Human Capital: OPM Needs to Better Analyze and Manage Dual Compensation Waiver Data
Published: 2014-12-29T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal workforce has a large number of retirement-eligible employees that could potentially result in a loss of skills hindering federal agencies' ability to meet their missions. Agencies can mitigate this challenge by hiring uniformed and civil service retirees. Generally, when an agency reemploys a retired civil service employee, their salary rate is subject to offset by the amount of the annuity received. Upon request, OPM has authority to waive offsets, allowing dual compensation (annuity and full salary). Dual compensation is also permitted under other authorities not administered by OPM, such as the authority provided to Defense.
GAO was asked to provide information on the use of rehired annuitants and OPM's dual compensation waiver authority. This report: (1) describes the trends in rehired annuitants for fiscal years 2004 to 2013; (2) identifies the extent to which OPM analyzes trends in the reasons for waiver requests, and provides guidance to agencies, and (3) evaluates the extent to which OPM ensures agencies' compliance with the conditions under which the waivers were granted. GAO analyzed OPM data, reviewed OPM documentation, and interviewed OPM officials.
section_title: What GAO Found
paragraphs: Agencies' use of reemployed annuitants has increased, with the number of on-board retired uniformed and civil service annuitants increasing from over 95,000 in fiscal year 2004 to around 171,000 in fiscal year 2013 (from about 5 percent to 8 percent of the federal workforce). This is inclusive of reemployed annuitants with and without dual compensation waivers. The Department of Defense (DOD) accounted for about 80 percent of rehired annuitants in 2013; ninety-eight percent of which were retired uniformed service members whose retirement pay is not subject to reduction. More than half of the total reemployed civilian annuitants in 2013, including DOD's civil service reemployed annuitants, would not be covered under the Office of Personnel Management's (OPM) dual compensation waiver authority.
OPM officials said that they do not conduct trend analysis of dual compensation waiver requests and they provide related guidance only as needed. While OPM is not required to conduct trend analysis, given the increasing number of retirement-eligible federal employees, without such analysis OPM may be missing opportunities to analyze information that can inform decisions about the human capital management tools it develops and provides for agencies government-wide. OPM's ability to conduct trend analysis is limited by its lack of a systematic and reliable process for maintaining dual compensation waiver documentation. The lack of policies and procedures is inconsistent with federal internal control standards and made OPM unable to timely retrieve the documentation for GAO's review.
OPM is not required by statute to monitor agencies' implementation of individual dual compensation waivers to determine whether relevant requirements are followed. OPM regulations provide for limited oversight in delegated situations, where waiver authority is delegated to agencies without a time limit.
section_title: What GAO Recommends
paragraphs: GAO recommends that OPM analyze trends in agencies' use of dual compensation waivers and establish policies and procedures for maintaining waiver documentation. OPM did not concur with the first and partially concurred with the second recommendation. GAO maintains that OPM should implement these actions as discussed in the report.

section_title: Letter
paragraphs: The federal workforce is aging. This has created a large number of  retirement-eligible employees and a potential loss of skills and experience  that could hinder agencies’ ability to meet their missions. By September  2017, nearly 31 percent of the federal workforce that was on board in  2012 is projected to be eligible for retirement. Increased federal  retirements can pose both human capital challenges and opportunities to  improve workforce planning. Strategic workforce planning that is  integrated with broader organizational strategic planning is essential for  ensuring that agencies have the mix of talent, skill, and experience they  need to execute their missions cost-effectively and to achieve program  goals, especially as agencies face long-term fiscal constraints.
5 U.S.C. § 8344(i) and § 8468(f). For information on other dual compensation waiver  authorities, see GAO, Reemployment of Retirees: Six Agencies’ Use of Dual  Compensation Waiver Authority is Limited, GAO-12-855R (Washington, D.C.: Sept. 10,  2012). not administered by OPM (e.g., the Department of Defense authority  under 5 U.S.C. § 9902(g)).
You asked us to provide information on reemployed annuitants in the  federal workforce and OPM’s management of its dual compensation  waiver authority. This report: (1) describes the trends in all reemployed  annuitants for fiscal years 2004 to 2013; (2) identifies the extent to which  OPM analyzes trends in the reasons for dual compensation waiver  requests under its authority, and provides guidance to agencies, as  appropriate; and (3) evaluates the extent to which OPM ensures  agencies’ compliance with the conditions under which the waivers were  granted.
