Oil and Gas Oversight: Interior Has Taken Steps to Address Staff Hiring, Retention, and Training but Needs a More Evaluative and Collaborative Approach
Published: 2016-09-29T00:00:00

Fast Facts:
The explosion on the Deepwater Horizon oil rig in 2010 stressed the importance of supervising oil and gas production. To that end, the Department of the Interior has been trying to hire, retain, and train qualified staff to oversee these activities. For example, it has increased salaries for key staff and is helping to pay off more employee student loans. However, we found that Interior doesn't know if these efforts are working. It also hasn't determined whether its training programs are effective.
We recommend that Interior evaluate its hiring incentives and training programs, and increase collaboration across its offices.

Highlights:
section_title: Why GAO Did This Study
paragraphs: The explosion onboard the Deepwater Horizon drilling rig in April 2010 highlighted the importance of effective oversight of oil and gas activities, but Interior has faced challenges in hiring, retaining, and training staff responsible for such oversight. Since 2011, Interior's management of federal oil and gas resources has been on GAO's list of program areas that are at high risk, partly because of human capital challenges. In a February 2015 update to the list, GAO found that Interior had begun to address these challenges but needed to do more.
GAO was requested to review the status of Interior's human capital challenges. This report examines Interior's efforts to (1) resolve its hiring and retention challenges for key oil and gas staff and (2) address its training needs for such staff. GAO reviewed regulations, reports, and department documents; analyzed Interior and OPM information; and interviewed department officials.
section_title: What GAO Found
paragraphs: The Department of the Interior has taken steps to resolve its hiring and retention challenges for key staff engaged in oil and gas activities, but it has not evaluated the effectiveness of its efforts and has missed opportunities to collaborate within the department for resolving these challenges. Specifically, Interior has taken steps to address two underlying factors—lower salaries and a lengthier hiring process compared with industry—that impede its ability to hire and retain such staff. For example, in fiscal year 2012 Interior began using special salary rates to give higher pay to certain key staff in its bureaus that oversee oil and gas resources: the Bureau of Land Management (BLM), Bureau of Safety and Environmental Enforcement (BSEE), and Bureau of Ocean and Energy Management (BOEM). To bolster compensation further, some bureaus increased the number of staff receiving student loan repayments and other incentives. Officials said these efforts in fiscal year 2015 filled positions, but they had not evaluated the effectiveness of their efforts. As a result, Interior cannot determine how or whether it should alter its approach. Regarding the lengthy hiring process, the bureaus recently adopted new human resources software that may provide them with better data to track their hiring process. As the bureaus sought to improve hiring and retention, Interior's Office of Policy, Management and Budget—which is charged with managing human resources and addressing cross-cutting issues—missed opportunities to facilitate collaboration across the bureaus. For example, two bureaus used separate recruitment teams that did not collaborate. Senior officials in the office did not identify any collaboration mechanism that they used to bring the bureaus together to discuss shared challenges. Without such a mechanism, the bureaus may continue to address these challenges through fragmented and potentially duplicative efforts.
Interior has trained key oil and gas staff without fully evaluating the bureaus' staff training needs or the training's effectiveness, according to officials, and Interior has provided limited leadership in facilitating the bureaus' sharing of training resources. The Federal Workforce Flexibility Act of 2004 and Office of Personnel Management (OPM) regulations require agencies to evaluate their training efforts, but Interior's Office of Policy, Management and Budget has not performed these evaluations. In addition, none of the bureaus have evaluated training, according to officials, and only one developed technical competencies for staff as directed in Interior's Departmental Manual. Further, BSEE's training for inspectors does not include proficiency examinations or certifications, according to officials, although two oversight bodies recommended implementing a certification program in 2010. Interior has provided limited leadership in facilitating the sharing of training resources across the bureaus, appearing to miss opportunities that could improve the use of these resources. For example, BOEM does not have staff to develop curricula or evaluate training efforts and, as of July 2016, BSEE had 6 full-time staff in their training program, according to officials. These bureaus conduct limited evaluations. In contrast, BLM had 59 staff in its training program and has the capacity to evaluate their training efforts, according to officials. Without further evaluation and leadership, Interior may not be able to ensure key oil and gas staff are adequately trained for their oversight tasks, and the bureaus may miss opportunities to share resources.
section_title: What GAO Recommends
paragraphs: GAO is recommending that Interior evaluate the effectiveness of special salary rates and incentives, evaluate its bureaus' training programs, develop technical competencies for all key oil and gas staff, evaluate the need for a BSEE inspector certification program, and better facilitate collaboration across the bureaus. Interior agreed with one recommendation, partially agreed with 3 others, and disagreed with one recommendation. GAO continues to believe that the recommendations are valid, as discussed in the report.

section_title: Letter
paragraphs: The explosion and fire onboard the Deepwater Horizon drilling rig in April  2010––which resulted in 11 deaths, multiple serious injuries, and the  largest marine oil spill in the history of the United States––highlighted the  importance of effective oversight of oil and gas activities on federal lands  and waters. The Department of the Interior (Interior) oversees such  activities, which provide important sources of energy for the United  States. Onshore, Interior oversees oil and gas activities for about 700  million subsurface acres, including minerals beneath more than 245  million federally managed surface acres. Offshore, Interior oversees  similar activities for more than 1.7 billion acres in the waters of the Outer  Continental Shelf, which includes submerged lands in federal waters off  the coast of Alaska, the Gulf of Mexico, and the Atlantic and Pacific  coasts. Interior’s oversight responsibilities include reviewing and  approving oil and gas companies’ (operators) plans and applications for  permits to drill; inspecting oil and gas operations, such as drilling rigs and  production platforms, to ensure compliance with safety and environmental  regulations; and determining how much oil and gas is produced from  federal lands and waters to calculate royalties and other revenues due to  the federal government from these resources. Interior reported that in  2015 the U.S. Department of the Treasury received $7.2 billion from  royalties and other payments related to oil and gas development on  federal lands and waters.
Three bureaus within Interior share oversight responsibilities for activities  related to federal oil and gas resources: the Bureau of Land Management  (BLM), the Bureau of Safety and Environmental Enforcement (BSEE),  and the Bureau of Ocean Energy Management (BOEM). BLM oversees  onshore oil and gas activities, and the other two bureaus oversee  offshore oil and gas activities—BSEE reviews drilling applications from  operators and conducts inspections of offshore oil and gas activities, and  BOEM oversees offshore oil and gas leasing and makes decisions on  plans for energy and mineral resources exploration and development. To  do this work, Interior employs specialists and scientists such as petroleum  engineers, inspectors, geologists, geophysicists, natural resource  specialists or biologists, and environmental protection specialists that  require specialized training to ensure they are able to perform their duties.  Interior’s Office of Policy, Management and Budget is responsible for  overseeing efforts to hire and train these staff, as part of the office’s  overall responsibility for managing human resource issues and  addressing relevant cross-cutting issues within Interior.
In March 2010, we found that Interior faced various human capital  challenges, including hiring and retaining staff and, as a result, had  difficulty meeting its responsibilities to oversee oil and gas activities on  offshore federal leases. Advances in technologies, such as horizontal  drilling in shale formations onshore and deepwater drilling offshore, have  made additional oil and gas resources accessible for development,  increasing Interior’s oversight tasks. In February 2011, we added  Interior’s management of federal oil and gas resources to our list of U.S.  government program areas at high risk of waste, fraud, abuse, and  mismanagement or in need of broad reform, partly because of the  department’s ongoing human capital challenges. In January 2014, we  found that Interior had begun to address hiring and retention challenges  for key oil and gas staff at BLM, BSEE, and BOEM but continued to face  such challenges, which were driven by two underlying factors: (1) lower  federal salaries compared with industry and (2) a lengthy federal hiring  process compared with industry. We recommended that Interior explore  the expanded use of existing authorities, such as recruitment incentives,  to help bridge the salary gap for key oil and gas oversight staff, develop  clear guidance for how the effectiveness of incentives will be assessed,  and systematically collect data on the hiring process in order to identify  the causes of delays and expedite the process. In a February 2015  update to our High-Risk list, we found that Interior had begun to address  some of these challenges but needed to do more. Then, in February  2016, we found that BSEE did not have enough staff to meet its goals for  monitoring operator compliance with environmental standards.
