OFFICE OF 

INSPECTOR GENERAL

Human Capital Planning at the 

Farm Credit Administration

A-15-03

Audit Report 

Auditor-in-Charge

Sonya Cerne

Issued February 29, 2016

FARM CREDIT ADMINISTRATION
Farm Credit Administration Office of Inspector General

 1501 Farm Credit Drive 

 McLean, Virginia 22102-5090

 

 

February 29, 2016 

The Honorable Kenneth A. Spearman, Board Chairman 

The Honorable Dallas P. Tonsager, Board Member

The Honorable Jeffery S. Hall, Board Member 

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102-5090

 

Dear Board Chairman Spearman and FCA Board Members Tonsager and Hall:

The Office of Inspector General (OIG) completed an audit of Human Capital Planning at the Farm Credit 

Administration (FCA or Agency). The objectives of this audit were to assess the adequacy of the 

Agency’s human capital planning and the effectiveness of its implementation. 

We found the Agency has an adequate human capital planning process. FCA has a Human Capital Plan 

for FY 2014-2018 in place and a new plan is being prepared. FCA has a process to identify key person 

dependencies and plans for future needs of the Agency. FCA also has an equal employment 

opportunity and inclusion (EEOI) program that includes written policies and procedures and an EEOI 

element on all employees’ performance evaluations. 

We identified opportunities to improve or modify human capital planning and implementation. In 

response to our audit, OMS agreed to the following actions: 

1. Formalize the human capital planning process by: 

identifying membership (positions) of the Human Capital governance body,

scheduling reviews of the Human Capital Plan objectives, and

monitoring and tracking progress toward meeting human capital goals.

2. Track data on succession planning efforts. Document the strategies to mitigate the risks. 

Monitor and follow-up to capture and utilize results.

3. Assess organizational leadership and development programs and modify to promote, 

enhance, and improve initiatives within the Agency.

4. Coordinate and revise the network distribution list for FCA job announcements.
5. Increase coordination between OMS and EEOI on special emphasis programs and outreach.

6. Implement a plan to improve the exit interview process and disperse exit interview data to 

gather consistent, useful information for comparison and trends.

7. Consider a veterans’ representative for Agency veteran efforts.

8. Provide training to all personnel involved in the recruiting and hiring process on potential 

biases and barriers to employment.

9. Conduct an assessment of FCA hiring practices to identify potential barriers and areas of 

improvement.

10. Establish a policy that includes the plan for requesting and analyzing applicant flow data for 

FCA job announcements.

11. Conduct a survey, or use other information-gathering tools, to gather additional targeted 

information on workplace diversity and inclusion.

We appreciate the courtesies and professionalism extended by FCA personnel to the OIG staff. If you 

have any questions about this audit, I would be pleased to meet with you at your convenience.

Respectfully,

Elizabeth M. Dean

Inspector General

Enclosure
RESULTS

We found the Agency has an adequate

human capital planning process.  FCA has

a Human Capital Plan for FY 2014‐2018 in

place and a new plan is being prepared.   

Regarding succession planning, FCA has a

process to identify key person

dependencies and plans for future needs

of the Agency. There is also a training

program for personnel who are

responsible for recruiting examiner and

intern positions for the Office of

Examination, the most prominent career

path within FCA.  Finally, with respect to

diversity and inclusion, FCA has an equal

employment opportunity and inclusion

(EEOI) program.  The EEOI Director

reports directly to the FCA Board

Chairman, and there are written policies

and procedures.  All employees are

accountable for supporting EEOI, in part,

by being evaluated on EEOI in their

performance evaluations.  

We identified a few opportunities,

however, to improve or modify human

capital planning and implementation.

 Several key positions in the Agency

were not identified in the human

capital planning request.   

 Efforts to address the gap in mid‐

career experience levels and track

progress in doing so could increase

effectiveness.

 Developmental and training

programs could be enhanced.

 The Agency’s workforce diversity

and inclusion efforts could be

improved through outreach efforts,

increased coordination , and data

collection and analysis efforts.

The objectives of the audit were to assess the adequacy of the Agency’s

human capital planning and the effectiveness of its implementation.  

The Agency agreed to implement 11 agreed‐upon actions to improve the

human capital planning process in response to our audit:

1. Formalize the human capital planning process.   

2. Track data on succession planning efforts.  Document the

strategies to mitigate the risks.  Monitor and follow‐up to

capture and utilize results.

3. Assess organizational leadership and development programs and

modify to promote, enhance, and improve initiatives within the

Agency.

4. Coordinate and revise the network distribution list for FCA job

announcements.

5. Increase coordination between OMS and EEOI on special

emphasis programs and outreach.

6. Implement a plan to improve the exit interview process and

disperse exit interview data to gather consistent, useful

information for comparison and trends.

7. Consider a veterans’ representative for Agency veteran efforts.

8. Provide training to all personnel involved in the recruiting and

hiring process on potential biases and barriers to employment.

9. Conduct an assessment of FCA hiring practices to identify

potential barriers and areas of improvement.

10. Establish a policy that includes the plan for requesting and

analyzing applicant flow data for FCA job announcements.

11. Conduct a survey, or use other information‐gathering tools, to

gather additional targeted information on workplace diversity

and inclusion.

