DOD Civilian Personnel: Intelligence Personnel System Incorporates Safeguards, but Opportunities Exist for Improvement
Published: 2009-12-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Since 2001, Government Accountability Office (GAO) has designated strategic human capital management as a high-risk area because of the federal government's long-standing lack of a consistent approach to such management. In 2007, the Under Secretary of Defense for Intelligence (USD(I)) began developing a human capital system--called the Defense Civilian Intelligence Personnel System (DCIPS)--to manage Department of Defense (DOD) civilian intelligence personnel. In response to a congressional request, GAO examined the extent to which DOD has (1) incorporated internal safeguards into DCIPS and monitored the implementation of these safeguards and (2) developed mechanisms to identify employee perceptions about DCIPS. GAO analyzed guidance, interviewed appropriate officials, and conducted discussion groups with employees at select DOD components. At the end of GAO's review, legislation was enacted that impacts, among other things, how DCIPS employees will be paid.
section_title: What GAO Found
paragraphs: While early in its implementation of DCIPS, DOD has taken some positive steps to incorporate 10 internal safeguards to help ensure the fair, effective, and credible implementation of the system; however, opportunities exist to immediately improve the implementation of two of these safeguards, and continued monitoring of all is needed. For example, one safeguard requires employees to be trained on the system's operations, and GAO noted that DOD had provided extensive training to employees on DCIPS to include several Web-based and classroom courses. For another safeguard--which requires ongoing performance feedback--GAO noted that DOD's guidance requires feedback between employees and supervisors at the midpoint and at the close of the performance rating cycle. However, GAO determined that in the case of two safeguards--involving employees and fully implementing the merit principles--DOD could immediately improve its implementation. First, while DOD has leveraged mechanisms like town hall meetings and "brown bags" to involve employees in DCIPS, its guidance does not identify a formalized process for the continuous involvement of employees in the system implementation--which could ultimately undermine its credibility. Second, while DOD has stated that it will conduct an analysis of final ratings utilizing demographic data, DOD does not have a written policy outlining how this will be accomplished, and therefore may be unable to fully determine whether potential barriers to fair and equitable ratings exist. Without steps to improve implementation of this safeguard, employees may lack confidence in the system. Finally, GAO previously reported--for systems like DCIPS--that continued monitoring of such systems' safeguards is needed to help ensure agency actions are effective. In October 2009, DOD provided GAO with a draft DCIPS evaluation plan that would be executed after the first payout in January 2010. Without finalizing and executing the plan, DOD will not know if it has achieved desired outcomes from the system. DOD has used several mechanisms to provide employees with information; however, these mechanisms do not comprehensively identify and address employee perceptions of DCIPS. For example, USD(I), among other things, maintains a Web-site that contains frequently asked questions submitted by employees and responses by USD(I). Absent, however, are mechanisms to systematically identify employee perceptions. The nongeneralizable results of the discussion groups GAO conducted with employees and supervisors yielded mixed views. For example, participants generally expressed positive views about the concept of pay for performance. But participants at most of the Intelligence Components noted that DCIPS was being implemented too quickly or many questions went unanswered. Although DOD officials have drafted surveys that will allow them to more comprehensively collect employee perceptions about DCIPS, these surveys lack questions that would provide insight about employee perceptions of certain safeguards and overall acceptance of DCIPS. Without including such questions and expeditiously implementing its surveys, DOD will not have clear insight into employee perceptions.

section_title: Letter
paragraphs: Since 2001, we have designated strategic human capital management as a  high-risk area because of the federal government’s long-standing lack of a  consistent approach to such management.  We have previously reported  that strategic human capital management can be a powerful lever for  affecting transformational change.  Additionally, in our 2009 High-Risk  Series update, we identified the importance of having committed and  sustained top leadership in agencies across the federal government to  address this challenge and of developing a clear linkage between  individual employee performance and organizational success to create and  maintain a more results-oriented, customer-focused, collaborative, diverse,  and inclusive workforce.  In a 2008 report to Congress, the Office of the  Director for National Intelligence (ODNI) noted that, in the aftermath of  the terrorist attacks of September 11, 2001, and prior to Operation Iraqi  Freedom, congressional and presidential reviews identified significant  institutional, cultural, and organizational factors that impeded the  Intelligence Community from operating in an effective and collaborative  manner.  As an  example, the report noted that one such review  concluded that the U.S. Intelligence Community (1) had failed to  encourage joint personnel assignments that could break down cultural  barriers and foster collaboration amongst the various intelligence  agencies; (2) contained personnel systems that were ill-suited to hire and  retain the most talented young people, who could often earn far more  money outside the government; and (3) had compensation systems—like  the General Schedule System—that were too often tied to “time-in-grade,”  rather than demonstrated achievement.  The commission recommended,  among other things, that ODNI establish a central human resources  authority for the Intelligence Community; create a uniform system for  performance evaluations and compensation; and develop a more  comprehensive and creative set of performance incentives. To this end,  both ODNI and the Under Secretary of Defense for Intelligence (USD(I))— the primary organization responsible for development and oversight of  DOD’s intelligence community personnel system—have consistently  emphasized their commitment to reforming and modernizing the disparate  personnel systems used throughout the Intelligence Community.
Specifically, as part of a comprehensive approach to consistently  modernize compensation across the U.S. Intelligence Community, ODNI  has taken steps to develop a pay modernization framework to help prevent  inequality in pay, ensure a level playing field, help the Intelligence  Community compete with the private sector for employees with critical  skills, and retain a competitive workforce. ODNI officials stated that this  pay modernization framework will also help bring the U.S. Intelligence  Community closer together and act as a true community and not simply an  association of agencies with similar and related missions.  According to  ODNI officials, to address the personnel challenges in the Intelligence  Community that mirror those found throughout the rest of the executive  branch, the Director of National Intelligence launched the National  Intelligence Civilian Compensation Program.  Further, according to these  same officials, the National Intelligence Civilian Compensation Program is  a modern performance management and pay-for-performance initiative for  the U.S. Intelligence Community, which is intended to replace the existing  obsolete compensation systems used in much of the U.S. Intelligence  Community.  Specifically, the National Intelligence Civilian Compensation  Program is an overarching framework established by various Intelligence  Community directives, which sets forth common performance  management and pay rules for this community. See appendix I for a  detailed discussion of the National Intelligence Civilian Compensation  Program.  Using this framework, among other things, USD(I), in 2007,  began developing a human capital system—called the Defense Civilian  Intelligence Personnel System (DCIPS)—to manage civilian intelligence  personnel in the Department of Defense (DOD) intelligence components.   The statutory authority for this system originated in the National Defense  Authorization Act for Fiscal Year 1997, which provided DOD the  authority to create a pay-for-performance system for the defense  Intelligence Community—the National Geospatial-Intelligence Agency was  the first DOD organization to implement this authority in 1998.  In 2006,  the ODNI, in partnership with all of the elements of the U.S. Intelligence  Community, adopted the National Geospatial-Intelligence Agency’s piloted  model in its design.
In 2008, the Senate Armed Services Committee asked us to review the  implementation of DCIPS.  In response to this request, we examined the  extent to which DOD has (1) incorporated internal safeguards into DCIPS  and monitored the implementation of the safeguards and (2) developed  mechanisms to identify employee perceptions about it.
At the end of GAO’s review, legislation was enacted that contains  provisions that affect DCIPS. Specifically, provisions of the National  Defense Authorization Act for Fiscal Year 2010 suspended the fixing of  “rates of basic pay” under DCIPS “for employees and positions within any  element of the Intelligence Community,” except for the National  Geospatial-Intelligence Agency.  The act also required “rates of basic pay”  to be fixed in accordance with provisions of law that (disregarding DCIPS)  would otherwise apply, during the period beginning on the date of the  enactment of the defense authorization act and ending on December 31,  2010.  The act further required the Secretary of Defense, the Director of  the Office of Personnel and Management, and the Director of National  Intelligence to jointly designate an independent organization to review the  operation of DCIPS.  The Secretary of Defense, the Director of the Office  of Personnel and Management, and the Director of National Intelligence  are required, under the act, to submit to the congressional oversight  committees a written report describing any actions that the Secretary has  taken or proposes to take in response to the report of the independent  organization. Additionally, the provisions require the Secretary of Defense  to submit to the congressional oversight committees a written description  of any actions taken or proposed to be taken by the Secretary in response  to GAO’s review and recommendations regarding DCIPS. On November 3,  2009, the USD(I) stated in a memorandum to the defense intelligence  workforce, that the legislation did not repeal or terminate DCIPS, but  suspended certain provisions of the DCIPS pay-setting regulations until  December 31, 2010. The memorandum further noted that the National  Geospatial-Intelligence Agency would be the only defense intelligence  component to continue under all DCIPS regulations—including all of the  performance-based pay adjustment processes included in the regulations.   According to the memorandum, eligible employees in the remaining  intelligence components will not receive a payout under DCIPS but will  receive scheduled increases equivalent to step increases under the General  Schedule structure, as well as the full General Pay Increase and locality  pay, in January.
To address our first objective, we analyzed guidance issued by the  Director of National Intelligence and the USD(I) and interviewed key DOD  officials to determine the extent to which DOD has incorporated internal  safeguards identified in our prior work on human capital management  issues. Specifically, we assessed the extent to which DOD has  incorporated the following 10 performance management safeguards:      Assure that the agency’s performance management system links  employee objectives to the agency’s strategic plan, related goals, and  desired outcomes.  Implement a pay-for-performance evaluation system to better link  individual pay to performance and provide an equitable method for  appraising and compensating employees.
Provide adequate training and retraining for supervisors, managers, and  employees in the implementation and operation of the performance  management system.  Institute a process for ensuring ongoing performance feedback and  dialogue between supervisors, managers, and employees throughout  the appraisal period and setting timetables for review.