Also in March 2010, we found that Interior had not consistently provided  appropriate training for offshore inspection and engineering staff. In June  2011, Interior announced the opening of a new National Offshore Training  and Learning Center and the development of its first formal training  curriculum for inspectors and engineers. In July 2012, we found that  Interior had made some progress with its offshore training but had not  finalized its training classes or certified any offshore inspection staff. We  also concluded in that report that until Interior has successfully  developed, finalized, and implemented a training program for inspectors  and engineers, Interior would continue to have difficulty providing  adequate oversight of offshore oil and gas activities in the Gulf of Mexico.
You requested that we review the status of Interior’s human capital  challenges. This report examines Interior’s efforts to (1) resolve its hiring  and retention challenges for key oil and gas staff and (2) address its  training needs for such staff.
To address both of these objectives, we reviewed relevant laws, such as  the Federal Workforce Flexibility  Act of 2004, as well as Interior’s  guidance and documentation related to hiring, retention, and training  issues. In addition, we reviewed documentation and reports from the  Office of Personnel Management (OPM), Interior’s Office of Inspector  General, and Interior’s Outer Continental Shelf Safety Oversight Board.  We also reviewed our reports related to human capital planning,  collaboration, and training and development. We focused our review  on Interior staff working in positions that we identified in our January 2014  report as being key to the oversight of oil and gas. The key oil and gas  staff included petroleum engineers, inspectors, geologists, natural  resource specialists (biologists), and environmental protection  specialists at BLM; petroleum engineers, inspectors, geologists,  geophysicists, and biologists (natural resource specialists) at BSEE; and  petroleum engineers, geologists, geophysicists, and biologists (natural  resource specialists) at BOEM. We interviewed managers and staff from  Interior’s Office of Policy, Management and Budget, as well as officials  from BLM, BSEE, and BOEM who were responsible for oversight of oil  and gas activities and training to understand their perspectives about  Interior’s and the bureaus’ hiring, retaining, and training efforts. These  managers and staff worked in headquarters, 14 BLM state and field  offices, 4 BSEE district offices, BSEE and BOEM’s Gulf of Mexico  Regional Offices, and BSEE’s Alaska Regional Office. We also visited  local, state, and regional BLM, BSEE, and BOEM offices located in  Colorado, Louisiana, New Mexico, North Dakota, and Utah to interview  some of these officials; others we interviewed by phone. We selected  these locations to visit to obtain perspectives from staff working in a  variety of offices that differed in the total number of key oil and gas staff,  workload levels, and extent of hiring and retention challenges. The  responses of officials from these offices we interviewed are not  generalizable to all BLM, BSEE, and BOEM offices.
To examine Interior’s efforts to resolve its hiring and retention challenges  for key oil and gas staff, we reviewed actions taken since 2012 by  Interior’s Office of Policy, Management and Budget; BLM; BSEE, and  BOEM. We also analyzed personnel data for Interior and other federal  agencies, which we used for comparison purposes, from fiscal years  2003 through 2014 in OPM’s Enterprise Human Resources Integration  (EHRI) database. This database contains personnel data, such as  adjusted basic pay and occupation, for civilian federal employees. We  supplemented these data with data from BLM so that we could identify  BLM employees in key positions who were responsible for oil and gas  oversight. Using these data and additional EHRI data from fiscal years  2003 through 2014, we developed a statistical model to examine the main  factors that reduced the likelihood  that federal employees in key  positions—those that corresponded to the positions of key oil and gas  staff at BLM, BSEE, and BOEM—would leave those positions. We used  data on the approximately 29,000 federal employees throughout the  federal government who were hired into one of the key oil and gas  positions during fiscal years 2003 through 2014. We checked the EHRI  data for accuracy and consistency, and checked to ensure we used them  appropriately for our analysis. We determined that these data were  sufficiently reliable for the purpose of our reporting objectives. (See app. I  for a description of our statistical model.) To examine Interior’s efforts to  reduce its hiring process time, we requested information from the bureaus  on their hiring processes. We obtained information from BOEM and in  reviewing BOEM’s analysis of its hiring process we identified problems  with the data used, such as missing and inaccurately recorded dates.
To examine Interior’s efforts to address its training needs for key oil and  gas staff, we reviewed actions taken since 2012 by Interior’s Office of  Policy, Management and Budget; BLM; BSEE; and BOEM. We reviewed  Interior’s Departmental Manual, reports by the Outer Continental Shelf  Safety Oversight Board and Interior’s Inspector General, other  departmental documentation on training, and Interior’s and the bureaus’  written responses about training. In our review of the training provided to  staff at all three bureaus, we focused on technical training delivered to oil  and gas staff through classroom instruction. We did not formally review  on-the-job training provided to oil and gas staff or general classroom  training that was not specifically for oil and gas staff because it was  outside the scope of this review. We compared Interior’s actions with  requirements in the Federal Workforce Flexibility Act of 2004, with OPM  regulations on planning and evaluating training, with policy outlined in  Interior’s Departmental Manual, and with practices identified in our  reports  and our guide for assessing training efforts in the federal  government.
We conducted this performance audit from March 2015 to September  2016 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  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: BLM, BSEE, and BOEM are directly overseen by the Assistant Secretary  for Land and Minerals Management, who is responsible for guiding  Interior’s management and use of federal lands and waters and their  associated mineral and nonmineral resources. In addition, human capital  programs at the bureaus and elsewhere in the department are overseen  by Interior’s Assistant Secretary of the Office of Policy, Management and  Budget, which is broadly responsible for employee training and  development; part of the office’s mission is providing high-quality,  innovative, efficient, and effective training. The Office of Policy,  Management and Budget comprises multiple offices, including the Office  of Human Resources, which has primary responsibility for evaluating the  effectiveness of Interior’s personnel management program, and the Office  of Strategic Employee and Organization Development, which is  responsible for delivering efficient and effective training across the  department.
In fiscal year 2014, BLM, BSEE, and BOEM employed over 900 key oil  and gas staff who oversee onshore and offshore oil and gas activities.  Onshore land use planning is handled by BLM’s petroleum engineers,  natural resource specialists, geologists, and other scientists. Offshore  resource planning is handled by BOEM’s petroleum engineers,  geoscientists, and other specialists. Operators that are awarded leases  for oil and gas development can then submit to BLM (onshore) or BSEE  (offshore) an application for a permit to drill. Petroleum engineers,  inspectors, natural resource specialists, geologists, and other scientists  review and approve applications for permits to drill. The application for  permit to drill contains a detailed set of forms and documents that specify  requirements that the operator must follow when drilling. Once operators’  planning for oil and gas operations commence, BLM and BSEE  inspectors, petroleum engineers, and natural resource specialists carry  out a variety of oil and gas inspections. For example, BLM’s inspectors  conduct production inspections, drilling inspections, and environmental  compliance inspections. Similarly, BSEE inspectors conduct drilling and  production inspections to ensure that operators comply with all regulatory  requirements. However, Interior and others have stated that offshore  inspections in a marine environment are generally more complex and  difficult than onshore inspections and require helicopters or boats to  reach inspection sites, making the planning and performance of duties  more difficult and hazardous. Further, offshore facilities have large  amounts of equipment and personnel in relatively confined spaces,  more  sophisticated safety systems and requirements, and high production  volumes, pressures, and temperatures, as well as more limited access to  some equipment and piping, especially in deep water areas that are far  from shore.
In addition to GAO, Interior’s Inspector General and the Outer Continental  Shelf Safety Oversight Board have reported on Interior’s challenges  related to hiring and retention of such key oil and gas staff. For example,  Interior’s Inspector General concluded in December 2010 that the Bureau  of Ocean Energy Management, Regulation and Enforcement  (BOEMRE)—which was replaced by BSEE and BOEM in 2011 and which  oversaw offshore oil and gas activities—faced considerable hiring  challenges in the Pacific Region because of increased hiring by the oil  and gas industry in that area due to the industry’s significant salary  advantage over federal service. In addition, the report found that  engineers in BOEMRE’s Gulf of Mexico Region had to work extra hours  to keep up with increased workloads because of staffing shortages,  resulting in their inability to attend training or take annual leave. It stated  that continued shortages could lead to significant employee burnout and  the possibility of less comprehensive reviews as employees attempted to  keep pace with demands. In a second 2010 report, Interior’s Inspector  General reported that BLM risked losing its trained inspectors because oil  and gas operators commonly recruit BLM inspectors by offering high  salaries during successful business periods. In that report, the Inspector  General recommended, among other things, that BLM consider  developing and implementing a continued service agreement requiring  newly certified inspectors to stay with the bureau for a specified period of  time. Further, the Outer Continental Shelf Safety Oversight Board  reported in 2010 that Interior did not have a formal program to train its  inspectors.
