U.S. Department of Agriculture: Workforce Decisions Could Benefit from Better Linkage to Missions and Use of Leading Practices
Published: 2014-03-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: FSA, NRCS, and RD, USDA's service center agencies, interact directly with agricultural producers and rural communities through extensive field office structures. Achieving their missions depends in part on sustaining workforces with the necessary knowledge and skills. In fiscal year 2012, FSA, NRCS, and RD closed field offices and offered buyout and early retirement incentives to employees. GAO was asked to review aspects of USDA's human capital management.
This report examines: (1) how the workforces of USDA's service center agencies changed from fiscal year 2003 to fiscal year 2012, (2) the extent to which USDA's policy on supervisory ratios aligned with OPM guidance in fiscal year 2012, and (3) the extent to which USDA's service center agencies followed leading practices when closing offices and reducing staff in fiscal year 2012. GAO analyzed workforce data from OPM and USDA, reviewed documents, interviewed relevant officials, and compared leading practices with the actions agencies took to close offices and reduce staff in fiscal year 2012.
section_title: What GAO Found
paragraphs: From fiscal years 2003 to 2012, the size of the workforces declined at the U.S. Department of Agriculture's (USDA) service center agencies—the Farm Service Agency (FSA), Natural Resources Conservation Service (NRCS), and Rural Development (RD). The size of USDA's service center agencies declined by a higher percentage from fiscal years 2011 to 2012 than the average annual percent decline from fiscal years 2003 to 2012 (see fig.).
In fiscal year 2012, USDA policy on supervisory ratios did not align with Office of Personnel Management (OPM) guidance that states that an analytical approach can help agencies achieve the right balance of supervisory and nonsupervisory positions to support their missions. Instead, USDA's policy stated that all its agencies, regardless of their missions, should aim for a target ratio of one supervisor for at least nine employees (1:9). USDA officials were not able to provide a documented basis for this target ratio. In addition, USDA did not ensure that the service center agencies calculated their supervisory ratios the same way. As a result, USDA did not receive comparable information on supervisory ratios.
In fiscal year 2012, USDA's service center agencies generally followed or partially followed leading practices that GAO has identified when closing offices and using buyout and early retirement incentives as follows:
In closing offices, NRCS fully followed, and FSA and RD partially followed, the practice to present a business-case or cost-benefit analysis. USDA's policy on organizational changes did not direct agencies to follow leading practices to demonstrate to stakeholders they considered information such as underlying assumptions and other alternatives.
In using buyout and early retirement incentives, all three agencies fully followed practices to identify reshaping goals and to develop strategies that consider alternatives. However, NRCS followed, FSA partially followed, and RD did not follow the practice to link incentives to workforce reshaping or overall strategic goals. FSA and RD did not have human capital or workforce plans to clearly document how these strategies linked with broader efforts and could not show whether their remaining workforces had the right balance of skills in the right locations to support their missions.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that USDA take actions to revise its supervisory ratios policy; amend its policy on organizational changes to follow leading practices; and require RD and FSA to document links between various incentives and reshaping or strategic goals. USDA generally agreed with GAO's findings but disagreed with one finding and recommendation on supervisory ratios. GAO continues to believe in the need for a revised supervisory ratios policy.

section_title: Letter
paragraphs: The ability of the U. S. Department of Agriculture (USDA) to achieve its  mission depends in part on sustaining a workforce with the necessary  knowledge and skills. According to the Secretary of Agriculture, the  department has faced reductions in discretionary spending of about $3  billion (or 12 percent) from fiscal years 2010 to 2012. To implement these  reductions, USDA and its agencies have taken various actions to  restructure operations and reduce their staffs, including through closing  offices and offering buyout and early retirement incentives.
In fiscal year 2012, USDA announced that eight agencies would close  offices and programs. Of these, the three agencies with the largest overall  staffing level percentage reductions were USDA’s service center  agencies—the Farm Service Agency (FSA), Natural Resources  Conservation Service (NRCS), and Rural Development (RD). These  agencies interact directly with agricultural producers and rural  communities through an extensive field office structure.