Assure that the agency’s performance management system results in  meaningful distinctions in individual employee performance.
Provide a means for ensuring that adequate agency resources are  allocated for the design, implementation, and administration of the  performance management system.
Assure that there is an independent and credible employee appeals  mechanism.
Assure that there are reasonable transparency and appropriate  accountability mechanisms in connection with the results of the  performance management process, including periodic reports on  internal assessments and employee survey results relating to  performance management and individual pay decisions while  protecting individual confidentiality.
Involve employees in the design of the system, to include employees  directly involved in validating any related implementation of the  system.
Adhere to merit principles set forth in section 2301 of title 5 of the U.S.
Code. (For example, section 2301 (b)(2) deals with fair and equal  treatment, regardless of factors such as political affiliation, race, color,  sex, age, or handicapping condition and section 2301 (b)(8)(A) says  that employees should be protected against arbitrary action, personal  favoritism, and coercion for partisan political purposes.) (The merit  principles are listed in their entirety in appendix II.)
To address our second objective, we examined the extent to which DOD  had mechanisms in place to identify employee perceptions about DCIPS  and reviewed DOD surveys and information about DCIPS on defense  intelligence component Web sites. We also reviewed town hall meetings  about DCIPS and interviewed headquarters level DCIPS staff responsible  for implementing DCIPS at each of the nine defense intelligence  components and the Defense Security Service. To obtain insight into  employee perceptions and opinions of DCIPS, we visited seven DOD  intelligence components and conducted 26 nongeneralizable discussion  groups.  For each of the seven DOD intelligence components, we  conducted separate discussion groups for employees and supervisors both  in the Washington, D.C., area at each organization’s headquarters, as well  as at three field locations in the United States to determine if employee  perceptions varied by location.  While the information from our  discussion groups is not generalizable to the entire population of DOD  civilian intelligence personnel, this information provides insight into  civilian intelligence personnel perceptions about the implementation of  DCIPS.  However, other employees and supervisors under DCIPS who did  not participate in our discussion groups may have different perceptions.
We conducted this performance audit from November 2008 through  November 2009 in accordance with generally accepted government  auditing standards. Those standards require that we plan and perform the  audit to obtain sufficient, appropriate evidence to provide a reasonable  basis for our findings and conclusions based on our audit objectives. We  believe that the evidence obtained provides a reasonable basis for our  findings and conclusions based on our audit objectives. A more thorough  description of our scope and methodology is provided in appendix III.
subsections: section_title: Background
paragraphs: The authority for DOD to establish a pay-for-performance management  system for civilian defense intelligence employees originated in the  National Defense Authorization Act for Fiscal Year 1997.  Initially, in  1998, only the National Geospatial-Intelligence Agency implemented Full  Pay Modernization for its employees.  Specifically, the Office of the  Secretary of Defense granted the National Geospatial-Intelligence Agency  the authority to pilot test a pay-for-performance system. The National  Geospatial-Intelligence Agency eventually converted all of its employees  out of the General Schedule pay scale and into a system it called Total Pay  Compensation in 1999 and thus has been under that system for about 10  years.
As stated previously, ODNI, with agreement from agencies and  departments in the Intelligence Community, established the overarching  evaluation and performance based pay framework for this community—  the National Intelligence Civilian Compensation Program.  This framework  was established by Intelligence Community Directives, which among other  things, set common rating categories and performance standards that were  adopted by the Intelligence Community.  According to Intelligence  Community Directive 650, the Director of National Intelligence has the  responsibility to establish, in collaboration and coordination with the  heads of executive departments and independent agencies with  Intelligence Community employees, a set of unifying Intelligence  Community-wide principles, policies, and procedures governing the  compensation of civilian employees in the Intelligence Community.   DOD, in 2007, designated USD(I) as the organization responsible for  overseeing the implementation of DCIPS. USD(I) based DCIPS primarily  on the pay-for-performance system implemented at the National  Geospatial-Intelligence Agency. Appendix IV shows the notable  differences between the National Geospatial-Intelligence Agency’s system  and DOD’s DCIPS. Additionally, figure 1 outlines the U.S. Intelligence  Community’s pay modernization efforts under the National Intelligence  Civilian Compensation Program framework. DCIPS is one of the first  systems to use this framework.
DCIPS will be the performance management system applicable to DOD  civilian intelligence personnel in the DOD intelligence components, which  include the Defense Intelligence Agency, the National Geospatial- Intelligence Agency, the National Reconnaissance Office, the National  Security Agency, the Office of the Under Secretary of Defense for  Intelligence, and the intelligence elements of the military departments.
Although not a defense intelligence component, the Defense Security  Service also converted to DCIPS.
Implementation of DCIPS pay-for-performance began in September 2008  and consists of three specific phases: (1) Performance Management,  which focuses on the processes of setting expectations and objectives for  monitoring, rating, and rewarding employee performance; (2) Pay Bands,  which moves employee pay from the General Schedule/Government Grade  pay scale to the five pay ranges associated with a particular DCIPS work  category and work level; and (3) the First Performance Payout, which is  when employees will receive a combination of their performance-based  salary increase and their performance-based bonus increase for the first  time. The DOD components have implemented DCIPS, in some instances,  at different times.  Figure 2 depicts the timeline, at the time of our review,  for each component’s phased implementation.
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Under DCIPS, performance management consists of two interrelated  processes: the performance management process and the pay pool  process.The performance management process includes a 12-month  performance evaluation period that runs annually from October 1 through  September 30, unless USD(I) has granted an exception. During this period,  employees, along with their supervisors—who are also referred to as  rating officials—collaborate to identify performance expectations and  outcome-focused objectives; engage in regular dialogue to monitor  performance throughout the year, including a required mid-point review;  develop performance strengths and skills; document achievements  through employee self-assessments and rating official assessments; and,  finally, conduct an end-of-year performance review.  At the end of the  performance evaluation period, the rating official completes an evaluation  of record for each of the employees they supervise. These evaluations of  record are then passed through two levels of review: first by reviewing  officials and then by the Performance Management Performance Review  Authority. Reviewing officials are responsible for coordinating with rating  officials in evaluating and rating the performance of employees.  Concurrent with the actions of the reviewing officials, the Performance  Management Performance Review Authority conducts a high-level review  of all evaluations of record and ratings across the component with the  intent of ensuring rigor and consistency across all supervisors and  reviewing officials and compliance with applicable laws and regulations.  Within 45 days of the end of the performance evaluation period, all ratings  must be finalized and approved by the reviewing officials and the  Performance Management Performance Review Authority.
The pay pool process begins at the same time as the performance  management process with the establishment of pay pool structures and  annual training to strengthen participants’ understanding about the pay  pool process from October 1 to September 30. However, pay pools begin  their annual deliberations about employee salary increases and bonuses  after ratings are finalized. A pay pool is a group of individuals who share in  the distribution of a common pay-for-performance fund. Each employee is  assigned to a pay pool according to considerations regarding  organizational structure, geographic location, and/or occupation. Figure 3  illustrates a sample DCIPS pay pool structure, specifically the relationship  between the members of each pay pool—the employee, supervisor or  rating official, reviewing official, pay pool panel, pay pool manager, and  performance review authority.
Each of these pay pool members has defined responsibilities during the  annual deliberations and pay out process. The Pay Pool Performance  Review Authority, who can be either an individual or a panel of  individuals, oversees one or more pay pools to ensure procedural  consistency among the pay pools under its authority. The Pay Pool  Manager provides financial, scheduling, and business rules guidance for  the process; settles differences among panel members; and approves the  final pay pool panel recommendations. The Pay Pool Panel members,  which include reviewing officials and, in some cases, rating officials, are  responsible for determining performance-based salary increases and  bonuses using established pay pool guidance. Payouts are normally  effective on the first day of the first pay period following January 1 of the  new calendar year. The department issued overall guidance in September  2009 regarding its pay pool business rules.
DCIPS is a pay-banded performance management system.  As such,  employees have converted or will convert from the General  Schedule/General Government system to five distinct pay bands. Under  the General Schedule/General Government system, salary is determined by  the 15-grade/10-step system. Pay banding consolidates these 15 grades  into five broad pay bands, and the DCIPS pay system establishes a salary  range for each pay band, with a minimum and a maximum pay rate. Figure  4 illustrates which Government Grade/General Schedule pay grades/steps  Schedule pay grades/steps  apply to each pay band during conversion.   apply to each pay band during conversion.
section_title: DOD Has Taken Steps to Incorporate Internal Safeguards into DCIPS, but Two Safeguards and Monitoring Have Not Been Fully Implemented
paragraphs: Although DOD has taken some steps to implement internal safeguards to  ensure that the DCIPS performance management system is fair, effective,  and credible, opportunities exist to improve DOD’s implementation of 2 of  the 10 safeguards. Specifically, DOD has taken some steps to (1) link  employee objectives and the agency’s strategic goals and mission; (2)  provide a system to better link individual pay to performance in an  equitable manner; (3) train and retrain employees and supervisors in the  system’s operation; (4) require ongoing performance feedback between  supervisors and employees; (5) assure meaningful distinctions in  employee performance; (6) ensure agency resources are allocated for the  design, implementation, and administration of the system; (7) assure that  there is an independent and credible employee appeals mechanism; (8)  assure reasonable transparency of the system and its operation; (9)  involve employees in the design and implementation of the system; and  (10) adhere to merit principles set forth in section 2301 of title 5 of the U.S.  Code. We have previously reported that continued monitoring of such  systems’ safeguards is needed to help ensure DOD’s actions are effective  as implementation proceeds. While we believe continued monitoring of  all of these safeguards is needed as implementation proceeds and more  employees become covered by DCIPS, we determined that USD(I)’s  implementation of two safeguards—employee involvement and the  adherence to merit principles—could be improved immediately. Until  USD(I) effectively implements all of the safeguards, employees will not  have assurance that the system is fair, equitable, and credible, which  ultimately could undermine employees’ confidence and result in failure of  the system.