In terms of training, the Outer Continental Shelf Safety Oversight Board  also noted in its 2010 report that almost half of the offshore inspectors it  surveyed said they did not receive sufficient training. Further, BOEMRE  did not have an inspection certification program that combined classroom  and on-the-job experience, as well as a formal technical review or exam.  By contrast, the report pointed out that BLM had a certification program  that combined classroom instruction, on-the-job experience, and a formal  technical review or exam. Among the board’s recommendations were for  Interior to  implement a bureau-wide certification or accreditation program for  inspectors; consider partnering with BLM and its National Training Center to  establish an Interior oil and gas inspection certification program, with  training modules appropriate to the offshore environment as needed; develop a standardized training program similar to other Interior  bureaus to ensure that inspectors are knowledgeable in all pertinent  regulations, policies, and procedures; and ensure that annual training keeps inspectors up-to-date on new  technology, policies, and procedures.
Interior’s Inspector General came to similar conclusions and made similar  recommendations in 2010.
To address hiring and retention challenges, the federal government has a  variety of tools available to use. For example, to address staffing  problems caused when nonfederal employers pay significantly higher  salaries than what the federal government pays, an agency may request  special salary rates from OPM that establish higher minimum rates of  basic pay for positions in one or more geographic areas. Agencies  may also use incentive payments to recruit and retain employees.  Incentive payments can come in the form of recruitment incentives,  retention incentives, and relocation incentives. Recruitment incentives  can be paid to new employees in certain difficult-to-fill positions; retention  incentives can be paid to certain current employees holding high or  unique qualifications; and relocation incentives can be paid to certain  current employees who must relocate to accept a position in a different  geographic area and whose position is difficult to fill. To receive an  incentive payment, the employee must agree to complete a specified  period of service with the agency. In general, total incentive payments  may not exceed 25 percent of the employee’s original annual rate of basic  pay multiplied by the number of years of service the employee agrees to  complete. Agencies may also repay federally insured student loans in  order to recruit or retain highly qualified candidates or employees through  the Student Loan Repayment Program. Through this program, agencies  may make payments to the loan holder of up to a maximum of $10,000  for an employee in a calendar year and a total of not more than $60,000  for any one employee. Employees receiving this benefit must sign an  agreement to remain in the service of the agency for at least 3 years.  Federal agencies can use special salary rates, incentive payments, and  student loan repayments in combination to increase an employee’s  overall compensation.
section_title: Interior Has Taken Steps to Improve Hiring and Retention but Has Not Evaluated Its Efforts and Has Missed Opportunities to Collaborate on Challenges
paragraphs: Since 2012, Interior has taken steps to resolve its hiring and retention  challenges for key oil and gas staff, but it has not evaluated the  effectiveness of its efforts. In addition, Interior has missed opportunities to  facilitate collaboration among the bureaus, and as a result, the bureaus  have sometimes acted in a fragmented, overlapping, and potentially  duplicative fashion to resolve similar hiring and retention challenges.
subsections: section_title: Interior Has Taken Steps to Address Hiring and Retention Challenges but Has Not Evaluated the Effectiveness of Its Efforts
paragraphs: Since 2012, Interior has taken steps to address two underlying factors— lower salaries and a lengthier hiring process compared with the oil and  gas industry—that have impeded its ability to hire and retain key oil and  gas staff, but it has not evaluated the effectiveness of its efforts.
subsections: section_title: Salaries
paragraphs: Interior has increased the compensation for certain key oil and gas staff  through use of special salary rates, incentive payments, and student loan  repayments since fiscal year 2012, but the department has not evaluated  the effectiveness of this compensation in resolving its hiring and retention  challenges. During fiscal years 2012 through 2016, Interior had special  salary rates, authorized by Congress in annual appropriations acts, that  allowed it to pay certain staff up to 25 percent more than their basic pay.  Interior stated that in 2013 the Office of Policy, Management and Budget  met with officials from OPM, the U.S. Department of Agriculture, the  Department of Defense, and the U.S. Army Corp of Engineers to discuss  the impacts of expanding oil and gas extraction activities on their  recruitment and retention efforts. Interior also stated that the Office of  Policy, Management and Budget worked with officials from BLM, BSEE  and BOEM to (1) ensure that the three bureaus had the capacity to fund  special salary rates through the budget process, (2) develop an integrated  special salary rate request to OPM and (3) issue guidance that would  provide instruction to human resource officials and hiring managers on its  use. Further, Interior stated that, beginning in fiscal year 2013, the Office  of Policy, Management and Budget submitted applications to OPM  requesting to increase the base salaries for staff in certain positions and  geographic locations through a special salary rate. In fiscal years 2015  and 2016, OPM approved Interior’s requests to provide key oil and gas  staff in 11 states up to 35 percent more than their basic pay.
In addition, some of the bureaus increased compensation through other  tools, such as incentive payments and student loan repayments. For  example, for fiscal years 2012 through 2014, BLM and BSEE  substantially increased the number of staff receiving a retention incentive  payment from a total of 14 to a total of 346 employees. During the same  period, BSEE and BOEM increased the number of staff receiving a  student loan repayment from 25 to 66 employees. (See fig. 3.) As noted  earlier in this report, employees receiving incentive payments and student  loan repayments must sign an agreement to remain working for the  agency for a certain period of time. Service agreements, in addition to the  actual monetary payment, may also play a role in retaining staff.
Officials from the three bureaus said that these efforts to increase the  compensation paid to key oil and gas staff, along with the industry  downturn that reduced private sector hiring, had likely helped them fill  vacancies. In May 2015, BLM officials said that anecdotally they know  that the incentive payments and special salary rates have proven to be  somewhat effective and were particularly helpful in recruiting and  retaining inspectors. Similarly, in May 2015, BSEE officials said that they  had hired more staff in the first part of fiscal year 2015 than in fiscal year  2014, although they noted that they had the most difficulty recruiting  petroleum engineers and inspectors in the Gulf of Mexico Region  because the pool of prospective candidates was smaller than for other  positions. BSEE officials also said that while they lost a fair number of  staff in fiscal year 2014, many of those who left did so because of  retirements. Senior BOEM officials also reported success in hiring staff,  and senior officials said that as of May 2015 the bureau was fully staffed;  however, several months later BOEM officials in the Gulf of Mexico  Region did report some vacancies. Senior BOEM officials said they had  the most difficulty recruiting petroleum engineers, geologists, and  geophysicists.
Outside of these anecdotal observations, Interior and the bureaus have  not evaluated whether these efforts, and the specific tools they used,  were effective in hiring and retaining staff. In prior work, we have found  that strategic workforce planning requires evaluation of an agency’s  progress toward its human capital goals. In November 2014, Interior  senior officials told us that they would implement a performance measure  framework to evaluate the effectiveness of incentives on a quarterly basis  beginning in April 2015. However, as of July 2016, a senior official from  the Office of Policy, Management and Budget said these quarterly  reviews had not begun yet. In September 2016, officials said they had  developed initial performance metrics and gathered data for the first three  quarters of fiscal year 2016 and would continue to track and monitor the  data on a quarterly basis. However, the agency has not yet used this data  to evaluate the effectiveness of incentives. In the absence of these  evaluations, Interior cannot determine the extent to which the tools it is  using are effective in meeting its goals of hiring and retaining key staff or  whether it is expending funds on tools that are not the best use of its  limited resources. In addition, without regular evaluations, Interior may not  have the information it needs to determine if or how it should alter the  tools it uses as the oil and gas market shifts, potentially increasing  Interior’s competition with industry for oil and gas staff.
Bureau officials acknowledged that retaining newly hired staff may prove  difficult when oil and gas market conditions change again and companies  increase their hiring efforts. In April 2016, BLM officials noted that while  there have been some market-based changes that have proved to be  advantageous to the bureaus’ hiring efforts in some locations, the  potential for a resurgence in private sector demand for qualified  petroleum engineers and inspectors remains a likely probability over the  next 12 to 18 months. BLM further noted that since it takes 12 to 18  months to recruit, train, and certify entry-level petroleum engineers and  inspectors, losing these staff after they are hired and trained could  undermine much of the progress the bureau had made.