The Office of Management Services agreed with the report and provided

specific tasks to be completed to strengthen FCA’s human capital

planning and implementation.  These tasks included documenting

processes and strategies and increasing coordination.  The Agency stated

it would also implement new initiatives and policies in response to our

report.     
TABLE OF CONTENTS

BACKGROUND ______________________________________________________________________ 1

Prior Reviews____________________________________________________________________ 3 

AUDIT RESULTS______________________________________________________________________ 3

Succession Planning and Knowledge Management ________________________________________ 4 

Key Person Dependencies __________________________________________________________ 4 

Agreed-Upon Action 1_______________________________________________________________ 5 

Succession Planning ______________________________________________________________ 5 

Agreed-Upon Action 2_______________________________________________________________ 6 

Agreed-Upon Action 3_______________________________________________________________ 7 

Employee Hiring and Separations______________________________________________________ 7 

Hiring__________________________________________________________________________ 8 

Separations _____________________________________________________________________ 8 

Agreed-Upon Actions 4-6 ____________________________________________________________ 9 

Workplace Diversity and Inclusion ____________________________________________________ 10

Applicant Data Collection _________________________________________________________ 11

FedHR Navigation System Data ____________________________________________________ 12

OPM System Data _______________________________________________________________ 12

Agreed-Upon Actions 7-11 __________________________________________________________ 15

OBJECTIVE, SCOPE, AND METHODOLOGY________________________________________________ 16

ACRONYMS________________________________________________________________________ 17
1 

BACKGROUND 

The Farm Credit Administration (FCA or Agency) is an independent agency in the Executive Branch of the 

U.S. Government. The mission of the FCA is to promote a safe, sound and dependable source of credit 

for agriculture and rural America. FCA is responsible for regulating and examining the Farm Credit 

System and the Federal Agricultural Mortgage Corporation, the nation’s two agricultural governmentsponsored enterprises. 

FCA’s policy, regulatory agenda, and supervisory and examination activities are established by a fulltime, three-person Board whose members are appointed by the President of the United States. The 

President designates one member as Chairman of the Board. The Chairman also serves as FCA’s Chief 

Executive Officer.

In order to accomplish the mission, it is essential for FCA to ensure it has the right people with the right 

skills. FCA’s most valuable asset is its employees. Human capital planning is, therefore, imperative for 

the Agency. 

The Office of Management Services (OMS) is responsible for managing and delivering human capital 

services and coordinating human capital planning efforts. The Office of Equal Employment Opportunity 

and Inclusion (EEOI) manages and directs the Agency-wide diversity, inclusion, and equal employment 

opportunity program. 

Historically, the annual Human Capital Plan covers the subsequent five year period. FCA’s current 

Human Capital Plan covers FY 2014-2018, which has a primary purpose to identify future workforce 

needs. It states: 

The Agency conducted a human capital assessment and established strategic initiatives to 

identify and address workforce gaps and challenges.

Each office within FCA is responsible for addressing actions established by the strategic 

initiatives.

The Agency has a Human Capital Steering Committee comprised of the Chief Operating Officer, 

Office Directors, and the Chief Human Capital Officer. This Committee helps lead the human 

capital process within the Agency, determines the formal process for improvements, and 

monitors progress. 
2 

In the Human Capital Plan, the Agency identified the following gaps/challenges and the associated 

strategic initiatives:

•Strategic Initiative: Identify positions in which risk of 

key-person dependency (KPD) exists and ensure that 

plans are sufficient to build bench strength and 

manage succession for these positions.

GAP/ CHALLENGE 1: Key-Person 

Dependency

•Strategic Initiative: Meet projected staffing needs 

through aggressive hiring.

GAP/ CHALLENGE 2: Employee 

Turnover

•Strategic Initiative: Continue training programs and 

strategies to increase technical competencies of 

employees, with greater emphasis on technology skills.

GAP/ CHALLENGE 3: 

Competencies

•Strategic Initiative: Continue to create opportunities 

for employees to become more engaged with their 

work.

GAP/ CHALLENGE 4: Employee 

Engagement

•Strategic Initiative: Continue increasing workplace 

diversity and promoting inclusion.

GAP/ CHALLENGE 5: Diversity 

and Inclusion

A new Human Capital Plan is being prepared. A human capital call for information to all Office Directors 

was requested in April 2015.

We considered diversity and inclusion as part of the audit due, in part, to Congressional interest. In 

March 2014, the Committee on Financial Services, U.S. House of Representatives, issued letters to 

Inspectors General requesting reviews to determine whether any personnel practices created a 

discriminatory workplace or otherwise systemically disadvantaged minorities from obtaining senior 

management positions at the following agencies:

Federal Deposit Insurance Corporation, 

Department of the Treasury, 

Federal Housing Finance Agency, 

National Credit Union Administration, 

Board of Governors of the Federal Reserve System, and 

U.S. Securities and Exchange Commission. 
3 

The letters asked the Inspectors General to examine:

employee complaints, 

workplace policies and findings from satisfaction surveys,

individuals or groups that exhibited discriminatory behaviors or patterns, 

agency minority and women inclusion offices, and

employee compensation, rating systems, retention, and promotion of women and minorities.