In its 2012 annual report, USDA’s Office of Inspector General said the  need to plan for reduced staff in certain USDA agencies is one of the  department’s most serious management challenges. Specifically, the  report noted that USDA needs to ensure that, even as it reduces staff in  certain agencies, it maintains its ability to accomplish mission-critical  functions such as the servicing and oversight of billions of dollars in loans,  which are handled by USDA’s service center agencies. The Office of  Inspector General in its 2013 update on the department’s management  challenges stated that USDA should appropriately train and utilize its staff  in the face of significant staff reductions.
Having information on human capital trends over time such as changes in  staffing levels and shifts in occupation types can be helpful in  understanding the impact of such changes on the workforce and on an  agency’s ability to achieve its mission. For example, in a 2012 survey,  federal chief human capital officers noted the importance of using  workforce analytics to examine agency data and the need for data  analytics to be used as a predictive tool, particularly in the areas of  retirement and succession planning. In addition, we previously reported  that federal agencies experienced significant challenges to deploying the  right skills, in the right places, at the right time, in the wake of extensive  downsizing during the early 1990s, which was done largely without  sufficient consideration of the strategic consequences.
You asked us to review aspects of USDA’s human capital management  related to office closures and staff reduction efforts in fiscal year 2012.  This report examines: (1) how the workforces of USDA’s service center  agencies changed from fiscal year 2003 to fiscal year 2012, (2) the extent  to which USDA’s policy on supervisory ratios aligned with Office of  Personnel Management (OPM) guidance in fiscal year 2012, and (3) the  extent to which USDA’s service center agencies followed leading  practices when closing offices and reducing staff in fiscal year 2012.
To determine how the workforces of USDA’s service center agencies  changed from fiscal year 2003 to fiscal year 2012, we analyzed workforce  data from the OPM’s Enterprise Human Resources Integration database  and USDA’s National Finance Center; reviewed available reports, plans,  and departmental guidance from OPM and USDA related to human  capital management; and interviewed OPM and USDA officials. We took  several steps to ensure the reliability of the data and analytical process.  We chose to report workforce data for 10 years, starting in fiscal year  2003, because this period provided a historical context for the changes  that occurred in fiscal year 2012, among other things. Most of our  workforce data are reported for career permanent employees on full- or  part-time schedules because they represent a more stable part of the  workforce.
To determine the extent to which USDA’s policy on supervisory ratios  aligned with OPM guidance in fiscal year 2012, we reviewed OPM  guidance on its Human Capital Assessment and Accountability  Framework and compared it with USDA’s policy on supervisory ratios;  analyzed workforce data from OPM and USDA databases on supervisory  ratios; reviewed reports from USDA’s service center agencies on their  supervisory ratios and compared them with USDA guidance on  calculating supervisory ratios, as well as standards for internal control in  the federal government; and interviewed officials from OPM, USDA, and  USDA’s service center agencies.
To determine the extent to which USDA’s service center agencies  followed leading practices when closing offices and reducing staff, we  reviewed leading practices identified previously by GAO for successful  consolidations such as office closures and examined provisions in the  Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) applicable  to FSA’s office closures. We did not assess whether FSA complied with  the 2008 Farm Bill’s office closure provisions. In addition, we reviewed  provisions in the Chief Human Capital Officers Act of 2002 revising the  use of voluntary early retirement authority and voluntary separation  incentive payments, which are referred to in this report as buyout and  early retirement incentives. We also reviewed regulations and guidance  from OPM on the use of buyout and early retirement incentives and  leading practices from previous GAO work on consolidating physical  infrastructure and using buyout and early retirement incentives. For both  office closures and staffing reductions, we reviewed standards for internal  control in the federal government. We compared these criteria with  information provided by USDA’s service center agencies about the  actions they took to close offices and reduce staff in fiscal year 2012. We  also interviewed officials from the three agencies and representatives of  employee associations and unions to gather additional information about  the effects of office closures and staff reductions on agency operations.  Appendix I presents a more detailed description of our objectives, scope,  and methodology.