Because of the importance of key staff for Interior’s oversight of oil and  gas development, we developed a statistical model to examine the main  factors associated with the likelihood that federal employees in key  positions—petroleum engineers, inspectors, geologists, geophysicists,  natural resource specialists (or biologists), environmental protection  specialists—would leave those positions. While not definitive, the model  illustrates the type of analysis that Interior could potentially perform  itself—using more detailed and current data—to evaluate the  effectiveness of specific tools in retaining key oil and gas staff. For our  analysis, we used data mainly from OPM’s EHRI data set, which contains  personnel data for civilian federal employees. We supplemented our  analysis with data from BLM so that we could identify employees in key  positions who were responsible for oil and gas oversight. We used data  on approximately 29,000 federal employees throughout the federal  government, all of whom were hired into one of the key oil and gas  positions during fiscal years 2003 through 2014. Our model estimated  the effect that differences in salaries and other compensation had on the  likelihood that a federal employee would leave his or her position, while  controlling for factors such as the employee’s age, gender, geographic  location, and length of time working in that position. We also examined  the effect of the performance of the oil and gas market on employee  retention.
Our results showed that federal employees who received higher adjusted  basic pay (which could include a special salary rate), retention payments,  student loan repayments, and other additional compensation were less  likely to leave than their counterparts working in the same positions who  did not receive such compensation. We also found that when the oil and  gas market was performing well, federal employees in these positions  were more likely to leave their positions. Specifically, for federal  employees working in key oil and gas oversight positions, we found the  following:
Higher adjusted basic pay was significantly associated with a lower  likelihood of leaving, with each additional $1,000 reducing the  relative odds of leaving by about 2.0 percent.
All the categories of other compensation in our model—retention  payments, student loan payments, cash awards, and time-off  awards —were significantly associated with reducing the likelihood of  leaving. Among these categories, the strongest effects were from  retention and student loan payments.
A higher percentage growth rate of the oil and gas market was  significantly associated with a higher likelihood  of employees leaving  their position. Interior officials we interviewed said that they have  difficulty retaining key employees when the oil and gas market is  performing well, and our results support this assertion. Conversely, a  slower growth of the oil and gas market was associated with fewer  employees leaving their positions.
Our analysis also showed that natural resource specialists, biologists, and  environmental protection specialists were more likely than inspectors to  leave their positions. In addition, our analysis showed that BSEE and  BLM employees were more likely to leave their positions than federal  employees working in the same positions in other federal agencies and  other Interior bureaus. This effect was stronger at BSEE than at BLM,  with BSEE employees responsible for oil and gas oversight being 50  percent more likely to leave than their counterparts at BLM. However, our  results are based on EHRI data from fiscal years 2003 through 2014, the  most current EHRI data available to us at the time of our analysis. In  comparison, Interior has other data available to it that are more current  and detailed. For example, Interior has access to current fiscal year  information, which are not yet available in EHRI, on the types and  amounts of payments it has given its employees, which would allow the  department to conduct a more thorough and precise evaluation of the  effect of these payments on retention of key oil and gas staff.
section_title: Hiring Process
paragraphs: Each of the three bureaus has taken steps to begin to address their  lengthy hiring process. For example, in 2015 the three bureaus adopted  new human resources software that officials said will provide them with  better data to track their hiring process. In June 2016, officials from the  three bureaus said that they had started analyzing data extracted from  this new system to identify steps in the hiring process that may be  causing delays. Also in 2016, BSEE and BOEM issued new hiring  process guidance to clarify steps in the hiring process for its managers.  BSEE and BOEM also provided multiple training classes on the new  guidance to ensure that managers understood the process. In addition, in  a July 2015 memorandum, BOEM summarized the results of an analysis  of its hiring process and identified some improvements that could be  made. However, in reviewing the analysis, we identified problems with  the data used, such as missing and inaccurately recorded dates.
In June 2016, a senior official from Interior’s Office of Policy,  Management and Budget said that they were aware of the bureaus’  efforts to analyze their hiring process time. Officials from the three  bureaus said that their hiring processes continue to exceed OPM’s goal of  80 days. Some bureau officials also told us that their hiring process  sometimes took as long as 190 days. As noted previously, we  recommended in January 2014 that Interior systematically collect data on  hiring times for key oil and gas positions, ensure the accuracy of the data,  and analyze the data in order to identify the causes of delays and  expedite the process. However, senior officials from the Office of Policy,  Management and Budget did not indicate any plans to look across the  bureaus’ efforts in order to help address their shared challenge of a  lengthy hiring process. In the absence of such action to address the  lengthy hiring processes for the bureaus, they may be losing qualified  applicants who accept a different job. We continue to believe that having  accurate hiring data and finding ways to reduce the lengthy hiring process  are important steps toward resolving Interior’s hiring challenges and may  prove especially important if the oil and gas market shifts.
section_title: Interior Has Missed Opportunities for Collaboration on Resolving Challenges in Hiring and Retaining Key Staff
paragraphs: Interior’s Office of Policy, Management and Budget has missed  opportunities to facilitate collaboration across the three bureaus in  addressing their shared challenges in hiring and retaining staff. For  example, officials from this office said that they assembled the three  bureaus’ requests to OPM for a special salary rate, but we found that they  did not facilitate collaboration among the bureaus about which staff  should receive a special salary rate. BOEM officials requested the 35  percent special salary rate for certain key oil and gas staff but did not  request this special salary rate for its biologists (also referred to as natural  resource specialists). In contrast, BLM requested this 35 percent special  salary rate for its natural resource specialists along with other positions.  BOEM regional managers said that they were not aware that BLM was  requesting the special salary rate for its natural resource specialists and  did not know that they could request the special salary rate for these staff.  BOEM managers said that they learned of this after OPM had already  approved these requests. Some of these managers said that had they  known BLM was going to request a special salary rate for its natural  resource specialists, they probably would have done so too. Some  officials said that the bureaus compete with each other for the same pool  of applicants and staff. The fact that BLM can pay a natural resource  specialist 35 percent more than BOEM may place BOEM at a  disadvantage in its recruitment efforts and its ability to retain staff if its  natural resource specialists leave to take a comparable position at BLM.  In addition, BOEM may also be particularly vulnerable to losing its natural  resource specialists to industry, based on the results of our statistical  model and comments from BOEM managers, both of which indicated that  these staff were more likely to leave their position relative to other key oil  and gas staff.
Senior officials in Interior’s Office of Policy, Management and Budget did  not identify any collaboration mechanisms that they used to bring the  three bureaus together to discuss their shared human capital  challenges. These officials said the bureaus’ senior managers interact  through the meetings of the Deputies Operating Group and Principals  Operating Group. However, in our review of the topics discussed by  these groups in fiscal year 2015, we found that the bureaus’ hiring and  retention challenges were not discussed. In prior work, we have found  that collaborative efforts can enable organizations to produce more public  value than could be produced when they act alone. To facilitate  collaboration, agencies can use a variety of mechanisms, such as  interagency groups, communities of practice, and liaison positions.  Further, as we have concluded in prior work, leadership is a necessary  element for successful collaborative working relationships. Officials from  the three bureaus said that they do not have a mechanism, such as a  workgroup, in place to collaborate with each other on their shared hiring  and retention challenges. In the absence of such a collaboration  mechanism, the bureaus have sometimes acted in a fragmented,  overlapping, and potentially duplicative fashion to resolve similar hiring  and retention challenges. For example, some members of the BSEE and  BOEM recruitment teams told us that while they sought to hire staff with  similar skills, they participated in recruitment events, such as job fairs,  separately and did not give prospective applicants information about  career opportunities available at the other bureaus. Officials also said the  fact that the bureaus maintained separate recruitment tables was  confusing to prospective applicants. Some officials noted that greater  collaboration could be useful. For example, some BOEM officials said it  would be beneficial if the bureaus had a single booth that could represent  all the job opportunities at Interior because the broader range of  opportunities and locations might generate more interest among  prospective applicants. However, without further leadership from the  Office of Policy, Management and Budget to create or use an existing  mechanism to facilitate collaboration in addressing hiring and retention,  the bureaus may continue to address their shared challenges through  fragmented and potentially duplicative efforts, which can waste resources.