subsections: section_title: Link Employee Objectives to the Agency’s Strategic Goals and Mission
paragraphs: DOD has made efforts to link employees’ objectives to the agency’s  strategic goals, mission, and desired outcomes. For example, DCIPS  guidance stipulates that employees’ individual performance objectives  should align with the goals and objectives of the National Intelligence  Strategy, DOD, and the employee’s organization.  Specifically, an  employee, in conjunction with a rating official and supervisor (if  different), will establish approximately three to six performance  objectives, which set specific performance targets for the individual, and  link to National Intelligence Strategy, departmental, and component goals  and objectives. Further, according to the DCIPS guidance, performance  objectives for non-supervisory employees should be appropriate to the  employee’s pay band, pay, and career or occupation category, and will be  structured such that they are specific, measurable, achievable, relevant,  and time-limited (SMART). The guidance further requires the creation of  annual performance plans, to serve as records of the performance  planning process, which are to be reviewed and approved by reviewing  officials to ensure they are consistent with organizational goals and  objectives. DOD officials we spoke with identified SMART objectives as  the primary method of linking individual employee performance objectives  to agency mission and goals. Figure 5 illustrates how an individual’s  dual’s  SMART objectives align to agency and National Intelligence Strategy goals.     SMART objectives align to agency and National Intelligence Strategy goals.
section_title: Link Individual Pay to Performance in an Equitable Manner
paragraphs: USD(I) officials stated that DCIPS’s design allows for a better linkage  between individual pay and performance than the previous General  Schedule pay scale. DCIPS policy requires that DCIPS shall provide a basis  for linking performance-based pay increases and bonuses to (1) individual  accomplishments, (2) demonstrated competencies, and (3) contributions  to organizational missions and results—such that the greatest rewards go  to those who make the greatest contributions, consistent with both  performance and competitive pay administration principles.  Moreover,  DCIPS draft guidance states that the goal of the system is that it provide  for a reward system that attempts to motivate employees to increase their  performance contribution, making the employees’ level of performance  commensurate with their total compensation. Several DCIPS components  we spoke with, including the Army, Marine Corps, and Air Force, cited  DOD’s Compensation Work Bench, a computerized tool that calculates pay  increases by using performance ratings and pay pool information as a  primary mechanism for quantitatively connecting individual performance  and pay. In addition, the same components also cited the Performance  Appraisal Application, an online tool for monitoring employee  performance throughout a rating cycle, as another means of establishing  such linkage. Although DOD has created policy to better link an  individual’s pay to performance, it is too soon, given the current  implementation status, to determine the extent to which pay will be  equitably linked to performance, as a full performance cycle has not been  completed and DCIPS payouts have not yet occurred.
section_title: Provide Training in the Implementation and Operation of the System
paragraphs: DOD has taken several steps to provide extensive training to DCIPS users  in the implementation and operation of the performance management  system. For example, DCIPS policy requires that employees be trained in  the system, and that rating officials, supervisors, pay pool managers, and  pay pool members be trained in their responsibilities. According to  USD(I), each of the DCIPS components is required to implement training,  tailoring any materials provided by USD(I) as necessary to meet the needs  of its workforce. Additionally, there are currently a number of training  mechanisms, including Web-based courses, classroom sessions, and town  hall forums—so employees have a range of opportunities to learn about  DCIPS. USD(I) provided a training curriculum that includes courses such  as DCIPS 101, Managing Performance, and DCIPS Compensation  Fundamentals. Some training tools are designed for distinct groups (i.e.,  supervisors, human resource personnel, etc.) in order to ensure that  different groups have a contextual understanding of DCIPS.  See appendix  V for a list of major courses in this curriculum.
Officials we spoke with at a number of DCIPS components stated that they  offer a variety of classroom and Web-based training tools, some of which  were adapted from USD(I) training in order to better suit the needs of the  component’s workforce. For example, one component modified USD(I)’s  iSuccess course, which provides employees with step-by-step instruction  on how to write SMART performance objectives and self-assessments.  Other components have employed innovative approaches to training, such  as conducting joint training sessions with employees and supervisors in  order to increase transparency and to open dialogue between the two  groups.
Additionally, USD(I) administered a number of training evaluations for its  introductory DCIPS courses that indicated that employees generally  viewed the training as informative and beneficial.  However, during our  nongeneralizable discussion groups with employees, we found that  employee perceptions of training were somewhat mixed, as participants at  9 of our 13 discussion group sites stated that too many questions regarding  DCIPS went unanswered, including questions posed during training. In  particular, employees in one discussion group stated that training on  developing performance objectives was not helpful because it focused on  developing objectives for jobs that had very specific outputs, such as  making widgets. Although such feedback indicates that the breadth of  training offerings, as well as the scope and/or format of individual  sessions, could be improved, we note that we conducted our discussion  groups during April 2009 and May 2009, and according to one USD(I)  official, new training courses have since been added, such as  Compensation Fundamentals.
section_title: Ensure Ongoing Performance Feedback and Dialogue between Supervisors and Employees
paragraphs: DCIPS policy requires that rating officials and/or supervisors provide  employees with meaningful, constructive, and candid feedback relative to  their progress against performance expectations in at least one  documented midpoint performance review and an end-of-year review. In  addition, guidance requires rating officials and employees to engage in  dialogue throughout the rating period to, among other things, develop  performance objectives and an individual’s development plan. They are  also required to discuss progress toward achieving performance  objectives, behaviors related to successful performance, and individual  employee development. Most of the DCIPS components we spoke with  stated that additional feedback beyond the minimum required guidance is  encouraged, but not mandatory. Formal feedback between employees and  supervisors should be documented in the Performance Appraisal  Application—DOD’s online performance management tool. At 7 of the 13  sites we visited, discussion group participants told us that communication  with supervisors has increased under DCIPS, with most interactions being  face-to-face, as encouraged by DOD.
section_title: Assure Meaningful Distinctions in Individual Employee Performance
paragraphs: DCIPS is intended to create a performance management system that  provides meaningful distinctions in employee performance. However,  because performance evaluations have yet to occur under DCIPS, it is  unclear the extent to which ratings will actually result in meaningful  distinctions. Unlike the pass fail system, which some of the employees  were under, the performance ratings scale for DCIPS consists of five rating  categories, of which the lowest rating is a “1” (unacceptable performance)  and the highest rating is a “5” (outstanding performance). Ratings are  determined by comparing employee performance against performance  standards for the employee’s pay-band level.
Officials we spoke with at USD(I) and the DCIPS components also cited  other mechanisms to implement this safeguard. For example, USD(I) told  us that distinctions in individual employee performance will also be made  through the bonus process.  While all employees with performance  evaluations rated Successful or above will be eligible, USD(I) officials  expect that only 45 percent to 50 percent of employees who are eligible  will receive a bonus. A USD(I) official noted that limiting bonuses to less  than 50 percent of the staff will make bonuses more meaningful. Also, to  ensure accountability at the supervisory level, one of the components told  us it requires supervisors to demonstrate how they make distinctions in  ratings as part of their own performance objectives. Finally, DOD officials  stated that the mock performance review process will provide an  opportunity to determine how meaningful distinctions in performance will  be made, as well as a chance to garner lessons learned for assessing  performance.
Several of our discussion group participants expressed concern that there  is potential for a “forced distribution” of ratings (i.e., a fixed numeric or  percentage limitation on any rating level), which could effectively erode  meaningful distinctions in individual employee performance. However,  USD(I) officials told us that they had informed the components that forced  distributions of ratings are unacceptable and potentially illegal, and that  USD(I) has emphasized rigor and consistency in ratings throughout  DCIPS’s implementation by way of leadership training and the  Performance Review Authority.  Additionally, in August 2009, USD(I)  posted a statement on the DCIPS Web site reiterating its prohibition on  forced distribution of ratings found in DCIPS guidance.
section_title: Means to Ensure Adequate Agency Resources Are Allocated for the System’s Design, Implementation, and Administration
paragraphs: DOD, through USD(I), has taken steps to ensure that agency resources are  allocated for the implementation and administration of DCIPS. For  example, DCIPS guidance provides for an initial permanent salary increase  budget that is no less than what would have been available for step  increases, quality step increases, and within-band promotions under the  previous personnel system. Further, USD(I) will conduct, in coordination  with the components, an annual analysis of salary adjustments to  determine the effects on the distribution of the workforce within pay  bands, position of the workforce relative to the applicable labor market,  anticipated adjustments to the ranges, and projected General Schedule  increases for the year in which the next payout is to be effective.
Funding for the implementation of DCIPS was drawn from two primary  funding streams including: 1) the National Intelligence Program, and 2)  Military Intelligence Program. According to USD(I), funding was used to  cover the costs associated with conversion, including training, technology,  and Within-Grade Increases. USD(I) and several of the DCIPS components  we spoke with indicated that resources were sufficient to implement the  system. In particular, one component told us that the Office of the Director  for National Intelligence has been very receptive to resource concerns and  had asked to be notified of any shortfalls. In fact, at the time of our review,  only one DCIPS component told us it had requested additional funds for a  shortfall.  In addition, USD(I) created a resource management group  consisting of Chief Financial Officer officials from each DCIPS component  in order to ensure the proper level of funding is available for payouts  beginning in 2010.
section_title: Assure an Independent, Credible Employee Appeals Mechanism
paragraphs: We previously identified an independent and credible employee appeals  mechanism as a key component to ensuring that pay-for performance  systems are fair, effective, and credible. DCIPS does not provide a  distinct mechanism for employees to appeal adverse actions.  Instead, it  relies on existing agency procedures to fulfill this function, so that each of  the defense intelligence components has its own appeals mechanism.