The letters were issued in response to a 2013 Government Accountability Office report, Trends and 

Practices in the Financial Industry and Agencies after the Recent Financial Crisis. The GAO review found 

improvements were still needed in overall workplace diversity even after the requirements of the DoddFrank Wall Street and Consumer Protection Act. While the Farm Credit Administration OIG was not 

included in the request letters, we included workplace diversity and inclusion efforts at FCA as part of 

this audit. 

Prior Reviews 

We have performed multiple prior reviews related to human capital:

Human Capital: Job Classification (A-04-01, June 29, 2004) 

Performance Management and Internal Control Program (A-05-02, July 1, 2005) 

Records Management and Preservation of Institutional Knowledge (A-05-03, February 21, 2006) 

Affirmative Employment Program Action Plan (I-01-03, May 23, 2001) 

AUDIT RESULTS

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

effectiveness of its implementation. 

We specifically focused on three areas of human capital planning: 

key person dependencies and succession planning,

employee hiring and separation, and

workplace diversity and inclusion. 

In April 2015, the OMS Director issued the planning call for human capital for fiscal years (FY) 2016-

2020. Each office was requested to provide data in the following areas: Key Person Dependency Risk; 

Competencies; Office Needs, Duties, Processes, and Workload; Primary Challenges/Strategies; and 

Employee Engagement. 

We found that overall, the FCA has an adequate human capital strategy; however, opportunities to 

improve the human capital plan implementation and processes are discussed below.
4 

Succession Planning and Knowledge 

Management

Key Person Dependencies

FCA has a process to identify key person dependencies 

(KPD) and plan for future needs of the Agency. As part 

of the human capital process, FCA Office Directors 

were asked to identify the positions in their office 

where there were would be risk to the Agency if there 

was no substitute. They were also asked to describe 

their plan of action to ensure succession, thereby 

mitigating this risk. Although Office Directors 

identified 30 positions as KPDs across six offices, 

several key positions in the Agency were not identified 

in the human capital responses. Such positions 

included the:

Chief Operating Officer,

Chief Examiner, 

Director of the Office of Secondary Market 

Oversight, and

Director of the Office of Regulatory Policy. 

KPD Definition: “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 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.”

FCA Human Capital Plan 

2014-2018

While these seemingly mission critical positions have 

competent staffs, the Chief Operating Officer and 

Office Directors are leaders and notably, the decision-makers in specialized subject matter areas. They 

maintain and change significant business processes essential to FCA. Not identifying these positions

may represent a gap in the KPD identification process. 

Office Directors submitted plans of action for KPDs identified during the human capital planning call. 

These actions included developing additional staff, hiring contractor help, recruiting, and documenting 

policies and procedures. In order to gain a broader perspective from the employees, we also 

interviewed 7 of the 30 KPD employees identified by Office Directors. We asked questions related to: 

their current position, people trained to take over their main roles, backups, and other succession 

planning efforts. The following information is summarized from those interviews: 

Three of the seven individuals stated there are currently no other people trained to perform 

their roles. 

Four of the seven individuals stated the Agency has done an effective job at succession planning 

for their positions; one stated he/she was unsure; and two disagreed.

All seven of the individuals stated their knowledge management and sharing included: written 

policies, procedures, or documentation; training other individuals; or a combination of both. 

The Agency has already identified key person dependency as a gap/challenge in the Human Capital Plan. 

The plan states, “unusually high retirement rates and turnover have increased key person dependencies 

and created challenges for succession.” The plan also noted that most offices have employees who 
5 

serve in unique and critical leadership positions or have unique skills that would be difficult to replace. 

The Agency should ensure KPDs are identified to ensure business continuity, knowledge retention, and 

succession planning. 

While Office Directors are responsible for identifying KPDs and preparing action plans for KPDs within 

their respective office, the Agency’s Human Capital Steering Committee is designated in the Human 

Capital Plan to: 

lead the human capital process within the Agency,

determine the formal process for improvements, and

monitor progress. 

Currently, the Human Capital Steering Committee meets on an ad-hoc basis. Because of the informal 

nature and lack of a charter, the Committee is considered more of a group or governance body. There 

may be added benefit to giving the Committee more priority and formalization. The group should 

ensure Human Capital Plans identify and address KPDs and include risk mitigation strategies for those 

positions identified to ensure continuity within the Agency. This could strengthen the human capital 

targets and impact. 

Agreed-Upon Action 1

In order to improve the human capital process at FCA, OMS agreed to: 

1. Formalize the human capital planning process by: 

a. identifying membership (positions) of the Human Capital governance body, 

b. scheduling reviews of the Human Capital Plan objectives, and

c. monitoring and tracking progress toward meeting human capital goals. 

OMS stated the Agency would complete a charter or policy/directive documenting the human capital 

planning process including the items listed above. 

Succession Planning

Shortcomings in KPDs are, in part, mitigated through increasing bench strength, ensuring there are 

employees that could take over the positions. FCA has a challenge in succession planning given the 

current workforce statistics. 

FCA had 311 employees as of July 2015 (including Board members and interns). OE accounts for the 

majority of positions and, therefore, hiring at FCA. Specifically, 192 of FCA employees were examiners 

and staff in the Office of Examination (OE), responsible for the examination and supervision of the Farm 

Credit System. 