section_title: Interior Has Not Fully Evaluated Training Needs or Effectiveness, According to Officials, and Has Provided Limited Leadership in Facilitating the Bureaus’ Shared Use of Training Resources
paragraphs: Interior and its bureaus have trained key oil and gas staff without fully  evaluating the bureaus’ staff training needs or the training’s effectiveness,  according to officials, and Interior has provided limited leadership in  facilitating the bureaus’ sharing of training resources. Specifically, Interior  has not evaluated training needs or effectiveness as required by law and  regulations, according to officials, and its bureaus have not evaluated  training needs or effectiveness as directed by departmental policy.  Further, Interior’s Office of Policy, Management and Budget has provided  limited leadership in facilitating the sharing of training resources across  the bureaus, appearing to miss opportunities that could improve the use  of these resources.
subsections: section_title: Interior Has Not Evaluated Training Needs or Effectiveness, According to Officials
paragraphs: Interior’s Office of Policy, Management and Budget has not evaluated the  three bureaus’ training efforts, contrary to federal law and regulations,  according to officials. The Federal Workforce Flexibility  Act of 2004  requires agencies to regularly evaluate their training at the department  level with respect to accomplishing specific performance plans and  strategic goals in performing the agency mission and then modify the  training as needed. Similarly, OPM has stated that training and the  effective evaluation of training are critical within the federal government,  and OPM regulations require agencies to evaluate their training programs  annually to identify training needs and assess how well training efforts  contribute to accomplishing the agency mission. However, senior officials  from the Office of Policy, Management and Budget said that they have  not performed these annual evaluations of the bureaus’ staff training  needs. In addition, senior officials from this office said they have not  requested or received these annual training evaluations from the bureaus  even though Interior’s Departmental Manual states that bureaus should  conduct such evaluations and submit them to the office. These officials  explained that they thought that the 2008 Departmental Manual was old  and needed to be revised. However, based on our review of the manual  and discussion with an official in Interior’s Office of the Solicitor, we  determined that the manual is still in effect.
Similarly, the bureaus have not evaluated their oil and gas staff’s training  needs to the extent directed by Interior’s policies, according to officials.  For example, as noted above, Interior’s Departmental Manual directs  each bureau to conduct an annual evaluation of its training program;  these evaluations are to determine if the program is effectively meeting  identified needs. The manual also states that training programs should  identify and address competency gaps, including for technical  competencies. Similarly, our guide for assessing training efforts in the  federal government states that well-designed training programs are linked  to agency goals and to the skills and competencies needed for the  agency to perform effectively. However, none of the bureaus have  consistently evaluated training needs, according to officials, and only one  of the bureaus developed competencies for their key oil and gas staff.
The bureaus’ efforts to evaluate training needs and develop  competencies include the following:
BLM most recently evaluated training needs for its oil and gas staff in  2012 and 2013. BLM evaluated the training needs for its natural  resource specialists and environmental protection specialists in 2012,  followed by its petroleum engineers, inspectors, and geologists in  evaluations that spanned 2012 and 2013. In so doing, BLM did not  follow the direction of Interior’s Departmental Manual to conduct  annual evaluations. In addition, BLM has not developed technical  competencies for its oil and gas staff per OPM and Interior  definitions.
BSEE has not formally evaluated the training needs of its key oil and  gas staff, according to officials. Instead, BSEE officials told us that  these training needs are discussed by managers, subject matter  experts, and other staff who use this information to identify training  courses for staff to take. In addition, BSEE has not developed  technical competencies for its key oil and gas staff per OPM and  Interior definitions.
BOEM has relied on its offices within its three regions to implement its  training efforts, and on individual supervisors to evaluate training  needs, according to BOEM officials, but BOEM officials told us that  the bureau has not formally evaluated the training needs of its key oil  and gas staff bureau-wide. These supervisors evaluate training needs  of individual  employees at the beginning of each fiscal year, and  BOEM seeks to address these needs of its staff through vendor- based training, training taught by BOEM staff, and mentoring,  according to officials. BOEM has, however, developed competencies  per OPM and Interior definitions for its geologists, geophysicists, and  petroleum engineers by using ones already published by other  sources.
Officials from each of the bureaus told us they have not performed annual  evaluations of their training needs because officials from the Office of  Policy, Management and Budget have not requested them. Without  evaluating training needs and developing competencies, Interior cannot  ensure that the training it provides for key oil and gas staff is linked to the  competencies needed for the agency to perform effectively and that the  training addresses any competency gaps.
The bureaus also have not evaluated the effectiveness of the training  provided to their key oil and gas staff as directed by Interior’s  Departmental Manual. The manual states that all formal training courses  sponsored by departmental bureaus or offices are expected to be  evaluated, and it recommends that bureaus use a five-level evaluation  system to assess the effectiveness of their training, with targets for the  percentage of courses that should be evaluated at each level. (See fig. 4.)  For example, the guidance recommends that all training courses receive  level 1 evaluations, which measure student satisfaction and identify ways  to improve the training; successively lower percentages of courses are  recommended to receive successively higher levels of evaluation.
Officials from each of the bureaus told us they have not fully evaluated  the effectiveness of their training efforts because either they did not have  staff to perform them or Interior did not request it. Collectively, the  bureaus conducted varying levels of evaluations, and none reported  doing evaluations above level 3, as discussed below:
BLM conducts level 1 and 2 evaluations for each course, as well as  level 3 evaluations and proficiency examinations for certain courses,  according to BLM officials. For example, for its inspector certification  training program, comprised of six modules, each inspector is to  complete a proficiency examination and complete related field work,  according to a BLM handbook. BLM’s inspectors must demonstrate  proficiency in each module before they can progress to the next  module, according to BLM officials. Following the successful  completion of all six modules, inspectors are eligible for certification  and, once certified, they are allowed to issue citations to operators  when appropriate.
BSEE conducts level 1 evaluations for all of its training and its  vendors conduct level 2 evaluations to some extent but not to the  extent directed by the Departmental Manual, according to BSEE  officials. In addition, BSEE has not developed competencies for its  inspectors and does not conduct level 3 evaluations for its inspectors  to measure how training affected behavior and skills, according to  officials. Further, BSEE’s training for inspectors does not include  proficiency examinations or certifications, according to officials, as  BLM’s training program does. BSEE officials told us that they have not  implemented a certification program, although the Outer Continental  Shelf Safety Oversight Board and Interior Inspector General  recommended it in 2010. By conducting such evaluations and  requiring these examinations for certification of inspectors, BSEE  could ensure that its inspectors learned and could apply content  received in training courses (i.e., were adequately trained). In the  absence of such evaluations, BSEE may not be able to verify that its  inspectors are adequately trained. BSEE officials told us that they  planned to obtain two independent evaluations of their training efforts.  According to these officials, the first evaluation, which will review  whether the training currently offered to engineers is sufficient, was  tentatively scheduled to start in July 2016. The second evaluation will  review the bureau’s approach to identifying competencies, training,  and possible certification requirements for inspectors and, according  to officials, the contract for the work should be awarded by December  2016. As of June 2016, BSEE officials told us that they were finalizing  their efforts to initiate the first evaluation and were planning to  complete a statement of what work would be included in the second  evaluation.
BOEM conducts level 1 evaluations when requested by vendors, but  BOEM did not report conducting higher-level evaluations. In addition,  BOEM officials stated that BOEM does not systematically evaluate  training provided by internal BOEM staff, vendors, or others because  the bureau does not have staff assigned to training, such as to  develop training curricula or evaluate training efforts.