According to USD(I) officials, guidance that would provide DCIPS a  distinct employee appeals mechanism is in draft.  When issued, according  to these officials, this guidance will provide the minimum requirements for  adverse action appeals, including fundamental due process, based on the  requirements established in chapter 75 of title 5 of the U.S. Code.   According to ODNI officials, chapter 75 does not statutorily apply to  DCIPS.  Rather, DOD is adopting these standards pursuant to ODNI  Intelligence Community Directives.  Additionally, ODNI guidance provides  that employees will receive due process in any adverse action, as defined  by applicable law and regulation, involving performance, as established by  their respective departments or agencies, including an objective and  transparent appeals process.
section_title: Assure Reasonable Transparency of the System and Its Operation
paragraphs: DOD has taken steps to ensure a reasonable amount of transparency is  incorporated into the implementation of DCIPS. For example, in contrast  to the National Security Personnel System—which uses a system of  weighted shares to determine employee payouts—DCIPS uses a software  algorithm, available to all DCIPS employees, to calculate salary increases  and bonus awards.  In addition, USD(I) officials told us that USD(I) has  communicated the performance management process through town hall  meetings, DCIPS Web sites, quarterly newsletters, and letters from USD(I)  management. Similarly, the DCIPS components are individually  conducting a range of activities to provide transparency, such as their own  town halls and open forum discussions. In particular, officials from one  component told us that they conducted a survey of employees to  determine how they received information about DCIPS and how they  preferred to receive such information in the future. According to USD(I)  officials, sharing aggregate rating results with employees is key to  ensuring transparency and ultimately to gaining employee acceptance of  the system. These officials also told us that they are instructing the DCIPS  components to publish aggregate rating results. In fact, in September 2009,  USD(I) provided a template for reporting DCIPS performance evaluation  and payout results to the workforce.  USD(I) officials stated that while the  template can be tailored to suit specific agency needs, it will also establish  a common way of reporting in which individual employees will be able to  see where they stand relative to their peers and within pay bands.  Separately, according to these same officials, USD(I) also plans to publish  rating results at the department level by merging the results of all pay pool  data from each of the DCIPS components. According to ODNI officials,  they intended to do the same for Intelligence Community-wide results.
section_title: Involve Employees in the Design and Implementation of the System
paragraphs: USD(I) and the defense intelligence components have taken some steps to  involve employees in the implementation of DCIPS, however more  opportunities exist to expand this involvement. As we previously reported,  involvement in a performance management system’s design and  implementation must be early, active, and continuing if DOD employees  are to gain a sense of understanding and ownership of the changes that are  being made. Specifically, USD(I) and the defense intelligence  components have used various mechanisms to obtain employee input.  For  example, USD(I) sponsored a survey to validate performance  competencies for DCIPS and administered training evaluations for a  variety of DCIPS courses, covering topics such as SMART objectives.  In  addition, the defense intelligence components conducted town hall  meetings to provide domestic and overseas employees with information  about DCIPS and to communicate with the workforce.
According to a USD(I) official, the components possess considerable  discretion regarding the nature and extent of employee involvement at the  agency level, and as such, have independently employed a number of  feedback mechanisms, including discussion groups and “brown bag”  meetings. In most cases, the impact of such efforts is unclear; however,  officials at one DCIPS component told us that some employee concerns  were elevated to the Defense Intelligence Human Resources Board and  actions were taken.  For example, some employees expressed concerns  about the elimination of career ladders, which eventually resulted in a  policy change allowing employees who were hired under a particular  career ladder to remain in that career ladder under DCIPS. Similarly,  USD(I) provided us with a draft guide to writing effective performance  objectives, which, according to officials, was produced at the request of  employees that attended a pilot training course.
While the above-mentioned steps demonstrate a commitment to engage  the workforce, USD(I) has not taken advantage of other opportunities to  expand such efforts by establishing a formal process for the continuous  involvement of employees in DCIPS. As we previously reported, leading  organizations involve employees directly and consider their input before  finalizing key decisions—such as draft guidance. Although USD(I)  officials stated they allow employees to comment on draft guidance,  USD(I) does not have, in its guidance, a formalized process for the  continued and direct involvement of employees in the development and  implementation of DCIPS. This is of concern, since employees and  supervisors in discussion groups at 12 of the 13 sites we visited indicated  that they had limited or no involvement in the design and implementation  of the system. Without continuous employee involvement in the  implementation of DCIPS, employees may experience a loss of ownership  over the system, which could ultimately undermine its credibility.
section_title: Adherence to Merit Principles
paragraphs: USD(I) has taken steps to ensure that DCIPS incorporates the merit  principles set forth in section 2301 of title 5 of the U.S. Code.  The Office  of Personnel Management has noted that prior to rolling out an alternative  personnel system, an agency should document its business processes and  procedures associated with all aspects of the system. In September 2009,  USD(I) provided to us a document that stipulates that no later than March  31, 2010, components will provide the USD(I) Human Capital Management  Office with detailed data, including demographic analysis, on performance  evaluation and payout results.  In September 2009, USD(I) also published a  template for publishing DCIPS performance evaluation and payout results  to the workforce. This template provides a sample aggregate workforce  report for employees, which contains demographic-based reporting  categories, including gender, race, ethnicity, age, disability status, and  veterans’ status and provides details to report to employees, including  each groups’ average rating, salary increase, and bonus.
While notable, this 2009 document, however, does not specify what data  are to be collected for the post-decisional demographic analysis, how the  data should be analyzed, what process the components should follow to  investigate potential barriers to fair and equitable ratings and their causes,  or a process for eliminating barriers that are found. Until DOD specifies  these steps in its guidance, the intelligence components may not follow a  consistent approach in these areas, the department may be unable to fully  determine whether potential barriers to fair and equitable ratings exist,  and employees may lack confidence in the fairness and credibility of the  DCIPS and its ratings. To help ensure equity, fairness, and non- discrimination in ratings, we are recommending that DOD issue guidance  on its analysis of finalized ratings that explains how the demographic  analysis of ratings is to be conducted.
section_title: DOD’s Initial Plans to Monitor DCIPS and the Safeguards
paragraphs: We have previously reported with another pay-for-performance system  that continued monitoring of safeguards is needed to help ensure that a  department’s actions are effective as implementation progresses.  We  have also reported that adequate evaluation procedures would, among  other things, facilitate better congressional oversight, allow for any  midcourse corrections, assist DOD in benchmarking its progress, and help  document best practices and lessons learned with employees and other  stakeholders. In October 2009, DOD provided us with a draft evaluation  plan that details tentative procedures to monitor and evaluate DCIPS  implementation, including all of the safeguards. For example, it provides  for the examination of the relationship between performance ratings and  annual performance payouts, and establishes methods of obtaining  employee feedback, such as attitude surveys, interviews, and focus  groups.
According to DOD officials, they do not expect to execute the evaluation  plan until after the first payout, in January 2010. DOD’s efforts to draft an  evaluation plan are notable; however, without finalizing and executing  such a plan, the department will not have a clear understanding of whether  it is achieving its desired outcomes as part of implementing the new  performance management system for its intelligence components.
section_title: DOD Had Several Mechanisms to Provide Information to Employees, but These Did Not Comprehensively Identify Employee Perceptions of DCIPS, and Future Mechanisms Do Not Include Some Needed Questions
paragraphs: At the time of our review, DOD had several mechanisms to engage  employees and provide information.  However, these mechanisms did not  comprehensively identify employee perceptions.  GAO conducted 26  discussion groups, which while not generalizable, did show that  employees and supervisors had mixed views about certain aspects of the  system.  Additionally, DOD’s planned mechanisms do not include certain  questions related to the safeguards.
subsections: section_title: DOD Had Several Mechanisms to Provide Information to Employees, but These Did Not Comprehensively Identify and Address Employee Perceptions
paragraphs: DOD, at the time of our review, had several mechanisms in place to  provide information to employees about DCIPS; however, these  mechanisms did not comprehensively identify and address employee  perceptions.  Specifically, the defense intelligence components conducted  numerous town hall meetings to brief employees on DCIPS—covering  such topics as the performance management cycle and roles and  responsibilities of employees/supervisors---and to understand their  concerns.  USD(I) also maintained a Web site that contained frequently  asked questions submitted by employees and USD(I)’s response. Some of  the frequently asked questions provided by the naval Intelligence  Community, as an example, included:      Will basic civil service protections be preserved, such as whistle  blower protections and veteran’s preference?
What safeguards will be in place to ensure that DCIPS rewards merit  for merit's sake, and does not cater to nepotism and cronyism?