We conducted this performance audit from October 2012 to March 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: USDA is one of the largest civilian federal government departments, with  more than 100,000 employees as of the end of fiscal year 2012. It is  composed of 17 agencies and a number of departmental offices. FSA,  NRCS, and RD are collectively referred to as USDA’s service center  agencies. They provide financial and technical assistance to agricultural  producers and rural communities. Specifically, FSA provides payments  and loans to agricultural producers through various programs, including  farm commodity and crop disaster assistance programs authorized in the  2008 Farm Bill. NRCS provides, among other things, technical and  financial assistance to private landowners to implement conservation  practices on their land. NRCS’s Soil Science Division, along with other  federal agencies, states, and other entities, makes and maintains an  inventory of the soil resources of the United States and disseminates the  results for both nonfarm and farm uses. RD provides loans, grants, and  technical assistance to rural residents, businesses, and other entities.
The workforces of USDA’s service center agencies are located in national  headquarters operations, which include specialized offices in various  locations, as well as in extensive field office structures, which include  USDA service center locations. As of the end of fiscal year 2012, FSA’s  workforce was located in more than 2,100 offices, with a total of about  13,600 employees—about 1,300 in FSA’s headquarters operations and  about 12,300 in field locations. NRCS’s workforce was located in  approximately 2,900 offices, with a total of about 11,800 employees— about 1,200 in NRCS’s headquarters operations and about 10,600 in field  locations. RD’s workforce was located in more than 400 offices, with a  total of about 5,100 employees—about 1,400 in its headquarters  operations and about 3,700 in field locations.
USDA’s Blueprint for Stronger Service is a departmental initiative  announced by the Secretary of Agriculture in January 2012 that is  intended to streamline operations and cut costs across the department.  This initiative encompasses a number of efforts at the departmental and  agency levels. Office closures announced under the initiative in fiscal year  2012 resulted in the closure of more than 200 offices, facilities, and labs  in eight USDA agencies, including at USDA’s service center agencies. As  part of this initiative:
FSA closed 125 offices (out of about 2,100 total offices) in 32 states.  Based on information from FSA, these closures resulted in estimated  net savings, starting in fiscal year 2013, of about $2.1 million. In  choosing which offices to close, FSA officials told us they were guided  by provisions in the 2008 Farm Bill, which requires that, to the  maximum extent practicable, the agency must close offices with two  or fewer permanent full-time employees and that were less than 20  miles from another office before closing any office located more than  20 miles from another office. FSA officials also reported that they  closed unstaffed offices regardless of their distance from another  office. In addition to closing offices, FSA offered four rounds of  buyout or early retirement incentives to its employees in fiscal year  2012. With limited exceptions, three of the four rounds were offered to  staff in both headquarters operations and field locations, in some  cases subject to a priority order. The fourth offer was limited to  employees in offices selected for closures in fiscal year 2012. In  response to these incentives, OPM and USDA data indicate that 682  FSA employees accepted buyout or early retirement incentives,  which, according to FSA officials, resulted in about $20 million in cost  savings in fiscal year 2012.
NRCS closed 24 soil survey offices (out of about 160 soil survey  offices and about 2,800 offices overall) in 21 states. According to  NRCS officials, these closures resulted in estimated savings of about  $1.3 million in fiscal year 2013. NRCS officials told us that to  determine which local soil survey offices to close, they reviewed  offices’ funding, workload, and proximity to specific universities. For  regional office closure determinations, officials told us they considered  workload, proximity to transportation corridors, and equitable  distribution of local offices in each region. In addition to closing  offices, NRCS offered buyout and early retirement incentives to  employees affected by the soil survey office closures. According to  NRCS officials, 18 NRCS employees accepted buyout incentives, and  a subset of those individuals also accepted early retirement incentives  associated with its soil survey office closures in fiscal year 2012. The  savings NRCS attributed to employees accepting those incentives  was approximately $470,000 in fiscal year 2012.
RD closed 43 offices (out of more than 400 total offices) in 17 states.
According to RD officials, these closures resulted in estimated net  savings, starting in fiscal year 2013, of about $710,000. In choosing  which offices to close, RD officials told us that they used focus groups  and weighed multiple criteria, including whether (1) an office location  was in an isolated community, (2) a particular location served tribal  lands, and (3) other USDA agencies were contemplating a closure in  the same location. In addition, prior to the office closures, RD offered  buyout and early retirement incentives to all optional and early  retirement eligible employees, except for employees in two  occupations. OPM data indicate that 599 RD employees accepted  buyout or early retirement incentives in fiscal year 2012, which RD  officials told us resulted in about $25 million in cost savings in fiscal  year 2012.