None of the bureaus reported conducting level 4 or 5 evaluations, which  would give the bureaus information about the overall effectiveness of their  training efforts by measuring the impact of training courses on staff’s job  performance and comparing program benefits to training costs. During  our review, key oil and gas staff we interviewed told us that some courses  provided for inspectors were not always effective. For example, BSEE  inspectors at four local offices told us in September 2015 that the training  courses BSEE provided them, which were primarily led by contractors,  did not adequately prepare them to perform inspections because the  courses focused on how equipment operates and did not teach them how  to inspect the equipment. Similarly, managers from four BSEE offices told  us that inspector courses were not entirely relevant and not tailored to  inspectors’ responsibilities. For example, one manager said that these  training courses do not familiarize inspectors with information they need  to perform inspections, such as what to look for when inspecting the  equipment. A BSEE training official told us in January 2016 that she had  heard this same feedback. In response, BSEE created an extra day of  training for some courses, such as their Cranes and Rigging Inspections  course that would be led by a BSEE instructor, not a contractor, who  would teach the inspectors how to inspect the equipment covered in  these courses. Without evaluating its bureaus’ training efforts, Interior  may not be able to ensure that its key oil and gas staff are being  adequately trained to execute their oversight tasks, and it may not be  spending training funds effectively and efficiently.
section_title: Interior Has Provided Limited Leadership in Facilitating the Sharing of Training Resources across Bureaus
paragraphs: Interior’s Office of Policy, Management and Budget has provided limited  leadership in facilitating the sharing of training resources across the  bureaus. The Office of Strategic Employee and Organization  Development—housed within the Office of Policy, Management and  Budget—has objectives that include improving training across the  bureaus and facilitating the sharing of training resources, such as training  staff expertise and course curricula. However, we identified areas where it  appears that the Office of Strategic Employee and Organization  Development has missed opportunities to improve the bureaus’ training  efforts and facilitate the sharing of training resources. For example,  BOEM, which is the smallest of the three bureaus, does not have staff  assigned to developing curricula or evaluating training efforts across the  bureau and, as discussed earlier, it therefore relies on external vendors  for training and evaluates the training when requested by the vendors. In  addition, BSEE, which had 6 full-time staff in their Offshore Training  Program as of July 2016, according to officials, also relies on external  vendors for training and conducting level 2 evaluations. In contrast, as of  July 2016, BLM had 59 full-time staff in its National Training Center, and  has the capacity to evaluate their training efforts, according to officials.
In 2010, the Outer Continental Shelf Safety Oversight Board and Interior’s  Inspector General recognized strengths in BLM’s training program for  inspectors and recommended that BSEE and BLM consider partnering to  establish an Interior-wide inspection certification program. However,  neither Interior’s Office of Policy, Management and Budget nor the  bureaus evaluated the need for or viability  of a joint inspector certification  training program, according to officials.
Similarly, Interior’s Office of Policy, Management and Budget has not  pursued potential opportunities for BOEM and BSEE to share training  resources, according to officials. Recognizing that BOEM is a smaller  bureau than BSEE, and recognizing the benefits of economies of scale,  BOEM has arranged since 2011 to have BSEE’s human resources  department service BOEM for select human resource functions, but not  training, according to a senior BOEM official. In January 2016, officials  from the Office of Policy, Management and Budget said that they were in  favor of BOEM using BSEE’s training program, but they had not yet taken  any steps toward encouraging such collaboration to facilitate the sharing  of resources.
In addition, to develop training courses specific to their bureau, BSEE  training officials said they would need curriculum developers, which they  do not have. As a result, BSEE officials said they rely almost exclusively  on external off-the-shelf courses taught by contractors. In contrast, BLM’s  training center has about six full-time curriculum developers, according to  officials. BLM training officials said that these curriculum developers  would be able to develop training curricula for BSEE if they worked  alongside subject matter experts from BSEE. However, officials told us  that the Office of Policy, Management and Budget has not taken any  steps to encourage collaboration in this area.
Senior officials from the Office of Policy, Management and Budget  acknowledged that their office has not effectively facilitated the sharing of  training resources across the bureaus as of June 2016. As we mentioned  earlier, we found in prior work that to facilitate collaboration, agencies can  use a variety of mechanisms, such as interagency groups, communities  of practice, and liaison positions; that leadership is a necessary element  for successful collaborative working relationships; and that collaborative  efforts can enable organizations to produce more public value than could  be produced when they act alone. In January 2016, a senior official from  the Office of Policy, Management and Budget said that their focus in the  previous fiscal year had been to assist the bureaus in obtaining a special  salary rate for their key oil and gas staff. Another senior Interior official  said that in January 2016 their Interior Training Directors Council— composed of senior training officials across Interior—would begin  reviewing training across the bureaus and seek to identify opportunities to  share training resources. According to its charter, the goal of the council  is to facilitate a partnership across the bureaus in order to maximize the  effectiveness and efficiency of training efforts throughout the Department  of the Interior. In March 2016, the council, which had previously  operated as a community of practice since 2001, shifted to a more formal  structure that would allow it to develop policy and make recommendations  to Interior’s Human Capital Officers, according to a senior official.  However, as of June 2016, officials had not reported any progress made  by the council, and it is unclear what, if any, steps the office has taken to  review training and identify opportunities to share training resources.  Without further leadership from the Office of Policy, Management and  Budget to create or make better use of an existing mechanism that  effectively facilitates collaboration across the bureaus and helps them  identify opportunities to share training resources, Interior and its bureaus  may not be spending training funds effectively and efficiently.
section_title: Conclusions
paragraphs: Since 2012, Interior has taken steps toward resolving its challenges in  hiring and retaining key oil and gas staff, who are the front line in  providing effective oversight of activities related to federal oil and gas  resources. Notably, to hire and retain such staff, Interior’s bureaus have  invested increasing resources into compensating them through special  salary rates, incentive payments, and student loan repayments—tools  that can help bridge the gap between federal salaries and those paid by  industry. We recommended in January 2014 that Interior explore the  expanded use of existing authorities, such as recruitment incentives, and  develop clear guidance for how the effectiveness of their use will be  assessed, among other things. Interior has partially responded to this  recommendation by its increased use of incentives, but it has not  evaluated their effectiveness. Interior also has not evaluated the  effectiveness of other tools, specifically the special salary rates and  student loan repayments. We developed a statistical model that Interior  could expand upon to analyze the effectiveness of specific tools. In the  absence of such evaluations, Interior cannot know the extent to which the  increased use of incentive payments, special salary rates, and student  loan repayments have been effective in hiring and retaining key staff. In  addition, without regular evaluation, Interior may not have information it  needs to determine if or how it should alter its approach when the oil and  gas market shifts and industry begins hiring more employees, potentially  increasing Interior’s competition with industry for oil and gas staff.
Further, Interior continues to face a lengthy hiring process, according to  officials. In January 2014, we also recommended that Interior  systematically collect data on hiring times for key oil and gas positions,  ensure the accuracy of the data, and analyze the data to identify the  causes of delays and expedite the hiring process. All three bureaus have  adopted new human resources software that may provide them with  better data to track their hiring process, and the bureaus have started to  analyze these data to identify what steps are causing delays in the hiring  process. We continue to believe that having accurate hiring data and  finding ways to reduce the lengthy hiring process are important steps  toward resolving Interior’s hiring challenges and may prove especially  important if the oil and gas market shifts.
Concerning training, Interior has not evaluated the bureaus’ training  needs or the training’s effectiveness as required by federal law and  regulations, and the bureaus’ have not fully evaluated their training efforts  as directed by Interior policy. None of the bureaus have consistently  performed annual evaluations of their training needs for all key staff, and  only one of the bureaus has developed technical competencies that are  critical to successful performance by these staff, as directed by Interior’s  Departmental Manual. Without evaluating training needs and developing  such competencies, Interior cannot ensure that the training it provides for  key oil and gas staff is linked to the competencies needed for the agency  to perform effectively and that the training addresses any competency  gaps. In addition, none of the bureaus have evaluated the effectiveness  of the training as directed by the Departmental Manual. Because Interior  and its bureaus have not fully evaluated their training efforts, Interior may  not be able to ensure that its key oil and gas staff are being adequately  trained to execute their oversight tasks, and it may not be spending  training funds effectively and efficiently. BLM’s inspector certification  training program stands out as an exception to these general findings  because BLM has evaluated inspectors’ training to ensure that they have  learned and can apply skills critical to their oversight duties. In contrast,  BSEE does not give inspectors proficiency examinations to measure  learning or application of skills, and does not certify them, as  recommended by two oversight bodies in 2010. Although BSEE officials  said they were finalizing their efforts to initiate the first evaluation of their  training efforts and were planning to complete a statement of what work  would be included in the second evaluation, unless they follow through  with and complete these efforts, the bureau cannot verify that its  inspectors are adequately trained.