USD(I) officials stated that it has used several other mechanisms,  including site visits and the annual Intelligence Community Climate  Survey, to collect employee opinions on various management policies and  practices.  While these efforts are notable, these mechanisms do not  comprehensively identify employee perceptions of DCIPS. However,  USD(I) does have plans to implement additional mechanisms that will be  discussed later in this report.
section_title: Employees and Supervisors in Discussion Groups Expressed Mixed Views regarding Some Aspects of DCIPS
paragraphs: The non-generalizable results of the discussion groups we conducted  identified, among other things, mixed views about certain aspects of the  system. Specifically, our discussion groups identified areas that employees  and supervisors found positive regarding DCIPS and several areas where  they expressed a consistent set of concerns about DCIPS, some of which  are listed below.  Our prior work, as well as that of the Office of Personnel  Management, has recognized that organizational transformations, such as  the adoption of a new performance management system, often entail  fundamental and radical changes that require an adjustment period to gain  employees’ trust and acceptance.  As a result, we expect major change  management initiatives in large-scale organizations to take several years to  be fully successful.
subsections: section_title: Employees Generally Expressed Positive Views about the Concept of Pay-for- Performance but Were Concerned About the Pace of Implementation
paragraphs: At 7 of the 13 locations visited, discussion group participants generally  expressed positive views about the concept of pay for performance.  For  example, employees at one location stated they like the idea of linking pay  to performance and think that there is more opportunity for financial  growth.  Additionally, supervisors at another location stated they thought  DCIPS is a better system than pay for tenure/time. At another location,  supervisors stated they liked the concept of DCIPS because they felt pay  for performance will reward the hard workers. However, participants in 9  of 13 discussion groups felt that DCIPS was being implemented too  quickly.  Additionally, employees and supervisors at 9 of the 13 locations  visited said too many questions about DCIPS went unanswered.  For  example, employees at one location felt that in-class instructors were  unable to provide answers to basic questions about DCIPS and its  implementation.  Further, supervisors in another location stated they felt  unprepared to answer employee questions about DCIPS.
section_title: Amount of Time Spent on Performance Management Diverts Attention from Mission Work
paragraphs: Participants at 10 of the 13 locations visited said the amount of time spent  working on DCIPS diverts attention from their mission work. For example,  supervisors at one location stated mission activities have taken a back seat  to the activities required to implement DCIPS, and at another location  supervisors were dismayed by the significant amount of time the rating  process entails.  Both employees and supervisors at several locations also  felt that DCIPS was a tremendous administrative burden.  For example,  supervisors in one discussion group stated the administrative burden is a  “nightmare,” while supervisors in another discussion group stated DCIPS  is too time-consuming, takes away from actual work of value, monopolizes  the chain of command at critical moments; and is overly laborious without  tangible benefits compared with other systems. Other supervisors stated  employees are now more focused on DCIPS metrics than their actual jobs.   Moreover, employees in one discussion group stated that DCIPS is a  detriment to the mission because it is a huge administrative burden that  takes one away from performing his or her mission work.
section_title: DOD Plans to Implement Mechanisms to Comprehensively Identify and Address Employee Perceptions
paragraphs: We have previously reported that high-performing organizations  continuously review and revise their performance management systems  based on data-driven lessons learned and changing needs in the  environment.  Consistent with this approach, USD(I) officials have  drafted four surveys to be used by the components that will cover various  parts of DCIPS (training, performance objectives, ratings process, and  payouts) and be accompanied by guidance on how to assess survey  results.  However, while these surveys cover aspects of DCIPS, they lack  questions that would provide insight on certain aspects of the safeguards,  such as the likelihood an employee would utilize the internal grievance  process to challenge a rating.  Additionally, the surveys—at the time of our  review—did not directly ask questions or measure employees’ overall  acceptance of DCIPS.  Further, it is unclear exactly when these surveys  will be implemented, although USD(I) officials said they hoped to start  soon in order to capture baseline feedback from the first year.  USD(I)  officials further said the results of the surveys will inform future changes  to DCIPS.  However, without implementing a mechanism—like the four  surveys that include questions regarding certain safeguards, such as the  internal grievance process—DOD may not be able to comprehensively and  accurately identify and measure employee perceptions.
section_title: Conclusions
paragraphs: Human capital reform is one of the most significant transformations in the  federal government. In our 2009 High-Risk Series update, we identified the  importance of developing a clear linkage between individual employee  performance and organizational success and pointed out that the success  of implementing a performance management system is contingent on how,  when, and the basis on which it is done. However, at the end of this  review, legislation was signed by the President that contained provisions  that affect DCIPS. As mentioned previously, the USD(I) November 3, 2009,  memorandum to the defense intelligence workforce noted that the  legislation did not repeal or terminate DCIPS, but suspended certain  provisions of the DCIPS pay-setting regulations until December 31, 2010,  to allow for an independent review of DCIPS.  This memorandum also  stated that the department would continue to press forward with unifying  the defense Intelligence Community under a common personnel system  and specifically noted that the National Geospatial-Intelligence Agency  would continue under all DCIPS regulations—as allowed by the  legislation—and would be the focus of the department’s review of DCIPS.   We have acknowledged in prior work on performance management  systems that moving too quickly or prematurely could have detrimental  consequences for such systems.  The additional review of DCIPS efforts to  date may provide the department time needed to address any potential  issues and help ensure successful implementation.
We have further reported that a basic framework is needed to implement  major reforms, including performance management systems.  Our prior  reports make it clear that incorporation of internal safeguards is  fundamental for the effective implementation of performance management  systems.  Further, we have reported that committed top leadership and  involving employees in a new performance management system is a  continuous process.  While we recognize that DOD faces many challenges  in changing the culture to implement a pay-for-performance system  capable of serving the entire DOD Intelligence Community, we believe that  it is imperative that DOD continue to explore ways to build employee  confidence in the system to help ensure the system’s success.  By partially  incorporating the two safeguards we specifically mention, DOD could put  the fairness and credibility of DCIPS at risk.  However, given the newness  of DCIPS, constant monitoring of all safeguards is a prudent course of  action.  Further, without developing an evaluation plan that assesses  DCIPS, including the safeguards, the department will be unable to  determine if it is meeting its intended human capital reform goals.
Finally, until DOD implements its mechanism to comprehensively and  accurately identify and measure employee perceptions, including  questions related to the safeguards such as the internal grievance process,  it is not well positioned to develop a strategy to effectively address  concerns raised by employees regarding DCIPS.  Employees are the  number one stakeholders in this type of transformation.  With employees  from the National Geospatial-Intelligence Agency being the only  employees continuing under DCIPS regulations and given the agency’s 10- year history with a pay for performance human capital system, the  perspective of those employees will provide DOD with valuable insights as  it reviews DCIPS and monitors the implementation of the safeguards.  As  the Office of Personnel Management and other studies have shown, it  takes time for employees to accept organizational transformation—in this  case, a move to a performance management system.  As a result, employee  acceptance of the system—both eligible employees in the defense  intelligence components as well as those in the National Geospatial- Intelligence Agency—is dependent on those employees’ involvement in the  system’s design and implementation.  Ultimately, the success of the system  is dependent on this acceptance.
section_title: Recommendations for Executive Action
paragraphs: To improve DOD’s implementation of internal safeguards in DCIPS, and  mechanisms to identify employee perceptions of it, we recommend that  the Secretary of Defense direct that the Under Secretary of Defense for  Intelligence take the following four actions:  Issue guidance to institutionalize a process to involve employees  continually in future design and implementation changes to DCIPS;  Issue guidance on its analysis of finalized ratings that explains how the  demographic analysis of ratings is to be conducted, to help ensure  equity, fairness, and non-discrimination in ratings;    Finalize and execute its evaluation plan with metrics to assess the  system, including the implementation of internal safeguards, to help  ensure the department evaluates the impact of DCIPS; and    Expeditiously implement mechanisms—including the four surveys— that comprehensively and accurately identify and measure employee  perceptions; and ensure those mechanisms include questions regarding  certain safeguards, such as the internal grievance process and  employees’ acceptance of DCIPS.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD and ODNI.  DOD, in written  comments, concurred with all of our recommendations. We provided  ODNI with a draft of this report because, though not the focus of our  review, ODNI has played a significant role in strategic human capital  management reform for the U.S. Intelligence Community and is thus well  positioned to provide additional insights and comments on DCIPS and  companion efforts in the Intelligence Community. Both DOD and ODNI  provided us with technical comments, which we incorporated in this  report, as appropriate.  DOD’s and ODNI’s written comments are reprinted  in their entirety in appendixes VII and VIII, respectively.
In its written comments, DOD noted there are inherent challenges implicit  in implementing a change of this magnitude—specifically establishing a  common DCIPS framework within the defense intelligence components  that is fair and equitable, consistent, and transparent.  We agree with the  department and note in our report that change of this magnitude can take  several years to be fully successful.  Furthermore, DOD characterized our  recommendations as logical next steps in the evolution of DCIPS and  elaborated on specific steps it was taking to address each of our  recommendations.  First, DOD stated that, as recommended, it was  developing guidance to more formally institutionalize a process to involve  employees continually in design, implementation, and evaluation to the  evolving DCIPS.  DOD noted that since the Intelligence Community does  not have employee bargaining units, it is all the more important to ensure  a robust and consistent process for employee engagement. Second,  regarding our recommendation that DOD issue guidance on the analysis of  its ratings, the department noted that it issued initial guidance and was  finalizing guidance for individual components that takes into account  requirements of the Fiscal Year 2010 National Defense Authorization Act.   Third, DOD stated that, as recommended, it was in the process of  finalizing the DCIPS evaluation plan with metrics to assess the system and  stated that the department recognized the importance of evaluating  DCIPS.  Fourth, DOD stated that, as recommended, it was finalizing plans  to develop mechanisms that comprehensively and accurately identify and  measure employee perceptions.  DOD also noted that, as recommended,  the mechanisms would include questions regarding certain safeguards,  such as the internal grievance process and employees’ acceptance of  DCIPS.  If implemented in accordance with our recommendations, the  department’s actions appear to be a positive step in helping ensure  fairness, equity, and credibility of the personnel system.