Like other segments of the Federal Government and the U.S. workforce, FCA faces an overarching 

challenge, in planning for overcoming the amount of retirement eligibilities in the workforce. Based on 

information provided by FCA’s Office of Management Services (OMS), about 37 percent of FCA’s 

workforce is retirement eligible or will be eligible to retire, in the next five years. This workforce 

predicament places additional emphasis on the need to train and develop staff. 
6 

The FCA workforce can be broken down into three distinct categories in terms of retirement eligibilities: 

less than 10 years, 10-20 years, and more than 20 years until retirement. Data from OMS shows the 

Agency has a disproportionately low percentage of individuals at the Agency who are 10-20 years from 

retirement. While this may not impact FCA in the near future, it does show the uneven distribution of 

staff in the workforce and potential gaps in workforce readiness. The data shows 56 percent of FCA’s 

workforce has less than 10 years before retirement eligibility; only 11 percent of the workforce is in the

10-20 year window; and 33 percent are more than 

20 years from retirement. In addition to the large 

retirement-eligible percentage, there may also be 

shortcomings in personnel with enough experience 

to replace those with less than 10 years until 

retirement eligibility. 

In August 2015, a new recruiting committee was 

formed. In an FCA Board meeting, the committee 

stated its purpose is to: Less than 

10 years

10-20 56% 

years 

11% 

More 

than 20 

years 

33% 

FCA Workforce Based on 

Retirement Eligibilities 

coordinate recruiting efforts, 

identify and implement best practices, 

cultivate relationships, 

broaden diversity in the applicant pool, and

increase visibility and awareness of FCA.

One area of focus for the recruiting committee is to 

assess ways to create more awareness of FCA with 

mid-career hires. To increase the effectiveness of 

recruiting mid-career professionals, FCA could 

benefit from formalizing approaches and monitoring the results and outcomes of its goals. 

FCA stated in the 2014-2018 Human Capital Plan that it was “taking several measures to mitigate KPD 

risk such as cross-training, external hiring, and creating pools of management and leadership talent.” 

However, in order for the action plan to be effective, FCA needs to specify and also monitor the progress 

of the actions on a regular basis. For example, the Agency stated cross-training was a measure to 

mitigate KPD risk. The plan also stated it “may establish more robust processes for transferring 

knowledge from employees who are near retirement to other employees.” To understand the progress 

made, the Agency could gather quantitative and/or qualitative data to measure progress. For example, 

gather information on how many cross training efforts take place; how many leadership development 

programs were completed; or how many external hires were realized.

Agreed-Upon Action 2

In order to improve succession planning, OMS agreed to: 

2. Track data on succession planning efforts. Document the strategies to mitigate the risks. 

Monitor and follow-up to capture and utilize results. 

OMS stated it would determine the best way to track FCA’s succession planning efforts and document 

the strategies to mitigate risks, monitor progress, and capture results. 
7 

Development and Training Programs

The Agency continues to have opportunities to develop newly hired personnel and emerging leaders. 

Currently, a few FCA personnel are selected for leadership and training programs. An analysis of FCA’s 

leadership development programs revealed many staff did not apply for these opportunities and FCA did 

not use all leadership tools available.

According to data provided by OMS from the FCA FedHR Navigator system, FCA developed four 

announcements for leadership/training programs for FYs 2012-2015, three for the Office of Examination 

Leadership Development Program, and one for the Upward Mobility Program. We found these 

programs were not being fully utilized by staff as a development path. In total, only nine people applied 

to the four announcements; for three of the programs, only one person applied for the position. Eight 

were designated as qualified and five were selected, although three of those individuals were selected 

for one of the announcements. 

Due the specialization of the programs, many employees were not eligible to apply for these programs. 

For example, the OE Leadership Development Program was only available to OE commissioned 

examiners at the VH-38/39 level. Also, the Upward Mobility Program was announced only at the VH 30-

35 level. Recognizing there are on-the-job and external opportunities for training and development, 

further exploration of the need for adding emerging leadership opportunities for a wider scope of 

employees would be informative, as would examining reasons why so few applied to the programs in 

the past. 

In addition, FCA is not utilizing other development/training programs described in: 

PPM 853, Supervisory Development Program, states a career opportunity announcement would 

be issued annually at the beginning of the fiscal year and remain open for a minimum of six 

weeks. According to the vacancy announcement log provided by Human Resources, FCA has not 

issued this announcement in FYs 2012-2015. 

PPM 854, Mentoring Program, states OMS will issue an opportunity announcement for the 

mentoring program. FCA has not issued this announcement in FYs 2012-2015. 

Agreed-Upon Action 3

In order to improve the effectiveness of leadership and development programs, OMS agreed to: 

3. Assess organizational leadership and development programs and modify to promote, enhance,

and improve initiatives within the Agency. 

OMS stated it would review current programs related to leadership development and determine what if 

any changes need to be made. 

Employee Hiring and Separations

Each month, OMS informs management and personnel of current staffing levels compared to the 

previous five years. These monthly status reports also show accessions, promotions, separations, and 

staffing actions. In order to examine hiring and separations, we requested hiring and separation data 
8 

from FY 2010 through June 30, 2015. We separated the data into two different categories: interns and 

non-interns. The data showed:

FCA hired 138 non-intern employees

142 non-intern employees separated from the Agency

70 interns were hired 

We examined this data in the context of diversity in hiring, as well as the impact of exit interviews in the 

context of separations. 