To describe the trends in agencies’ use of all reemployed annuitants— both individuals who did and did not receive dual compensation, including  retired uniformed service members whose retirement or retainer pay is  not subject to reduction—we analyzed data from OPM’s database, the  Enterprise Human Resources Integration (EHRI) Statistical Data Mart, for  fiscal years 2004 to 2013. We compared data on the number of  annuitants and their types of occupations to all federal employees. In  addition, we conducted interviews with OPM officials and reviewed our  prior reports on workforce issues. To evaluate the extent to which OPM  analyzes trends in the reasons for waiver requests under its authority and  provides related guidance, we reviewed OPM’s policies and procedures  for evaluating waiver requests, analyzed documentation from OPM, and  interviewed officials. To evaluate the extent to which OPM ensures  compliance with conditions under which the waivers were granted, we  reviewed relevant statutes, regulations, and OPM’s policies and  procedures for reviewing waiver requests, and we interviewed OPM  officials. We also reviewed the 16 waiver decision letters that OPM was  able to provide. According to OPM officials, the waivers were selected to  represent examples of the different purposes for which waivers may be  authorized. We were unable to assess whether the examples OPM  provided were representative of the universe of waiver requests because  of the conditions in which OPM maintains the files. We compared  information gathered from reviewing these letters as well as interviews  with OPM officials to the statutory and regulatory provisions, OPM’s  policies and procedures, and internal controls standards for the federal  government.appendix I.
For more information on our scope and methodology, see  For the purposes of this review, we determined that the data used in our  analyses were reliable. We determined that EHRI was sufficiently reliable  to report on trends for all reemployed annuitants, but was not reliable  enough to describe trends among reemployed annuitants authorized to  receive dual compensation compared to those with salary offsets or  annuity reductions. Our data reliability assessment included reviewing  relevant documentation, conducting interviews with knowledgeable OPM  officials, and conducting electronic testing of the data to identify obvious  errors or outliers.
We conducted this performance audit from April 2014 to December 2014  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.
subsections: section_title: Background
paragraphs: OPM may waive application of the salary offset requirement for  reemployed annuitants—thereby permitting dual compensation—pursuant  to 5 U.S.C. § 8344(i) and § 8468(f). Under these authorities, agencies  may request that OPM waive the offset requirement for individuals on a  case-by-case basis, or, that OPM delegate to the agency head the  authority to waive the offset requirement for individuals on a case-by-case  basis. The statutes provide OPM the authority to consider and approve  agencies’ waiver requests. OPM evaluates and may approve agency  requests for waivers on a case-by-case basis for four authorized  purposes: need to retain an individual, and other unusual circumstances.
OPM evaluates and may approve agency requests for delegation of  authority to waive salary offsets on a case-by-case basis for two  authorized purposes: other unusual circumstances.
Agencies requesting waivers or waiver authority must provide purpose- specific information about the circumstances for which the waiver or  authority is requested, as summarized in table 1.
In order to obtain delegated authority to waive salary offsets, an agency  must describe an emergency or other unusual circumstance comparable  to the third and fourth categories above. In addition to the purpose- specific information, agencies must identify the occupations, grades, and  locations of positions that might be filled under the delegated authority  and provide a statement of expected duration of reemployment to be  approved under the requested authority. For individual requests, agencies  must identify the individual for whom the exception is requested, the  appointing authority to be used, and the position to which he or she will  be appointed. In addition, the agency must demonstrate that the annuitant  will not agree to reemployment without the waiver. Agencies may also  seek to extend previously granted delegated authority.
Under 5 C.F.R. 553.201(g), agencies may also request extensions for  previously granted individual waivers. Agencies must show that the  conditions justifying the original waiver still exist. During this process,  OPM asks the agency for the reason why an extension is needed and  why other staffing options were unavailable.
Should the delegated agreement between OPM and the agency permit  the agency to renew individual waivers granted by the agency, the  agency may grant an extension of individual waivers.