Moreover, the Office of Policy, Management and Budget, which is  responsible for managing Interior’s human resources and addressing  cross-cutting issues, has not effectively facilitated collaboration among  the bureaus in addressing their shared hiring, retention, and training  challenges. Senior officials in Interior’s Office of Policy, Management and  Budget did not identify any collaboration mechanisms currently being  used to bring the three bureaus together to discuss their shared human  capital challenges and to share training resources. In the absence of such  a collaboration mechanism, the bureaus have sometimes acted in a  fragmented, overlapping, and potentially duplicative fashion to resolve  similar challenges. Without further leadership from the Office of Policy,  Management and Budget to create or make better use of an existing  mechanism, such as the Deputies Operating Group, Principals Operating  Group, or the Interior Training Directors Council, to facilitate collaboration  in hiring, retention, and training, the bureaus may continue to address  their shared challenges through fragmented and potentially duplicative  efforts.
section_title: Recommendations for Executive Action
paragraphs: To help ensure Interior can hire, retain, and train staff it needs to provide  effective oversight of oil and gas activities on federal lands and waters,  we recommend that the Secretary of the Interior take the following five  actions:  Direct the Assistant Secretary for Policy, Management and Budget to:
Regularly evaluate the effectiveness of its available incentives, such  as special salary rates, the student loan repayment program, and  other incentives in hiring and retaining key oil and gas staff.
Annually evaluate the bureaus’ training programs, including: staff training needs, potential opportunities for the bureaus to share training resources.
Direct the Assistant Secretary for Land and Minerals Management to:
Develop technical competencies for all key oil and gas staff.
Evaluate the need for and viability of a certification program for BSEE  inspectors.
Direct the Assistant Secretary for Policy, Management and Budget to  coordinate with the Assistant Secretary for Land and Minerals  Management to create or use an existing mechanism, such as the  Deputies Operating Group, Principals Operating Group, or the Interior  Training Directors Council, to facilitate collaboration across the three  bureaus in addressing their shared hiring, retention, and training  challenges.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided our draft report to Interior for review and comment. Interior  provided written comments, in which it agreed with one of the five  recommendations in the draft report, partially agreed with three others,  and disagreed with the remaining recommendation. Interior’s comments  are reproduced in appendix II, and key clarifying points from the  department are discussed below in the context of our recommendations.  Interior also provided technical comments, which we incorporated as  appropriate.
Interior agreed with our first recommendation, which would have the  Assistant Secretary for Policy, Management and Budget regularly  evaluate the effectiveness of its available incentives. Interior also  submitted several points of clarification and comments regarding our  related findings:   Interior clarified that it now has full approval for the special salary  rates. Interior also provided documents showing performance metrics  it would use to track and monitor the impact of special pay rates and  other pay flexibilities, such as incentive payments. We added  language to our report to further acknowledge these actions.
Interior disagreed (1) with the accuracy of how the report portrayed  the Office of Policy, Management and Budget’s role and (2) that the  office had missed opportunities to collaborate across the bureaus,  especially as it related to special salary rates for key positions. Interior  stated that the office was an integral partner, collaborator, and  coordinator among the departmental stakeholders and the bureaus'  leadership, human capital and budget teams. In response to Interior’s  comments, we added language to specifically identify the Office of  Policy, Management and Budget’s role and actions in the special  salary process. Regarding missed opportunities, Interior disagreed  that BOEM was excluded from the collaborative process for the  special salary requests. In the draft report, we did not state that  BOEM was excluded but rather that BOEM regional managers said  they were not aware that BLM was requesting the special salary rate  for its natural resource specialists and did not know that they could do  so. Therefore, while Interior stated that officials from the Office of  Policy, Management and Budget said that the office collaborated and  coordinated between departmental stakeholders, it appears not all  stakeholders were equally informed.
Interior stated that BLM's inclusion of natural resource specialists  does not have a negative impact on BOEM mission delivery. We did  not address such an impact in our report. We did state, however, that  since BLM can pay a natural resource specialist 35 percent more than  BOEM can, this difference may place BOEM at a disadvantage in its  recruitment efforts and its ability to retain staff if its natural resource  specialists leave to take a comparable position at BLM.
Interior stated that the data demonstrated that the greatest need for  BLM to acquire natural resource specialists was within the North  Dakota region and that BOEM does not maintain offices in that region.  However, BLM also offers the special salary rate for natural resource  specialists in other states where BOEM does maintain offices. In  addition, federal employees could relocate from one state to another  state in order to take a new job.
Interior partially agreed with our second recommendation, to have the  Assistant Secretary for Policy, Management and Budget annually  evaluate the bureaus’ training programs, including training needs, training  effectiveness and potential opportunities for the bureaus to share training  resources. Interior said that the Office of Policy, Management and Budget  would ensure that the three bureaus are coordinating their training needs  and that its Office of Strategic Employee and Organizational Development  can validate the bureaus’ engagement in this activity and provide support  in fulfilling  these recommendations. While these steps may be useful, as  stated in the report, Interior has not evaluated the bureaus’ training needs  or the training’s effectiveness as required by federal law and regulations,  and the bureaus have not fully evaluated their training efforts as directed  by Interior policy. We continue to believe that the Office of Policy,  Management and Budget is required by law and regulation to evaluate  the bureaus’ training programs. Without evaluating the bureaus’ training  programs, Interior cannot ensure that the training provided is sufficient to  support the required oversight duties.
Interior also submitted several points of clarification and comments  regarding related findings:   Interior stated that our report assumed that BOEM and BSEE should  be acquiring technical training from BLM, which, according to Interior,  does not accurately reflect the analysis conducted to determine the  training needs for offshore development or recognize the training  coordination that does occur. Relatedly, Interior stated that we did not  acknowledge the vastly different skill sets needed to inspect or permit  equipment needed for onshore versus offshore facilities. However, our  draft report did not state or assume that BLM would be training these  bureaus, and we did not recommend such an action. We did state that  it appears that Interior missed opportunities to improve the bureaus’  training efforts and facilitate the sharing of training resources in areas,  such as curricula development, which led to our second  recommendation. With regard to the differences in skill sets needed  for inspections, our interviews with agency officials support the point  that there are differences in these two inspection environments. We  added language to our report to better acknowledge these  differences. Nonetheless, our interviews also indicate that there are  common skills and knowledge used to inspect onshore and offshore  facilities. This point is illustrated by the fact that 15 BSEE staff took  one or more of BLM’s inspector certification training modules from  fiscal year 2012 through fiscal year 2015, according to BLM  documentation. We added language to our report to recognize that  BSEE staff took this BLM training.
Interior stated that our draft report did not recognize the training and  coordination that occurs and described collaborative efforts between  BSEE and BLM regarding training. We added language to our report  to recognize the BSEE staff who took BLM training. Nonetheless, it  appears that the Office of Policy, Management and Budget has  missed opportunities to facilitate the sharing of training resources, and  we continue to believe that there is a need for the type of evaluations  called for in our recommendation. Once the bureaus have made these  evaluations, they should be better able to identify overlapping skill  sets which could then be addressed by sharing training resources.
Interior also noted, with regard to BSEE training, that it would be  difficult and expensive to continuously update standard certification  modules and tests to keep pace with the technology changes in the  offshore oil and gas industry. Interior stated that BSEE therefore  chose to rely on vendors, rather than in-house expertise, to provide  classroom training. However, based on our review, none of the  bureaus has performed a level 5 evaluation, which would compare the  benefits and costs of training. As a result, the bureaus do not know  whether it would be cost effective to update certification modules  rather than continue the current reliance on vendors.
Interior partially agreed with our third recommendation that directed the  Assistant Secretary for Policy, Management and Budget to develop  technical competencies for all key oil and gas staff. In its comments,  Interior said that because oil and gas occupations are highly technical  positions, the bureaus would be best positioned to identify technical  competencies. We agree and have redirected our recommendation to the  Assistant Secretary for Land and Minerals Management, where the three  bureaus are housed.