Hiring

With respect to hiring, FCA provides training to personnel to recruit examiners and interns for OE. This

training includes instruction on how to promote the Agency to potential candidates, as well as details on 

the recruiting process. FCA has also launched a new recruiting committee to aid in developing recruiting 

initiatives. 

As part of an outreach effort for hiring, OMS implemented a new process attempting to enhance 

diversity in the hiring pool. FCA sends job announcements to emphasis groups identified by the Office 

of Personnel Management (OPM). The desired outcome aims at establishing a network of partners and 

organizations. FCA began issuing its announcements to several groups from the OPM list and created a 

distribution network list where the FCA job announcements would go out to the points of contact on the 

list. FCA’s distribution list contains three emphasis groups: 

Asian Americans, 

Indian Americans, and 

Lesbian, Gay, Bisexual, and Transgender. 

FCA’s list identified business groups such as the National Association of Asian MBAs and the Native 

American Finance Officer Association. However, from these three groups identified above, 26 of the 94 

points of contact on the list pose a challenge in deciphering relevancy to FCA jobs. For example, there 

were eight points of contact for medical professionals, 16 points of contact for law enforcement groups, 

and two for educational groups. It appears there is an opportunity to review pertinent points of contact 

and to expand the list to additional points of contact and relevant areas for FCA jobs and skillsets. 

Additionally, the EEOI Director stated FCA’s Special Emphasis Program managers each have their own 

network lists and reach out to their groups with job announcements. However, there appeared to be no 

coordination between the special emphasis lists and process and the new network list. Increased 

coordination and revision of the distribution list may increase the effectiveness of the outreach 

methods, and potentially increase diversity in the pool of applicants. Further, additional coordination 

between EEOI and OMS personnel may increase the effectiveness of overall human capital efforts. 

Separations

We also examined staffing data for separating employees. Between FY 2010 and June 30, 2015, FCA had 

142 employees separate from the Agency (excluding interns). FCA has a policy aimed at gathering 

information from exiting employees and maintains an exit questionnaire database with detailed 

questions. 
9 

The exit questionnaire asks for answers that potentially bring forth valuable information, such as:

What the person will be doing when they leave (retiring, other Federal agency, private sector)

Factors influencing their decision to leave

Opportunities and benefits available at gaining organizations

Supervision and recognition at FCA

FCA’s PPM 834, Exit Procedures, states an employee who is leaving the Agency will “complete and 

submit an electronic exit questionnaire.” OMS is required to, “ensure an electronic employee exit 

questionnaire is provided to each employee upon notification of his/her intent to separate from the 

Agency” and “ensure that all necessary clearances are obtained on the Form 302 (Employee Checkout 

Record)”. The Employee Checkout Record includes an exit interview with each separating employee. 

We found the Agency is not using separation information to the greatest extent possible.

Summaries from the questionnaire responses combine all responses and contain duplicates, 

making it difficult to analyze annual results. Improvements to the database to eliminate 

duplicates and separate the data by years would provide a more reliable and useful summary of 

the data.

OMS was not able to provide the verification that five of the eight separations sampled were 

handled in accordance with PPM 834.

There was confusion on the exit interview process with regard to who was performing the 

interview and how the process worked.

Exit interviews were inconsistent. Based on summaries provided by OMS, basic information was 

captured such as likes and dislikes about positions, but lacked consistent questions. Although 

the interviews are a fundamental way to capture information, inconsistent questions do not 

afford the effective trending of the data. 

There is currently no process to disseminate the results of the exit interviews or questionnaire 

results. The information could provide affirmation of effectiveness of FCA operations. It could 

likewise be used as a tool in developing strategic and operating plans.

With accurate and consistent methods to collect, analyze, and distribute the information collected from 

exiting employees, the data would potentially have greater use for planning.

Agreed-Upon Actions 4-6

In order to improve the hiring and attrition process, OMS, in coordination with the EEOI Director, agreed 

to: 

4. Coordinate and revise the network distribution list for FCA job announcements. 

5. Increase coordination between OMS and EEOI on special emphasis programs and outreach. 

6. Implement a plan to improve the exit interview process and disperse exit interview data to 

gather consistent, useful information for comparison and trends. 
10

OMS stated it would coordinate with the EEOI Director to update the network distribution list for FCA 

job announcements and increase coordination on special emphasis programs and outreach. OMS stated 

it would also develop a process to improve the exit interview process and gather the information for 

analysis and reporting, where appropriate. 

Workplace Diversity and Inclusion

FCA has an Equal Employment Opportunity and Inclusion (EEOI) program. FCA has an EEOI Director who 

reports directly to the FCA Chairman of the Board. Written policy statements, policies and procedures, 

and a performance element in every employee’s performance plan relating to EEO and diversity, are 

components of the EEOI Program. 

The Agency also has five special emphasis programs led by FCA employees under the direction of the 

EEOI Director in the following areas:

Blacks in Government 

Federal Women’s Program

Hispanic Organization for Leadership and Advancement

Persons with Disabilities Program

Asian American and Pacific Islander Program 

Although the Agency voices a desire to improve diversity and become more inclusive, improvements can 

be made. We identified several opportunities for improvement in FCA’s human capital efforts to 

promote increased diversity and inclusion in the workplace. 