There are other authorities permitting dual compensation for which OPM  does not exercise approval authority or otherwise regulate. For example,  government-wide waiver authority was contained in the National Defense  Authorization Act (NDAA) for Fiscal Year 2010 and allows agencies to  waive offset requirements on a temporary basis. Although that authority  was set to expire in October 2014, Congress recently passed an  extension of that authority through December 2019. In 2012, we reported  on the use of the NDAA authority and a few examples of other waiver  authorities which OPM does not manage, including waiver authorities  unique to Foreign Service annuitants and the Nuclear Regulatory  Commission. Additionally, the Department of Defense (DOD) does not  seek waiver approval from OPM because DOD has its own authority  which permits the reemployment of annuitants without subjecting salaries  to offset.
section_title: Use of Reemployed Annuitants Increased Between 2004 and 2013 with Most Concentrated in the Department of Defense
paragraphs: Our analysis of OPM’s data indicate that agencies’ use of reemployed  annuitants has increased, with the number of on-board uniformed and  civil service annuitants rising from over 95,000 in September 2004 to  around 171,000 in September 2013 (from about 5 percent to 8 percent of  the federal workforce). This is inclusive of reemployed annuitants with  and without dual compensation waivers, as well as retired uniformed  service members whose retirement or retainer pay is not subject to  reduction. More than half of these reemployed civilian annuitants,  specifically DOD’s civil service reemployed annuitants, would not be  covered under OPM’s waiver authority. DOD accounted for 83 percent of  the increase in annuitants from 2004 to 2013— of this increase,  approximately 3 percent were civil service annuitants and about 98  percent were uniformed service annuitants. In comparison, our analysis of  OPM’s data found that the overall size of the permanent career federal  workforce, as reflected in the number of employees in the 24 Chief  Financial Officers (CFO) Act agencies, increased about 11 percent over  the same period and that DOD accounted for about 40 percent of this  increase. The increase in reemployed annuitants reflects agencies’  greater reliance on all types of annuitants, including former uniformed  service members covered by military pension systems as well as retirees  from federal civilian service covered by the Federal Employees’  Retirement System (FERS) and the Civil Service Retirement System  (CSRS). Use of annuitants was concentrated in the three largest  agencies—DOD, Veterans Affairs (VA), and Homeland Security (DHS)— which collectively employed about 92 percent of annuitants in 2013, with  nearly 80 percent employed at DOD alone. Most of the increased reliance  on annuitants in DOD is tied to reemployment of uniformed service  members: 98 percent of DOD’s annuitants were retired uniformed service  members.
Our analysis also indicates that the other 21 CFO Act agencies saw  increases in reemployed annuitants, as well. For these agencies, the  number of on-board annuitants increased from over 23,000 in 2004 to  about 36,000 in 2013 (about 2 to 3 percent of these agencies’ workforce).  Although these agencies collectively relied more heavily on civil service  annuitants than VA and DHS, reemployed uniformed service members  still comprised nearly 79 percent of the on-board annuitants among these  agencies in 2013. Greater reliance on annuitants suggests recent losses  in key staff and institutional knowledge due to retirement. The number of  voluntary retirements at the 24 CFO Act agencies increased in recent  years, from 41,735 employees in 2004 to 58,313 in 2013 (2.4 to 3 percent  of these agencies’ workforce). In addition, many of these agencies  experienced hiring freezes between 2011and 2013, limiting their options  for replacing staff who retired or separated for other reasons. In response  to these circumstances and the increasing size of the retirement eligible  workforce—about 30 percent eligible to retire in five years—agencies appear to have turned to annuitants to bridge potential staffing gaps.Figure 1 shows the number of annuitants in the federal workforce from  2004 to 2013.
Our analysis of OPM data shows that in 2013, 83 percent of on-board  annuitants were in administrative, technical, or professional occupations,  which include positions related to administration and management,  information technology, and engineering, among others. Among civil  service annuitants on-board in 2013, aggregate annualized salaries were  highest in DOD, at $113.4 million (0.2 percent of DOD employees’  aggregate salaries) compared to $246.6 million among the other CFO act  agencies collectively (or 0.2 percent of employees’ aggregate salaries).  Among uniformed service annuitants on-board in 2013, aggregate  annualized salaries were also highest in DOD, at $10.2 billion (18.9  percent of DOD employees’ aggregate salaries) compared to $2.3 billion  among the other CFO Act agencies collectively (2.3 percent of  employees’ aggregate salaries). Similar to career employees, reemployed  annuitants generally had full-time schedules. However, most civil service  annuitants were also on term limited appointments, generally serving from  one to five years after retirement. Figure 2 shows the salary costs of  annuitants as a percentage of agencies aggregate annualized salary  rates.