Interior disagreed with our fourth recommendation that directed the  Assistant Secretary for Policy, Management and Budget to evaluate the  need for and viability  of a certification program for BSEE inspectors.  Regarding this recommendation, Interior said that oil and gas inspection  is highly technical and that BSEE was in the best position to evaluate the  technical training needed to carry out its authorities and responsibilities.  Based on this comment, we have redirected this recommendation to the  Assistant Secretary for Land and Minerals Management. Concerning our  related findings, Interior stated that the report does not recognize that  although BSEE Level II inspectors do not receive a formal certificate, they  receive a hands-on personal evaluation and approval from a supervisory  inspector. According to Interior, this supervisory approval confirms that  the Level II inspector attained all of the knowledge necessary through  course work and supervised on-the-job training—and, more importantly,  that the inspector sufficiently demonstrated these skills in the field—to  become a Level III  inspector. Although our current review of training  focused on technical training delivered through classroom instruction and  did not directly include an evaluation of on-the-job training, we agree that  such efforts are an important part of an inspection training program.  However, in July 2012, we reported that senior and regional office officials  stated that relying on a combination of on-the-job training, which included  pairing senior inspectors with newly hired inspectors, and some  classroom instruction produced inconsistent results because some senior  inspectors proved to be less effective trainers than others. We believe  that BLM’s model of training inspectors through a certification program  may offer some advantages over BSEE’s current approach, and we  continue to believe that the need for and viability of such a program for  BSEE inspectors should be evaluated.
Interior partially agreed with our fifth recommendation that directed the  Assistant Secretary for Policy, Management and Budget to coordinate  with the Assistant Secretary for Land and Minerals Management to create  or use an existing mechanism to facilitate collaboration across the three  bureaus in addressing their shared hiring, retention, and training  challenges. Interior stated that coordination already exists among the  bureaus and that, as part of the Office of Policy, Management and  Budget’s quarterly review of performance data, the office will ensure that  the bureaus continue to coordinate on hiring, retention, and training.  However, Interior disagreed with our statement that the Office of Policy,  Management and Budget has missed opportunities to collaborate across  bureaus to address recruitment and retention challenges. Our report  identifies examples of missed opportunities for collaboration, including  BSEE and BOEM recruitment teams who, according to team members,  participated in recruitment events such as job fairs separately and did not  give prospective applicants information about career opportunities  available at the other bureaus, even though they sought to hire staff with  similar skills. Because of these findings, we continue to believe that the  Office of Policy, Management and Budget should take a greater  leadership role in facilitating collaboration to address shared challenges  across the bureaus.
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If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or ruscof@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: Statistical Methodology Used to Examine Main Factors Associated with the Retention of Federal Employees in Key Oil and Gas Positions
paragraphs: To examine the Department of the Interior (Interior) efforts to resolve its  hiring and retention challenges for key oil and gas staff, we developed a  statistical model to examine the main factors that would reduce the  likelihood that federal employees in key positions—those that  corresponded to the positions of key oil and gas staff at the Bureau of  Land Management (BLM), the Bureau of Safety and Environmental  Enforcement (BSEE), and the Bureau of Ocean Energy Management  (BOEM) —would leave those positions.
subsections: section_title: Data
paragraphs: We developed a model to examine the main factors associated with  employee retention for key oil and gas-related employees at Interior. We  analyzed the probability of retention of federal employees hired on a  permanent basis into key oil and gas occupations from fiscal years 2003  through 2014. We used the Enterprise Human Resources Integration  (EHRI) database, which contains information on variables such as  adjusted basic pay, occupation, the agency where the employee worked,  hiring, separation, and awards. We supplemented the EHRI data with  data from the Standard & Poor’s 500 Energy Index (to measure demand  from the private sector for these key employees) and with data from BLM  to identify specifically those employees working in oil- and gas-related  positions.
section_title: Methods
paragraphs: Our model considered only federal employees who were hired as either  career competitive, conditional competitive, or career excepted; thus,  other type of hires, such as transfers-in or temporary hires, were not  included. We included only employees in our list of “key occupations”  throughout the federal government. In order to simplify our analysis, we  did not include employees with multiple periods of employment; that is,  we only considered those employees who were hired one time from 2003  through 2014. Employees who were hired more than once accounted for  only about 2 percent of the total number of hires during that time. In order  to be comprehensive and include separations other than just resignations,  we also included as “Quits” employees who had an inter-agency  transfers, either horizontal (same grade) or upward movement (higher  grade). Employees who separated for other reasons, such as retirement  or death, or who were still employed at the end of fiscal year 2014, were  treated as “Censored” by the model and no account was taken of the  difference in these types of “Exits” from the analysis. However, in order to  mitigate the effect on our model of possible separations due to retirement  or death, we excluded employees who were 50 or older at the time they  were hired.
section_title: Econometric Model
paragraphs: is the cumulative logistic probability distribution describing the probability  of i-th employee quitting at time (month) t and z(i,t) is a list (vector) of  variables that are believed to be associated with the i-th employee’s  probability of quitting at time t. Each employee is in the study for Tmonths and the data comprise each employee-month between the time  an employee was hired and the time that they either quit or they were  censored out of the study.
We used the following explanatory variables in our model:
The employee’s age at the time they were hired.
The employee’s gender.
The organization where the employee worked. We split this category
BLM employees in the key occupations who were also identified  by BLM as performing oil- and gas-related work.
Other BLM employees in the key occupations.
BOEM employees in key occupations for post-2011.
BSEE employees in key occupations for post-2011.
BOEMRE/MMS employees in key occupations through 2011. Note  that since we are using time-varying covariates, this category  changed starting in 2012 for any employee who was employed  during the redefinition of sub-agency organizations and  consequent reorganization.
Other Department of Interior employees in key occupations.
Federal government agencies other than Interior employees in key  occupations.
The frequency with which an employee received an award;  specifically, the number of awards in a given fiscal year per month  employed (at risk) in that fiscal year. We included the following award  categories:
Adjusted basic pay (salary) for the fiscal year.
Geographic location; specifically, the U.S. Census Division where the  employee’s duty station was located.
A set of time dummy variables indicating the employment duration  quarter for a given employee; that is, a dummy for any employee in  their first quarter of employment, a dummy for any employee in their  second quarter of employment and so on, up to a maximum of 47  dummies (there are 48 quarters from the start of 2003 to the end of  2014 so this allowed for 48 minus one dummy variables).
The percentage growth rate of the Standard & Poor’s 500 Energy  Index, which measured the health of the private energy sector and  consequent source of possible demand for federal employees in the  key occupations.
section_title: Results
paragraphs: A detailed set of results is shown in table 4. The main results pertinent to  our study were as follows:
All the awards variables except for student loan payments were  significantly associated with lowering the probability of quitting. The  student loan payments were significant at about the 6 percent level  but we hypothesized that these loan payments are more likely to go to  younger employees. This hypothesis was supported by our results  when we ran a second model that included an interaction term  between student loan payments and employees’ age when they were  hired. In this second model, the student loan payments were  significant and associated with a lower probability of quitting and the  interaction term was positive, suggesting the effect on reducing the  probability of quitting is greater for younger employees.
Higher adjusted basic pay (salary) was significantly associated with a  lower probability of quitting with the odds ratio higher by 1.8 percent  for each additional $1,000 in salary.
A faster growing private energy sector, as measured by the growth in  the Standard & Poor’s 500 Energy Index, was significantly associated  with a higher probability of quitting. This supports the hypothesis that  key occupation employees are attracted away from federal  employment when the private energy sector is performing well.
Organization results, relative to the base case; namely, key  occupation employees outside Interior, the following groups had a  significantly higher likelihood of quitting;
BLM employees identified by BLM as key oil- and gas-related  employees.
BSEE key occupation employees.
Other (outside BOEM, BSEE, and BLM) Interior key occupation  employees.
Occupation results, relative to the base case; namely, General  Inspection, Investigation  and Compliance occupation, the following  occupations had a higher likelihood of quitting:
General Natural Resource Management and Biological Scientists.
Environmental Protection Specialists.
section_title: Appendix II: Comments from the Department of Interior
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Dan Haas (Assistant Director),  John Barrett, Mark Braza, Scott Bruckner, Antoinette Capaccio, Michael  Kendix, Angela Miles, and Cynthia Norris made significant contributions  to this report. Also contributing to this report were David Bennett, Andrew  Berglund, Ashely Chaifetz, Eric Charles, Keya Chateauneuf, Clifton  Douglas, Glenn Fischer, Tom Gilbert, Paige Gilbreath, Holly Hobbs,  Steven Lozano, Sarah Martin, Gloria Ross, Lillian Slodkowski, Matt  Tabbert, Sarah Veale, Amy Ward-Meier, Michelle Wong, and Arvin Wu.