FCA’s overall percentages of veteran, female, and minority representation have been decreasing over 

the last few years. Our review of data provided by OMS shows that FCA hired 138 non-intern employees 

for the FY 2010-June 2015 period. The hiring included a 38 percent female representation and 24 

percent minority representation. OE accounted for 58 percent of the total hiring, with a 29 percent 

female representation and 15 percent minority representation. Overall, 28 veterans were hired. 

FCA hired 70 interns for the same period with a 44 percent female representation and 34 percent 

minority representation. OE accounted for 80 percent of the intern hires. The data showed no veterans 

were hired as interns. 

We also reviewed historical information, current FCA data, and various reports to compile statistics for

veteran, females, and minority representation at FCA from 2010 through June 2015. We found the 

following:

For veterans’ representation, FCA made improvements from 2010 to 2012 and increased the 

representation from 7.7 percent to 12.9 percent. However, there has since been a decrease to 

11.37 percent as of June 2015.

For female representation, there was an increase from 2010 to 2011 from 41.46 percent to 

43.43 percent, but a decrease from 2011 to 2015 to 40.8 percent. 

For minority representation, there was an increase from 2010 to 2012 from 19.16 percent to 

22.19 percent and then a decrease from 2012 to 2015 to 21.07 percent. 
11

Due to the relatively small numbers of employees in the FCA universe, FCA’s statistics can fluctuate with 

just one or two employee changes in representation. For example, the percentage of minority 

representation declined in 2015 even though there was one more minority within FCA. The decrease in 

overall representation was due to the increased number of hires with less minority representation. The 

data shows the same for female representation. There were four more females overall in 2015; 

however, the overall percentage declined because of the additional hires and the effect on the

percentage of representation. Despite these fluctuations, hiring data and overall representations show 

areas of opportunity for minority and female representation at FCA. 

Another potential area of improvement is veteran representation. FCA utilizes the Federal Pathways 

Program for hiring interns. This program was initiated by the President, in part, to preserve Veterans’ 

Preference rights. FCA reported in its 2014 Disabled Veterans Affirmative Action Program Report that 

half of the Agency’s veteran employees were eligible to retire over the next four years. This increases 

the need for the Agency to focus on veteran hiring. As noted above, there were no veteran hires in 

FCA’s intern program. Also, while FCA has various special emphasis programs, there is no veterans’ 

representative or point of contact for recruitment of veterans within the Agency. 

Applicant Data Collection

Applicant flow data is another factor that impacts diversity and inclusion efforts and therefore should be 

evaluated in the context of human capital planning. Applicant flow data is demographic information 

gathered on applicants responding to job announcements. On March 3, 2010, the U.S. Equal 

Employment Opportunity Commission (EEOC) and OPM issued a joint memorandum on applicant flow 

data emphasizing applicant data collection as an important tool in examining the fairness and 

inclusiveness of the Federal government’s recruitment efforts. The memorandum also stated that by 

reviewing this data, organizations can reassess and improve efforts to reach all segments of our 

population. OPM strongly supported the collection of optional demographic data. 

Applicant flow data can vary depending on how it is collected. For example, data can be collected for 

each phase of the hiring process through selection or exclusively at the application phase. Demographic

information on applicants includes: 

how the applicant learned about the position, 

sex, 

ethnicity, 

race, and

disability/serious health condition. 

It is important to note that applicant flow data is gathered from applicants who respond to such 

questions on a voluntary basis. 

In terms of sources from which FCA could obtain applicant flow data, there are two systems used for 

FCA job announcements. For all positions except entry-level examiner positions, FCA uses the FedHR

Navigator system as an internal system. For entry-level examiner positions, FCA utilizes an outside OPM

system. The main difference between applicant flow data generated by these two systems is the OPM 
12

data follows the applicant information from application to selection, whereas, the FedHR Navigator 

system only collects applicant information1

. 

FedHR Navigation System Data

For the data in the FedHR Navigator system, limited applicant flow data is currently available. According 

to OMS, the data provided was available through an EEO reporting tool, which was not used by FCA in 

the past. The data, obtained for this audit, contained applicant data for 85 of FCA’s announced 

positions. The FedHR Navigator System reported the data by race, ethnicity, and gender. The data 

showed there was an average response rate of 51 percent of those applicants that disclosed 

demographic information. The FedHR Navigator system reported the data by race, ethnicity, and 

gender. 

Even limited data includes information the Agency can use to improve diversity and inclusion efforts. 

For example, of those applicants that declared gender, there was not a large deviation (46 percent 

female and 54 percent male), but more men applied to the positions than women. This may mean a 

targeted emphasis on attracting women should ensue. Likewise, the limited data shows the Agency also 

has an opportunity to improve the applicant pool for minority representation and ethnicity diversity.

OPM System Data

We also reviewed applicant flow data from the OPM system. FCA requested applicant flow data for 

three jobs announced utilizing the OPM system, which contained demographic information. The data 

showed there were 728 total applicants for the three vacancies that disclosed race and national origin 

information and/or gender, which was 53 percent of the total applicants. The OPM reports show this

data by race/national origin and gender. 