section_title: OPM Does Not Conduct Trend Analysis of Dual Compensation Waiver Requests and Has Not Developed Policies and Procedures to Manage Waiver Documentation
paragraphs: OPM officials said that they do not conduct trend analysis of dual  compensation waiver requests because each waiver is so unique that  there is no trend or pattern to analyze. However, in our review of the  small sample of 16 waiver request submissions provided by OPM, we  found that “other unusual circumstance” was among the most often cited  reasons for requesting a waiver and agencies were requesting waivers for  individuals in administrative or professional occupations. An example of  an unusual circumstance cited by agencies requesting a delegation is an  urgent need to rehire annuitants to support the hiring of critical staff. For  example, DHS cited a need to rehire investigative program specialists to  support the hiring of law enforcement officers to meet a Congressional  mandate. In another example, OPM cited a need to hire retired judges to  help review applications for administrative law judge vacancies. This  suggests that there may be some benefit to conducting analysis of these  waivers because there may be trends that OPM is currently not aware of.  While there is no specific statutory requirement for OPM to conduct trend  analysis, without such analysis, OPM may be missing opportunities to  analyze this information that can help guide the human capital  management tools and guidance it develops and provides to agencies  government-wide. Ensuring OPM is identifying challenges and assisting  agencies as issues emerge is especially important given the increasing  number of retirement-eligible employees across the federal government.  As we have previously reported, unanticipated retirements could cause  skills gaps to further widen and adversely impact the ability of agencies’  to carry out their diverse responsibilities.
With regard to guidance provided to agencies, OPM officials said that  they occasionally identify or provide other tools or resources for human  capital workforce management to agencies requesting waivers, but they  do not do so routinely. For example, OPM may provide information on  advertising tools or other resources to agencies experiencing difficulty  hiring qualified candidates. OPM officials said that agency officials  submitting waiver requests are generally familiar with OPM’s tools or  guidance. However, we have previously found that agencies’ chief human  capital officers were either unfamiliar with some OPM tools or guidance,  or found the tools or guidance fell short of their agencies’ needs. OPM  officials said that on infrequent occasions they refer agencies that make  repeated requests to extend dual compensation waivers to OPM’s  workforce planning division for consultation on how to use its workforce  management tools more strategically. As we have recently reported, in an  era of limited fiscal resources, it is critical that OPM and agencies are  developing and using the most cost-effective tools to ensure agencies  can meet their missions.
subsections: section_title: OPM Has Not Developed Effective Policies and Procedures for Managing Waiver Request Documentation
paragraphs: We found that OPM lacks effective policies and procedures for  documenting waiver requests which may hamper its ability to conduct  trend analysis. OPM officials said that they do not have a systematic and  reliable process for maintaining dual compensation waiver  documentation. Specifically, OPM officials said they do not have a  standard policy for how dual compensation waivers are labeled or saved  and, therefore must individually review thousands of electronic  documents in their document management system database to identify  the waiver records. Officials said the waiver requests and supporting  materials are submitted to OPM and assigned to individuals for  preliminary review and analysis. OPM staff save these in the document  management system, but save documents inconsistently, sometimes  merging the request and documentation and saving the evidence  separately, without any standard labeling. Officials said that staff create a  routing slip, called an executive decision summary, for each file. OPM  staff use the routing slip to record the names of officials and dates of their  review to recommend approval or denial. However the routing slip may or  may not be saved with the corresponding waiver materials and does not  include summary information about the waiver request.
Federal internal control standards state that agencies should clearly  document significant transactions and events and the documentation  should be readily available for examination. These actions help  organizations run their operations efficiently and effectively, report reliable  information about their operations, and comply with applicable laws and  regulations.  Agencies can achieve this by developing and implementing  policies ensuring accountability for records, appropriate documentation of  transactions, and sufficient information and communication about  programs. However, OPM does not have such a policy to guide its  management of the dual compensation waiver files. As a result, OPM was  unable to retrieve these files in a timely manner for our review.
section_title: OPM Limits Duration of Waivers Approved In Lieu of Monitoring Agency Compliance
paragraphs: According to OPM officials, OPM does not monitor the agency’s  implementation of an individual dual compensation waiver once a waiver  is granted. The officials said OPM may require agencies to submit  documentation before approving delegated waiver authority in order to  determine whether the agency is complying with relevant requirements.  OPM officials said OPM’s role is limited to application review and  approval of dual compensation waiver requests and extensions, and that  it does not have a role in their implementation or oversight. OPM officials  also said individual and delegated waiver requests may be approved,  pending specific actions first taken by the requesting agency. However,  OPM officials said it is the requesting agency’s responsibility to ensure  that it meets the conditions outlined in the dual compensation waiver  approval letter. Officials said there was one exception—OPM requires  and reviews evidence from agencies requesting approval to extend a  previously granted waiver beyond the original term to determine if the  circumstances justifying the waiver still exist.
