individual Development Plan

OAS Office of Agency Services

OCFO Office of the Chief Financial Officer 

OCPA Office of Congressional and Public Affairs

ODAE Office of Data Analytics and Economics

OE Office of Examination

OGC Office of General Counsel

OIG Office of Inspector General 

OIT Office of Information Technology 

OPM Office of Personnel Management

ORP Office of Regulatory Policy

OSMO Office of Secondary Market Oversight

PPM Policies and Procedures Manual

System Farm Credit System
REPORT FRAUD, WASTE, ABUSE, &

MISMANAGEMENT

Fraud, waste, abuse, and mismanagement in government concerns 

everyone: Office of Inspector General staff, FCA employees, Congress, 

and the general public. We actively solicit allegations of any inefficient 

and wasteful practices, fraud, and mismanagement related to FCA 

programs and operations. You can report allegations to us in several 

ways:

Online: https://apps.fca.gov/oigcomplaint

Phone: (800) 437-7322 (Toll-Free)

(703) 883-4316

Email: fca-ig-hotline@rcn.com

Mail: 1501 Farm Credit Drive

McLean, VA 22102-5090

To learn more about reporting wrongdoing to the OIG, please visit our 

website at https://www.fca.gov/about/inspector-general.