The data shows there are areas where FCA could improve. For example, the more detailed data on race 

and national origin shows that while FCA began with a relatively diverse pool of candidates in terms of 

race and national origin, the personnel ultimately selected for the positions did not reflect the same 

diversity levels. In addition, the gender data shows that of those candidates that declared gender, there 

were less females applying to the positions than males. Recognizing there are applicants who drop out 

of the process or are eliminated for lack of basic qualifications at early stages, the collection of 

demographic information can provide data and aid the Agency in pinpointing places along the 

continuum of hiring where further analysis may provide opportunities to improve diversity and 

inclusion. While there are many factors considered in the hiring process to ensure the best qualified 

candidates are selected, the Agency can use the data as a tool for evaluating candidate consideration 

and exclusion in the hiring process.

 

1 For this audit, we reviewed applicant flow data from both of these systems utilized by FCA. For the FedHR

Navigator system, we received a report from OMS that used the EEO Summary Report tool on the system. This 

data set was limited to August 2011 through April 2015 announcements, excluding the OPM system 

announcements, and was limited to applicant information only. Because of the limitations of the data, it cannot 

be projected to all FCA announcements and applicants. The data set was also limited to only those that declared 

demographic information, and as noted above, this was voluntary for applicants. For the OPM system, we 

received a report on applicant flow data for three examiner positions announced in October 2014, January 2015, 

and March 2015. There are inherent limitations to the data that include the limited amount of announcements 

and the response rate of the demographic information because, again, the responses were voluntary for 

applicants. Therefore, the data also cannot be projected to all FCA announcements and applicants.
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Barrier Analysis

At the time of our fieldwork, FCA was not consistently using either the FedHR Navigator system or OPM 

system to collect or analyze applicant flow data. Although during our audit FCA requested applicant 

flow data on three jobs announced in the OPM system, FCA has no established process to request and 

analyze any applicant flow data. The Agency has not done so because, as FCA stated in its required 

annual equal opportunity report, “the agency had sufficient resources to enable the agency to conduct a 

thorough barrier analysis of its workforce, including the provision of adequate data collection and 

tracking systems.” The Agency also stated in its Hispanic Employment Report for 2014, “given the size of 

the Agency and with few vacancy announcements, the applicant flow data would not produce sizeable 

data for meaningful analysis.” We disagree. 

A barrier analysis is an assessment to monitor progress and identify areas where barriers may operate to 

exclude or disadvantage any group based on gender, race, ethnicity or disability. EEOC has determined 

that applicant flow data is demographic data that is an integral part of the barrier identification process. 

According to the EEOC, a barrier analysis allows the organization to “reassess and improve its efforts to 

reach all segments of our population.” As a result, collecting such data consistently would provide a 

solid foundation and be the first step to identify opportunities for improvement. For example, applicant 

flow data can provide details on diversity of the applicant pool, which can assist recruiting efforts. The 

data can also show potential barriers that exclude certain groups. It could also demonstrate areas

where training may be needed to address these barriers. Data can show demographic areas 

underrepresented and increase knowledge and awareness of hiring practices. Overall, when collected 

and compared, applicant flow data could be useful in analyzing potential barriers in the various stages of 

the hiring process. 

While no conclusions have been reached given the limitations of the data (percent declared, number of 

announcements, etc.), the data does show areas for potential improvement with the Agency’s recruiting 

and hiring efforts. One potential mechanism for improvement would be an in-depth review of the 

Agency’s hiring practices by a group, such as OPM’s Human Resources Solutions, or an internal review. 

An assessment could help determine if there are potential barriers within FCA’s process, in the initial 

application process, or in the subsequent processing of applications causing the diversity in the initial 

applicant pool to dissipate somewhere along the selection process. The assessment could target areas 

for potential improvement. 

Other agencies have contracted for a barrier analysis. The National Credit Union Administration’s OIG 

reported in its response to the Congressional request in March 2014 (as noted on page 2) that the 

agency contracted for expert professional services for an agency-wide barrier analysis to identify and 

eliminate any barriers that may exist that are impeding free and open competition in the workplace. 

FCA does not have an established process to request and analyze applicant flow data. FCA has not 

initiated an ongoing process to request and analyze all applicant flow data. It remains unclear whether 

FCA will continue to request the information; who would request the information; and how the 

information would be analyzed and subsequently disseminated. In order for this information to be 

effective and useful, FCA will need to decide which office will be responsible for requesting and 

analyzing the data. An effective dissemination method will need to be utilized in order for hiring 

managers and Agency personnel to realize the effects of their efforts and address areas that need 

improvement.
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Given the current trends and applicant flow information, the Agency may also benefit from a more 

focused, mandatory training in recruiting and hiring practices for employees involved throughout the 

process to address any potential barriers to diversity during the selection process. FCA did conduct a 

brown bag lunch event on unconscious biases in FY 2015. However, the event was not mandatory for 

those involved in the hiring process. While this event is useful and meaningful, FCA could benefit from 

additional training in this area.

Survey

Finally, given the data presented, an Agency-wide survey on workplace diversity and inclusion could be 

useful. The EEOC states that a climate survey can help agencies assess the pulse of their workforce and 

make changes. Issuing a survey to employees on workplace diversity and inclusion can help identify 

areas of concern or emphasis for current employees. The survey results could also assist in developing 

revised or new human capital strategies and solicit ideas from employees on areas of possible 

improvement. 