The statutory provisions authorizing OPM to grant individual and  delegated waiver requests do not specifically require OPM to conduct  oversight or monitoring of how agencies implement the authority granted  by OPM. However, OPM is generally required to maintain oversight over  delegated activities under 5 U.S.C. § 1104(b)(2).  Accordingly, OPM  regulations recognize the need for some oversight where OPM delegates  waiver authority to an agency with no time limit on that grant of authority.  In those instances, OPM regulations state that it may terminate an  agency’s delegated authority if it determines that the circumstances  justifying the delegation have changed substantially, or if the agency has  failed to manage the authority in accordance with the law, regulations, or   OPM officials stated that they do establish  the terms of the agreement.time limits on delegation agreements and, in the one delegated waiver  example OPM provided for our review, the waiver was authorized for a  specific period. Given OPM’s document management challenges, as  previously discussed, OPM was unable to provide us with a  representative sample of waiver approval letters to determine whether  OPM consistently established time limits on the delegation of waiver  authority provided to agencies and, if not, whether there were instances  where monitoring or oversight was necessary.
section_title: Conclusions
paragraphs: Given the budgetary and long-term fiscal challenges facing the nation,  agencies must identify options to meet their missions with fewer  resources. While federal agencies shoulder this responsibility, OPM,  through its authority to review and approve dual compensation waivers,  as well as its responsibility to assist agencies with all aspects of  human  capital management, should identify trends in waiver use and develop  cost-effective human capital tools and resources, where appropriate.  These objectives cannot be achieved without analysis of dual  compensation waiver information. However, OPM has not developed  adequate policies and procedures for the management of dual  compensation waiver documentation. Given the increasing use of  reemployed annuitants and the impending wave of retirements, OPM is  missing an opportunity to leverage the information gained through the  review and approval of dual compensation waivers to inform and improve  upon the assistance it provides federal agencies in their management of  human capital.
section_title: Recommendations for Executive Action
paragraphs: To improve OPM’s assistance to agencies and management of its dual  compensation waiver program, we recommend that the Director of OPM  take the following two actions:  1.  Analyze dual compensation waivers to identify trends that can inform  OPM’s human capital management tools.  2.  Establish policies and procedures for documenting the dual  compensation waiver review process.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this product to OPM for review and comment. In  written comments, which are reprinted in appendix II, OPM did not concur  with one recommendation and partially concurred with one. OPM also  provided technical comments, which we incorporated as appropriate.
OPM stated that it did not concur with our recommendation to analyze  dual compensation waivers to identify trends that can inform OPM’s  human capital management tools. OPM noted that the waivers are  authorized for specific purposes and that the statue does not require  OPM to conduct any trend analysis. OPM also noted that it does not grant  a large number of waivers and that those patterns are identified when  particular circumstances, like natural disasters prompt agencies to seek  waivers for similar issues. As noted in the report, we agree that there are  clearly defined purposes and that there is no statutory requirement for  OPM to conduct a trend analysis. While our analysis did find that most of  rehired annuitants were likely hired under an authority maintained by the  Department of Defense, OPM was unable to provide evidence of the  number of individual or delegated waivers that it had approved in any  year, including currently active waivers. Further, given the likelihood of  future agency requests for dual compensation waivers for natural  disasters, the patterns OPM identified after Hurricane Katrina and  potential lessons learned are evidence of the kind of insight that could be  informing OPM’s other human capital management tools or resources.  We continue to believe that OPM should analyze waivers and identify  trends that could improve its other tools.
OPM stated that it partially concurred with our recommendation to  establish policies and procedures for documenting the dual compensation  waiver review process. OPM noted that it has policies and procedures for  adjudicating waivers and that it is in compliance with the National  Archives and Records Administration policies. However, OPM was unable  to provide evidence of any such policies and procedures. In fact, OPM  could not demonstrate adherence to federal internal control standards  stating agencies should clearly document significant transactions and  events and the documentation should be readily available for  examination. Further, while OPM was able to ultimately produce 16  waiver decision letters, it was unable to provide a single complete,  agency waiver application along with the supporting documentation and  corresponding OPM decision letter. OPM also could not identify the total  number of waivers for any given time period, meaning that even if OPM  individually reviewed the thousands of documents in its document  management system, it would not know if all materials were maintained  appropriately. We continue to believe that OPM should take action to fully  address this recommendation and comply with federal internal control  standards.