In written comments, ODNI stated that it appreciated the opportunity to  comment on our report, thought the overall tone of the report was fair and  balanced; but noted that they felt the reports Highlights page, unlike the  overall report, was overly negative.  We reevaluated our Highlights page to  ensure that it appropriately reflected our findings as seen throughout the  report and made some changes to address ODNI’s comments about tone.   For example, we previously enumerated the ten safeguards in the  highlights page but deleted a number of those to incorporate specific  actions that DOD had taken to more directly mirror language in other parts  of our report.  ODNI also stated that it believed our report should  emphasize that DCIPS was authorized by statute in 1997 and is separate  and distinct from the National Security Personnel System. Our draft  noted both of these points.  ONDI also noted in its comments that it  believed our report should emphasize that DCIPS and the NICCP are  intended to meet the goals of the Intelligence Reform and Terrorism  Prevention Act of 2004.  We have made appropriate changes to our report  but note also that we reviewed the implementation of DCIPS and not  ODNI’s National Intelligence Civilian Compensation Program.  ODNI  further stated that Intelligence Community Directive 650 clearly lays out  10 guiding principles that very closely align to the 10 criteria we chose for  our review.  We agree but note that our objective was not to determine  whether DCIPS met the intent of Intelligence Community Directives but  rather to determine whether DCIPS incorporated the safeguards identified  in our prior work as best practices for public and private performance  management systems.  ODNI also commented that change is often difficult  for employees to accept and there will always be some employee  discomfort; however, these officials believed that this discomfort is more a  reflection of where DCIPS is in its implementation schedule than with any  material defect with system’s design.  We also acknowledge, in our draft  and in prior reports, that major change management initiatives in large- scale organizations take several years to be fully successful.  ODNI  expressed an appreciation for our comprehensive review and our  recommendations to DOD and agreed to work with USD(I) in an  expeditious manner to address the areas we identified.  ODNI made a  number of other technical comments that we considered and incorporated  into our draft, as appropriate.
We are sending copies of this report to the appropriate congressional  committees and the Secretary of Defense.  In addition, this report will be  available at no charge on GAO’s Web site at http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-3604 or by e-mail at farrellb@gao.gov.  Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this report.  GAO staff who made major contributions to  the report are listed in appendix IX.
section_title: Appendix I: The National Intelligence Civilian Compensation Program
paragraphs: In March 2005, the Commission on the Intelligence Capabilities of the  United States Regarding Weapons of Mass Destruction recommended to  the President that the Director of National Intelligence use its human  resources authority to create a uniform system for performance  evaluations and compensation, and develop a more comprehensive and  creative set of performance incentives.  In response to the commission’s  recommendation, the Director of National Intelligence established the  National Intelligence Civilian Compensation Program (NICCP), which  creates a uniform system of performance evaluation and compensation for  the Intelligence Community's civilian workforce and aims at building a  culture of collaboration across the Intelligence Community.  NICCP  represents a fundamental shift from the current General Schedule pay  scale to a more performance-based, market model.  The cornerstone of the  Office of the Director of National Intelligence’s approach to establishing  NICCP has been inter-departmental collaboration within the Intelligence  Community.  An ODNI official noted that NICCP essentially acts as a  "treaty", or common, framework that establishes the performance  management and pay rules that are to be commonly and consistently  applied across the Intelligence Community.
Specifically, NICCP institutes a common set of core requirements such as  setting basic rates of pay, managing performance, and pay based on  performance. This framework also includes establishing six common  performance elements by which all Intelligence Community civilian  employees will be assessed.  Specifically, these include Accountability for  Results, Communication, Critical Thinking, Engagement and  Collaboration, Personal Leadership and Integrity, and Technical Expertise.  Supervisors will also be evaluated on six performance elements, of which  they share four with non-supervisors—Accountability for Results,  Communication, Critical Thinking, Engagement and Collaboration—and  two that are unique to them, Leadership and Integrity, and Management  Proficiency.  Additionally, rating levels under this new system are from 1  to 5—with 1 being unacceptable performance and 5 being outstanding  performance  In addition to being applicable to Intelligence Community employees  within DOD, NICCP is also applicable to certain other national intelligence  organizations from other federal agencies and departments—including the  Central Intelligence Agency, the Department of Homeland Security, the  Federal Bureau of Investigation, and the Office of the Director of National  Intelligence, which currently have pay-setting authorities. For example,  the Central Intelligence Agency is currently using its statutory authority to  implement a pay-for-performance system and has, to date, created a Pay  Modernization Office, and developed a project plan, implementation  schedule, and pay modernization Web site.  According to officials in the  Office of the Director of National Intelligence, other federal agencies or  departments that do not currently have the same statutory authorities  include offices within Departments of Energy, State, Treasury, and the  Drug Enforcement Administration.
As reported by ODNI, the Intelligence Community agreed upon the several  “enabling” directives that actually constitute NICCP.  Specifically, the  essence of the NICCP framework has been captured in a suite of five  enabling directives.  They include the following:  Intelligence Community Directive 650—National Intelligence  Civilian Compensation Program: Guiding Principles and Framework  (Effective April 28, 2008).  Intelligence Community Directive 651—Performance Management  System Requirements for the Intelligence Community Civilian  Workforce (Effective November 28, 2007 and Updated Nov. 21,  2008).  Intelligence Community Directive 652—Occupational Structure for  the IC Civilian Workforce, (Effective April 28, 2008).    Intelligence Community Directive 653––Pay-Setting and  Administration Policies for the IC Civilian Workforce (Effective May  14, 2008))  Intelligence Community Directive 654 –Performance-Based Pay for  the IC Civilian Workforce (Effective April 28, 2008.)
section_title: Appendix II: Merit System Principles
paragraphs: While our review focused on two merit principles that relate directly to  performance management, 5 U.S.C. §§ 2301(b)2 and (b)(8A), the following  provides the entire list of merit principles found in section 2301:  Section 2301 of title 5 of the U.S. Code applies to executive agencies and  requires federal personnel management to be implemented consistent with  the following merit system principles.  1.  Recruitment should be from qualified individuals from  appropriate sources in an endeavor to achieve a work force from  all segments of society, and selection and advancement should be  determined solely on the basis of relative ability, knowledge and  skills, after fair and open competition which assures that all  receive equal opportunity.   2.  All employees and applicants for employment should receive fair  and equitable treatment in all aspects of personnel management  without regard to political affiliation, race, color, religion,  national origin, sex, marital status, age, or handicapping  condition, and with proper regard for their privacy and  constitutional rights.   3.  Equal pay should be provided for work of equal value, with  appropriate consideration of both national and local rates paid by  employers in the private sector, and appropriate incentives and  recognition should be provided for excellence in performance.   4.  All employees should maintain high standards of integrity,  conduct, and concern for the public interest.   5.  The Federal work force should be used efficiently and effectively.   6.  Employees should be retained on the basis of adequacy of their  performance, inadequate performance should be corrected, and  employees should be separated who cannot or will not improve  their performance to meet required standards.   7.  Employees should be provided effective education and training in  cases in which such education and training would result in better  organizational and individual performance.   8.  Employees should be—  (A) protected against arbitrary action, personal favoritism, or  coercion for partisan political purposes, and   (B) prohibited from using their official authority or influence for  the purpose of interfering with or affecting the result of an  election or a nomination for election.   9.  Employees should be protected against reprisal for the lawful  disclosure of information which the employees reasonably  believe evidences—  (A) a violation of any law, rule, or regulation, or   (B) mismanagement, a gross waste of funds, an abuse of  authority, or a substantial and specific danger to public health or  safety.
section_title: Appendix III: Scope and Methodology
paragraphs: In conducting our review of the Defense Civilian Intelligence Personnel  System (DCIPS), we limited our scope to the performance management  aspect of DCIPS.  We did not address either the performance management  of the Senior Executive Service at the Department of Defense (DOD) or  other aspects of DCIPS, such as classification and pay.
subsections: section_title: Extent to which DOD Incorporated Internal Safeguards into DCIPS
paragraphs: To determine the extent to which DOD has incorporated internal  safeguards and accountability mechanisms into DCIPS, we used the  following internal safeguards and accountability mechanisms, which were  derived from our previous work on pay-for-performance management  systems in the federal government:    Assure that the agency’s performance management system links  employee objectives to the agency’s strategic plan, related goals,  and desired outcomes;   Implement a pay-for-performance evaluation system to better link  individual pay to performance, and provide an equitable method for  appraising and compensating employees;    Provide adequate training and retraining for supervisors, managers,  and employees in the implementation and operation of the  performance management system;   Institute a process for ensuring ongoing performance feedback and  dialogue between supervisors, managers, and employees  throughout the appraisal period and setting timetables for review;     Assure that the agency’s performance management system results  in meaningful distinctions in individual employee performance;     Provide a means for ensuring that adequate agency resources are  allocated for the design, implementation, and administration of the  performance management system;     Assure that there is an independent and credible employee appeals    Assure that there are reasonable transparency and appropriate  accountability mechanisms in connection with the results of the  performance management process, including periodic reports on  internal assessments and employee survey results relating to  performance management and individual pay decisions while  protecting individual confidentiality;   Involve employees in the design of the system, to include employees  directly involved in validating any related implementation of the  system; and     Adhere to the merit principles set forth in section 2301 of title 5 of  the U.S. Code. (Two of these merit principles, which relate directly  to performance management—((b)2 and (b)(8A)—for example,  identify (1)  fair and equal treatment, regardless of factors such as  political affiliation, race, color, sex, age, or handicapping condition  and (2) protection against arbitrary action, personal favoritism, and  coercion for partisan political purposes, as necessary, in all aspects  of personnel management.  The merit principles are listed in their  entirety in appendix II.)