Annually, along with most of the Federal Government, FCA participates in the Federal Viewpoint Survey. 

This survey includes questions related to diversity. For 2015, FCA had an 87.2 percent response rate. 

The following positive responses were given to workplace diversity and inclusion questions:

Question 34: Policies and 

programs promote 

diversity in the workplace77.51 percent positive

Question 38: Prohibited 

personnel practices are not 

tolerated-74.73 percent 

positive

Question 45: My 

supervisor is committed to 

a workforce representative 

of all segments of society76.98 percent positive

Question 55-Supervisors 

work well with employees 

of different backgrounds67.14 percent positive

Although these questions relate to workplace diversity and inclusion, FCA may benefit from a more 

targeted survey, or other information-gathering tool, specific to FCA to further improve efforts. For 

example, Question 34 on the viewpoint survey asks employees if policies and programs promote 

diversity in the workplace (for example, recruiting minorities and women, training in awareness of 

diversity issues, mentoring). According to the EEOI Director, FCA is currently working to gather 

information on potential questions for a survey. 

 
15

Agreed-Upon Actions 7-11

In order to improve the human capital challenge area of workplace diversity and inclusion, OMS, in 

coordination with the EEOI Director, agreed to: 

7. Consider a veterans’ representative for Agency veteran efforts.

8. Provide training to all personnel involved in the recruiting and hiring process on potential biases 

and barriers to employment.

9. Conduct an assessment of FCA hiring practices to identify potential barriers and areas of 

improvement.

10. Establish a policy that includes the plan for requesting and analyzing applicant flow data for FCA 

job announcements.

11. Conduct a survey, or use other information-gathering tools, to gather additional targeted 

information on workplace diversity and inclusion.

OMS stated it would work with the EEOI Director regarding the veterans’ representative and would 

provide documentation that shows the results of the decision. OMS also stated a current training 

program would be updated and/or expanded for staff involved in the recruiting and hiring process. 

OMS will also do an internal assessment or seek an outside source to do an assessment of hiring 

practices and will develop a process on how applicant flow data will be gathered, analyzed, and 

reported. OMS stated it would also work with the EEOI Director to determine an information gathering 

process/plan to obtain workplace diversity and inclusion information. 
16

OBJECTIVE, SCOPE, AND METHODOLOGY

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

effectiveness of its implementation. We conducted fieldwork at FCA’s Headquarters in McLean, VA from

April 2015 through December 2015. We limited our scope to FCA’s human capital implementation

efforts from FY 2011-2015 and planning efforts for FY 2016-2020. 

We took the following steps to accomplish the objectives: 

Identified and reviewed applicable Federal laws, regulations, OMB policy, and other 

guidance related to the objectives. 

Reviewed prior audits, inspections, evaluations, and reviews related to human capital 

planning. 

Conducted interviews with the Chief Human Capital Officer, Human Resources personnel, 

the Equal Employment Opportunity and Inclusion Director, Training Officer, and selected 

personnel identified as key person dependencies. 

Identified and reviewed applicable internal FCA policies and procedures.

Reviewed current employee statistics for retirement based on information issued to Office 

Directors for the human capital call as of June 2015. 

Reviewed positions identified as key person dependencies. We judgmentally sampled 7 of 

the 30 individuals listed as key person dependencies based on the type of dependencies and 

mitigating factors. We also considered the office the person worked in and retirement 

eligibility. Because the sample is judgmental, it cannot be projected over the entire 

population. 

Analyzed hiring and separation data from 2010 through June 2015 compiled by OMS. 

Sampled exit interview records and questionnaire results. 

Reviewed and analyzed FCA’s diversity and inclusion initiatives. We analyzed workplace 

statistics compiled by OMS and compared the data to overall representation numbers based 

on historical reports of FCA’s workforce. 

Analyzed applicant flow data received on examiner and non-examiner positions. 

This audit was performed in accordance with the 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 

assessed internal controls and compliance with laws and regulations to the extent necessary to satisfy 

the objectives. Because our review was limited, it would not necessarily have disclosed all internal 

control deficiencies that may have existed at the time of our audit. We assessed the computerprocessed data relevant to our audit objectives through comparing multiple types of data to various 

sources and assessing risk. We determined that the data was sufficiently reliable. We assessed the risk 

of fraud related to our audit objectives in the course of evaluating audit evidence. Overall, we believe 

the evidence obtained provides a reasonable basis for our conclusions based on our audit objectives. 
17

ACRONYMS

EEOI Equal Employment Opportunity and Inclusion

FCA Farm Credit Administration

FCS Farm Credit System

FY Fiscal Year

OE Office of Examination

OIG Office of Inspector General

OMS Office of Management Services

OPM Office of Personnel Management
REPORT

Fraud | Waste | Abuse | Mismanagement

FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

Phone: Toll Free (800) 437-7322; (703) 883-4316

Fax: (703) 883-4059

E-mail: fca-ig-hotline@rcn.com

Mail: Farm Credit Administration

Office of Inspector General

1501 Farm Credit Drive

McLean, VA 22102-5090