We are sending copies of this report to the appropriate congressional  committees and to the Director of the Office of Personnel Management. In  addition, the report will be available at no charge on the GAO website at  http://www.gao.gov.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 7 days from the  report date. At that time, we will send copies to the Committee on  Homeland Security and Government Affairs. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report please contact  me at (202) 512-2717 or jonesy@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 key contributions to this report  are listed in appendix III.
section_title: Appendix I: Scope and Methodology
paragraphs: To analyze reemployed annuitant trends, we used the Office of Personnel  Management’s (OPM) Enterprise Human Resources Integration (EHRI)  Statistical Data Mart, which contains personnel action and on board data  for most federal civilian employees. We analyzed agency-level EHRI data  for the 24 Chief Financial Officers (CFO) Act agencies, which represent  the major departments (such as the Department of Defense) and most of  the executive branch workforce. We analyzed EHRI data starting with  fiscal year 2004 because personnel data for the Department of Homeland  Security (which was formed in 2003) had stabilized by 2004. We selected  2013 as the endpoint because it was the most recent, complete fiscal  year of data available during most of our review.
We classified annuitants in two ways:  1.  Military only annuitants (retired uniformed service officers or service  enlisted members who are receiving retired or retainer pay).2.  Military and Federal Employees’ Retirement System or Civil Service  Retirement System annuitants (including individuals with all valid  EHRI annuitant codes).
We analyzed on-board trends for most of the executive branch workforce,  including temporary and term-limited employees. However, we focused  on career permanent employees in our analysis of separation trends and  retirement eligibility because these employees comprise most of the  federal workforce and become eligible to retire with a pension, for which  temporary and term limited employees are ineligible. To calculate the  number of federal civilian employees, we included all on board staff,  regardless of their pay status. In addition, we excluded Foreign Service  workers at the State Department since those employees were not  included in OPM data for the years after 2004.
We examined on-board and annuitant counts, voluntary separations,  adjusted base pay, and retirement eligibility trends by agency, and  occupation. Occupational categories include Professional, Administrative,  Technical, Clerical, Blue Collar, and Other white-collar (PATCO)  groupings and are defined by the educational requirements of the  occupation and the subject matter and level of difficulty or responsibility of  the work assigned. Occupations within each category are defined by  OPM.
To calculate voluntary separation rates, we added the number of career  permanent employees with personnel actions indicating they had  separated from federal service with either mandatory or voluntary  retirement personnel actions and divided that by the 2-year on board  average. To calculate retirement eligibility for the next 5 years, we  computed the date at which the employee would be eligible for voluntary  retirement at an unreduced annuity, using age at hire, years of service,  birth date, and retirement plan coverage.
We used the EHRI adjusted base pay to examine the annualized salaries  of on-board individuals. It is important to note that this amount does not  necessarily reflect the actual amount annuitants were paid in the fiscal  year, but rather, the total annualized salary of annuitants in the data.
We assessed the reliability of the EHRI data through electronic testing to  identify missing data, out of range values, and logical inconsistencies. We  also reviewed our prior work assessing the reliability of these data and  interviewed OPM officials knowledgeable about the data to discuss the  data’s accuracy and the steps OPM takes to ensure reliability. On the  basis of this assessment, we believe the EHRI data we used are  sufficiently reliable for the purpose of this report.
To evaluate the extent to which OPM analyzes trends in the reasons for  waiver requests and provides related guidance, we reviewed OPM’s  policies and procedures for evaluating waiver requests, analyzed  documentation from OPM, and interviewed officials.
To evaluate the extent to which OPM ensures compliance with conditions  under which the waivers were granted, we reviewed relevant statutes,  regulations, OPM’s policies and procedures for reviewing waiver  requests, and interviewed OPM officials. We also reviewed the 16 waiver  decision letters that OPM was able to provide. According to OPM officials,  the waivers were selected to represent examples of the types of requests  for the different authorized waiver purposes. We were unable to assess  whether the examples OPM provided to us were representative of the  universe of waiver requests because of the conditions in which the files  are maintained. We compared information gathered from reviewing these  letters as well as interviews with OPM officials to the statutory and  regulatory provisions, OPM’s policies and procedures, and internal  controls standards for the federal government.
section_title: Appendix II: Comments from the Office of Personnel Management
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgment
paragraphs: In addition to the individual named above, Chelsa Gurkin (Assistant  Director), Anthony Patterson (Analyst-in-Charge), Vida Awumey, Sara  Daleski, Karin Fangman, Kimberly McGatlin, and Rebecca Shea made  major contributions to this report.