To assess the implementation of these safeguards and accountability  mechanisms, we obtained, reviewed, and analyzed DOD guidance and  other regulations provided by officials in the Office of the Director of  National Intelligence, the Office of the Under Secretary of Defense for  Intelligence, and the intelligence components in DOD. Specifically, we  reviewed and analyzed key documents such as DCIPS guidance and  policies, along with Office of Personnel Management guidance on  performance management systems. We also reviewed available DCIPS  training materials, including self-paced online trainings on the DCIPS Web  site: http://dcips.dtic.mil/index.html, attended the DCIPS Data  Administrator Training Course, and reviewed and analyzed DVDs of town  hall meetings recorded by the Office of Naval Intelligence. Because DCIPS  was in early implementation, we continuously reviewed the DCIPS Web  sites including the Under Secretary of Defense for Intelligence’s main Web  site for updates on training materials and policies. Finally, we obtained  relevant documentation and interviewed key Intelligence Community and  DOD officials from the following organizations:    The Associate Director of National Intelligence for Human Capital and  Intelligence Community Chief Human Capital Officer, Office of the  Director of National Intelligence;    The Under Secretary of Defense for Intelligence;    Under Secretary of Defense for Intelligence, Human Capital    Under Secretary of Defense for Intelligence, Chief of Staff  Directorate;    Defense Intelligence Agency, Directorate for Human Capital, Office    National Geospatial-Intelligence Agency, DCIPS Program    National Reconnaissance Office, Office of Human Resources;    National Security Agency, Human Resource Strategies;    Department of the Army, Intelligence Personnel Management    Department of the Navy, Civilian Personnel Programs;    Office of Naval Intelligence, Civilian Intelligence Personnel    Headquarters, U.S. Marine Corps, Intelligence Department,    Department of the Air Force, DCIPS Program Office;    Defense Security Service, Office of Human Resources.
section_title: Extent to which DOD has Mechanisms to Identify Employee Perceptions about DCIPS
paragraphs: To determine the extent that DOD had developed mechanisms to identify  and address employee perceptions about DCIPS, we evaluated two  primary sources of information.  First, we reviewed the results of existing  mechanisms DOD is using to address employee perceptions—which  included climate surveys for the Intelligence Community, town hall  meetings, along with information from the USD(I)’s Web site.  Second, we  conducted small group discussions with civilian intelligence personnel  within the department who were converting to DCIPS and administered a  short questionnaire to these participants to collect information on their  background, tenure with the federal service and DOD, and attitudes  toward DCIPS.
subsections: section_title: Discussion Groups
paragraphs: We conducted 26 discussion groups with defense civilian intelligence  employees and supervisors from 7 of the 10 defense intelligence  components converting to DCIPS.  For the purposes of our discussion  groups, we omitted defense civilian intelligence personnel from the Army,  Air Force, and the Defense Security Service because at the time of our  review, these components had not attained the same level of  implementation as the other defense intelligence components.
Additionally, for the defense intelligence components we did conduct  discussion groups with, we also conducted discussion groups with 6 of 7  defense intelligence components that had a field location.
Our overall objective in using the discussion group approach was to obtain  insight into employee and supervisor perceptions about DCIPS and its  implementation thus far. Discussion groups, which are similar in nature  and intent to focus groups, involve structured small group discussions that  are designed to obtain in-depth information about specific issues. The  information obtained is such that it cannot easily be obtained from a set of  individual interviews. From each location, we requested that each defense  intelligence component draw a systematic sample from its list of personnel  in order to obtain a sample of 8 to 12 employees and 8 to 12 supervisors to  participate.  At the majority of the discussion groups, we reached our goal  of meeting with 8 to 12 employees and supervisors in each discussion  group; however, since participation was not compulsory and at some  locations populations of employees to draw this random sample from  were small, in a few instances we did not reach the recommended 8  participants in the group. Discussions were held in a semi-structured  manner, led by a moderator who followed a standardized list of questions.  The discussions were documented by one or two other analysts at each  location.  For field sites, we selected components that had a concentration  of more than 25 employees.
section_title: Scope of Our Discussion Groups
paragraphs: In conducting our discussion groups, our intent was to achieve  saturation—the point at which we were no longer hearing new  information. As noted, we conducted 26 discussion groups with employees  and supervisors of DOD civilian intelligence personnel at the 13 DOD sites  we visited. Our design allowed us to identify themes, if any, in perceptions  held by employees and supervisors.  Discussion groups were conducted  between April 2009 and May 2009.
section_title: Methodology of Our Discussion Groups
paragraphs: A discussion guide was developed to facilitate the discussion group  moderator in leading the discussions. The guide helped the moderator  address several topics related to employees’ and supervisors’ perceptions  of the performance management system, including their overall perception  of DCIPS and the rating process, the training they received on DCIPS, the  communication they have with their supervisor, positive aspects of DCIPS,  and any changes they would make to DCIPS, among others. Each  discussion group began with the moderator greeting the participants,  describing the purpose of the study, and explaining the procedures for the  discussion group. Participants were assured that all of their comments  would be discussed in the aggregate or as part of larger themes that  emerged. The moderator asked participants open-ended questions related  to DCIPS. All discussion groups were moderated by a GAO analyst, while  at least one other GAO analyst observed the discussion group and took  notes. After each discussion group, the moderator and note taker reviewed  the notes from the session to ensure that the nature of the comments was  captured accurately.
section_title: Content Analysis
paragraphs: We performed content analysis of our discussion group sessions in order  to identify the themes that emerged during the sessions and to summarize  participant perceptions of DCIPS.  Specifically, at the conclusion of all our  discussion group sessions, we reviewed responses from each of the  discussion groups and created a list of themes. We then reviewed the  comments from each of the 26 discussion groups and assigned comments  to the appropriate themes, which were agreed upon by three analysts. The  responses were used in our evaluation and discussion of how civilian  employees perceive DCIPS.
section_title: Limitations
paragraphs: Discussion groups are not designed to (1) demonstrate the extent of a  problem or to generalize the results to a larger population, (2) develop a  consensus to arrive at an agreed-upon plan or make decisions about what  actions to take, or (3) provide statistically representative samples or  reliable quantitative estimates. Instead, discussion groups are intended to  provide in-depth information about participants’ reasons for holding  certain attitudes about specific topics and to offer insights into the range  of concerns about and support for an issue. Specifically, the projectability  of the information obtained during our discussion groups is limited for  three reasons. First, the information gathered during our discussion  groups on DCIPS represents the responses of only the employees and  supervisors present in our 26 discussion groups. The experiences of other  employees and supervisors under DCIPS who did not participate in our  discussion groups may have varied. Second, while the composition of our  discussion groups was designed to ensure a random sample of employees  and supervisors under DCIPS, our sampling did not take into account any  other demographic or job-specific information.  Third, our discussion  group samples are not generalizable to all component locations.
section_title: Use of a Questionnaire to Supplement Discussion Group Findings
paragraphs: We administered a questionnaire to discussion group participants during  the discussion group session to obtain further information on their  backgrounds and perceptions of DCIPS. The questionnaire was  administered and received from 238 participants of our discussion groups.  The purpose of our questionnaire was to (1) collect demographic data  from participants for the purpose of reporting with whom we spoke (see  table 1), and (2) collect information from participants that could not easily  be obtained through discussion, e.g., information participants may have  been uncomfortable sharing in a group setting.  Specifically, the  questionnaire included questions designed to obtain employees’  perceptions of DCIPS as compared with their previous personnel system,  the accuracy with which they felt their ratings would reflect their  performance, and management’s methods for conveying individual and  group rating information. Since the questionnaire was used to collect  supplemental information and was administered solely to the participants  of our discussion groups, the results represent the opinions of only those  employees who participated in our discussion groups. Therefore, the  results of our questionnaire cannot be generalized across the population of  DOD civilian intelligence personnel.
We conducted our review from November 2008 to November 2009 in  accordance with generally accepted government auditing standards. Those  standards require that we plan and perform the audit to obtain sufficient,  appropriate evidence to provide a reasonable basis for our findings and  conclusions based on our audit objectives. We believe that the evidence  obtained provides a reasonable basis for our findings and conclusions  based on our audit objectives.
section_title: Appendix IV: Defense Civilian Intelligence Personnel System Compared to the National Geospatial-Intelligence Agency System
paragraphs: The Defense Civilian Intelligence Personnel System (DCIPS) is largely  based on the National Geospatial-Intelligence Agency’s Total Pay  Compensation pay-for-performance system.  The National Geospatial- Intelligence Agency’s system was in existence for about 10 years (1999- 2009).  Table 2 provides a comparison of the two systems.
Table 2. DCIPS and Total Pay Compensation Comparison.
Pub. L. No. 104-201 §§1631-1632 (1996), as  amended by Pub. L. No. 106-398, § 1141 (2000)  (codified at 10 U.S.C. §§1601-1614).
Established by Rater and approved by  Reviewer(s)
Work roles and occupations crosswalk to OPM job  titles/categories.
Final Ratings will be inserted into Compensation  Work Bench—a software tool which utilizes an  algorithm to determine salary increases and  bonus awards.Any changes to pay increases  based on the algorithm, per DCIPS guidance,  must be documented, justified, and approved by  the PRA (see below)
Final ratings are inserted into a Total Performance  Compensation spreadsheet—software tool which  utilizes an algorithm to determine salary increases  and bonuses.  Any changes to salary increases  and bonuses, per guidance, must be documented,  justified, and approved by boards, office level  directors, and Agency review authority.
A Pay Pool PRA oversees one or more pay  pools, and conducts a summary review of all  salary decisions to assess conformance to  policy guidance and equity across pay pools.   The Pay Pool PRA approves the final pay pool  decisions.
section_title: Appendix V: Training Curriculum
paragraphs: The Under Secretary of Defense for Intelligence has designed several  training courses as part of a curriculum for the Defense Civilian  Intelligence Personnel System (DCIPS).  This curriculum covers various  aspects of DCIPS.  Table 3 illustrates the range of training courses  provided to Intelligence Community employees.
section_title: Appendix VI: Defense Civilian Intelligence Personnel System Comparison with the National Security Personnel System
paragraphs: In addition to the Defense Civilian Intelligence Personnel System (DCIPS),  DOD has also been implementing a pay-for-performance system for  civilian employees who were not in the Intelligence Community—the  National Security Personnel System.  Table 4 provides a comparison of the  two systems.
DCIPS and the National Security Personnel System: A Comparison  Pub. L. No. 104-201 §§1631-1632 (1996), as  amended by Pub. L. No. 106-398, § 1141  (2000) (codified at 10 U.S.C. §§1601-1614).
Pub. L. No. 108-136, § 1101 (2003), as  amended by Pub. L. No. 110-181, §  1106 (2008) (codified at 5 U.S.C. §§  9901-9904).
Established by Rater and approved by  Reviewer(s) before the pay pool process.
Established by the Pay Pool.  Pay Pools  are responsible for reviewing ratings of  record, share allocations, and payout  distribution.
Job titles aligned to four occupationally- based career groups.
One common pay band structure for all  occupations aligned to common work  categories/levels    4 career groups  comprised of 15 pay  schedules and 44 pay bands.
Employee payout in early January  DCIPS and the National Security Personnel System: A Comparison  Final Ratings will be inserted into  Compensation Work Bench—a software tool  which utilizes an algorithm to determine salary  increases and bonus awards.Any changes to  pay increases based on the algorithm must be  documented, justified, and approved by the  PRA (see below)
Also uses a Compensation Work Bench,  however employees are assigned a  number of shares based on their  performance rating; the value of one  share is determined by the overall  number of shares awarded.
Pay Pool Performance Review Authority  (PRA)
A Pay Pool PRA oversees one or more pay  pools, and conducts a summary review of all  salary decisions to identify potential issues  with regard to merit, consistency, or unlawful  discrimination among the pay pools under its  authority.  The Pay Pool PRA approves the  final pay pool decisions.
Provides oversight of several pay pools,  and addresses the consistency of  performance management policies  within a component, major command,  field activity, or other organization as  determined by the component.
section_title: Appendix VII: Comments from the Department of Defense
section_title: Appendix VIII: Comments from the Office of the Director of National Intelligence
paragraphs: Ms. Brenda S. Farrell Director, Defense Capabilities (U) This responds to the November 12,2009 request for review of a draft report entitled "DOD Civilian Personnel: Intelligence Personnel System Incorporates Safeguards, but Opportunities Exist for Improvement," GAO-I 0-134. (U) We appreciate the opportunity to comment on the draft report given the central role the ODNI played in recent development of Defense Civilian Intelligence Personnel System (DCIPS) and the National Intelligence Civilian Compensation Program (NICCP), and the importance of those companion efforts to the Intelligence Community's overall transformation. Please find attached our suggested edits to the body of the report and our official comments for inclusion in the appendices. (U) Overall, we believe the tenor of the report is fair and balanced, Highlights are overly negative and should be modified to more accurately reflect the tone In addition, we believe the report should also emphasize that and body of the report. DCIPS and the NICCP are intended to meet the goals of the Intelligence Reform and Terrorism Prevention Act of 2004. Thus, the ODNI and DoD are pursuing these efforts as a means of integrating and unifying the Community under a single, common human capital policy framework, where the IC's agencies and elements have historically operated under as many as six separate statutory personnel systems. GAO has noted that common human capital policies can act as a powerful tool in support of organizational transformation, and no where is this more critical than in the Ie. We also believe the report should emphasize that DCIPS was authorized by statute in 1997 and is separate and distinct from the National Security Personnel System; the latter was authorized several years later and has taken a much different path with respect to its design and implementation. (U) In 2001 GAO identified human capital as a "High Risk Area" across the executive branch, and it has been a champion of civil service reform ever since. We applaud your efforts in that regard and believe that NICCP/DCIPS is consistent with the spirit and intent of GAO's views. We also appreciate your comprehensive review and thoughtful recommendations; we take them seriously and will work with DoD to implementthem insofar as possible. (D) If you have any questions regarding this matter, please do not hesitate to contact me at (703) 275-2473.
Director of Legislative Affairs Comments of the Intelligence Community Chief Human Capital Officer on the GAO DRAFT Report: Intelligence Personnel System Incorporates Safeguards, but Opportunities Exist for Improvement ODNI appreciates the opportunity to comment on this GAO report. While the overall tenor of the report is fair and balanced, we do feel obligated to make a couple of important points. The design of DCIPS complies with all IC Directives, which were developed after an extensive period of collaboration among IC agencies and elements. The policy design represents a serious consideration of lessons learned from best practices found in existing successful alternative pay systems (with particular attention paid to NGA). Furthermore, the IC did gather input (in 2006) from hundreds of IC employees during the policy development and program design phases. It has always been our intention to continue soliciting additional employee suggestions for process improvement at the conclusion of each annual performance and pay cycle.
IC Directive 650 clearly lays out ten guiding principles which very closely align to the ten criteria chosen by GAO for their review. We agree that employees must be informed and educated on the details of the IC-wide program, as well as their department or agency's compensation and performance management systems. They are to be given the opportunity to provide feedback on the content of those systems and their implementation, and their feedback must be considered when those systems are developed, implemented, and administered. During the design and implementation phases of our change initiative, we made several changes based on employee feedback. For example, we decided to pass through to all employees the full general pay increase (unadjusted by performance results). We also modified our implementation schedules whenever the agencies or elements didn't feel their workforce was properly prepared to convert to DCIPS.
Change is often difficult for employees to accept, and there will always be some who are uncomfortable with the rate of change. But we believe this is more a reflection of where DCIPS is in its implementation schedule then any material defect in the design. The feedback that will be the most valuable will only come after we have been allowed to run all the way through a pay-for-performance cycle so we can evaluate the results.
Regarding safeguards, our ICDs clearly affirm the need for employee protections. We must provide rigorous oversight of the administration of IC compensation and performance management systems, including review mechanisms to guard against unlawful discrimination and partisan pressures, and other non-merit factors such as cronyism and favoritism. We must also ensure transparency of merit-based pay and performance decisions for employees. We acknowledge that DCIPS can and must be improved, and agree to work with USD(I) in an expeditious manner to address the areas you have identified. However, we strongly believe that DCIPS has been established on a strong foundation of policy directives and incorporates many best practices in its processes. We think DCIPS is off to a very solid start and will only get better.
section_title: Appendix IX: GAO Contact and Staff Acknowledgments
paragraphs: Brenda S. Farrell, (202) 512-3604, or farrellb@gao.gov.
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact named above, Marion Gatling (Assistant  Director), Beth Bowditch, Margaret Braley, Ryan D’Amore, Nicole Harms,  Cynthia Heckman, Mae Jones, James P. Krustapentus, Lonnie McAllister,  II, Spencer Tacktill, Carolyn Taylor, John Van Shaik, José Watkins, and  Greg Wilmoth made key contributions to this report.
section_title: Related GAO Products
paragraphs: Human Capital: Monitoring of Safeguards and Addressing Employee  Perceptions Are Key to Implementing a Civilian Performance  Management System in DOD. GAO-10-102. Washington, D.C.: October 28,  2009.
Human Capital: Continued Monitoring of Internal Safeguards and an  Action Plan to Address Employee Concerns Could Improve  Implementation of the National Security Personnel System. GAO-09-840.  Washington, D.C.: June 25, 2009.
Human Capital: Improved Implementation of Safeguards and an Action  Plan to Address Employee Concerns Could Increase Employee  Acceptance of the National Security Personnel System. GAO-09-464T.  Washington, D.C.: April 1, 2009.
Questions for the Record Related to the Implementation of the  Department of Defense’s National Security Personnel System.  GAO-09-669R. Washington, D.C.: May 18, 2009.
High-Risk Series: An Update. GAO-09-271. Washington, D.C.: January  2009.
Human Capital: DOD Needs to Improve Implementation of and Address  Employee Concerns about Its National Security Personnel System.  GAO-08-773. Washington, D.C.: September 10, 2008.
Human Capital: DOD Needs Better Internal Controls and Visibility over  Costs for Implementing Its National Security Personnel System.  GAO-07-851. Washington, D.C.: July 16, 2007.
Office of Personnel Management: Key Lessons Learned to Date for  Strengthening Capacity to Lead and Implement Human Capital  Reforms. GAO-07-90. Washington, D.C.: January 19, 2007.
Post-Hearing Questions for the Record Related to the Department of  Defense’s National Security Personnel System (NSPS). GAO-06-582R.  Washington, D.C.: March 24, 2006.
Human Capital: Observations on Final Regulations for DOD’s National  Security Personnel System. GAO-06-227T. Washington, D.C.: November  17, 2005.
Human Capital: Designing and Managing Market-Based and More  Performance-Oriented Pay Systems. GAO-05-1048T. Washington, D.C.:  September 27, 2005.
Human Capital: DOD’s National Security Personnel System Faces  Implementation Challenges. GAO-05-730. Washington, D.C.: July 14, 2005.
Questions for the Record Related to the Department of Defense’s National  Security Personnel System. GAO-05-771R. Washington, D.C.: June 14,  2005.
Questions for the Record Regarding the Department of Defense’s  National Security Personnel System. GAO-05-770R. Washington, D.C.:  May 31, 2005.
Post-Hearing Questions Related to the Department of Defense’s National  Security Personnel System. GAO-05-641R. Washington, D.C.: April 29,  2005.
Human Capital: Preliminary Observations on Proposed Regulations for  DOD’s National Security Personnel System. GAO-05-559T. Washington,  D.C.: April 14, 2005.
Human Capital: Preliminary Observations on Proposed Department of  Defense National Security Personnel System Regulations. GAO-05-517T.  Washington, D.C.: April 12, 2005.
Human Capital: Preliminary Observations on Proposed DOD National  Security Personnel System Regulations. GAO-05-432T. Washington, D.C.:  March 15, 2005.
Posthearing Questions Related to Strategic Human Capital  Management. GAO-03-779R. Washington, D.C.: May 22, 2003.
Human Capital: DOD’s Civilian Personnel Strategic Management and  the Proposed National Security Personnel System. GAO-03-493T.  Washington, D.C.: May 12, 2003.