Prior to this initiative, USDA’s service center agencies have closed  offices. For example, FSA officials told us that the agency has closed  hundreds of offices in the last 10 years as a result of staff reductions and  workload changes.
OPM provides guidance to federal agencies on human capital  management topics. For example, OPM issued the Human Capital  Assessment and Accountability Framework, which includes five systems  that provide a framework for human capital management for the federal  government. This guidance states, among other things, that an effectively  implemented workforce planning system results in the right balance of  supervisory and nonsupervisory positions to best support the agency  mission based on an analysis of customer needs and workload  distribution. OPM also provides guidance to agencies on classification of  grades and positions. For example, under the General Schedule,  agencies use a uniform set of OPM-issued standards to classify positions  into occupation series within five occupational groups, including (1)  professional and scientific positions, (2) administrative and management  positions, (3) technical and medical support positions, (4) clerical and  administrative support positions, and (5) other.
At USDA, the Office of Human Resources Management directs  implementation of the Human Capital Assessment and Accountability  Framework and evaluates human capital management policies, among  others, to determine how effectively they support human capital efforts to  achieve program results. Among other things, and as follows, the office:
Assists in the implementation of USDA’s Cultural Transformation, a  set of initiatives launched in 2010 to promote, among others, diversity,  inclusion, and high-performance. For example, the office issues a  monthly report that tracks progress on various measures, including  the diversity of the USDA workforce, performance management, and  communication with employees.
Provides guidance and oversight to USDA agencies on human capital  planning and management. For example, the office has developed a  draft human capital planning guide to aid its agencies in developing  human capital plans. As part of its oversight of human capital  management, the office oversees the implementation of a 2010 USDA  policy on the ratio of supervisors to employees that, among other  things, outlines a process for agencies to annually calculate their  supervisory ratios and provide the results to USDA.
USDA has a policy on organizational changes. Among other things, it  states that USDA’s Secretary or Assistant Secretary for Administration  must approve organizational changes that include, among other things,  the closure of an office. The policy also states that proposals for  organizational changes such as office closures include a variety of  detailed information, including (1) the circumstances giving rise to the  proposal; (2) human resource management, financial, and facilities  impacts; (3) a copy of an internal analysis on civil rights impact; and (4)  verification from agency management that internal control requirements  have been met.
In our past work, we have established leading practices for consolidation  initiatives such as office closures. Specifically, such practices include  the following:  Identify and agree upon goals. The key to any consolidation initiative  is the identification of and agreement on specific goals. Defining goals  can also help agency leaders clarify the benefits associated with a  consolidation and describe a future that will be both different from and  better than the past.
Present a business-case or cost-benefit analysis. Such an analysis  can help agencies show stakeholders why a particular initiative is  being considered and the range of alternatives considered to ensure  they are using public funds most effectively.
Identify stakeholders and develop a two-way communications  strategy. Since stakeholders often view consolidation as working  against their own interests, it is critical that agencies identify the  relevant stakeholders and develop a two-way communications  strategy that both addresses stakeholder concerns and conveys the  rationale for and overarching benefits associated with the  consolidation.
Implement consolidations using change management practices.  Implementing a consolidation requires the concentrated efforts of both  leadership and employees. Agencies should have an implementation  plan for the consolidation that includes, among other things, essential  change management practices such as active, engaged leadership at  the highest possible levels; a dedicated implementation team that can  be held accountable for change; and a strategy for documenting best  practices and measuring progress toward the established goals of the  consolidation.
In our past work, we have also established leading practices for  implementing staff reductions through the use of buyout and early  retirement incentives. Such practices include the following:  Identify the reshaping goals of the agency. This will assist agencies in  linking buyout and early retirement incentives to specific  organizational objectives.
Develop workforce reshaping strategies that fully consider alternative  methods. This will help agencies identify whether alternatives to  buyout and early retirement incentives may more effectively meet  agency reshaping goals and could work in conjunction with these  tools.
Design buyout and early retirement incentives that demonstrate a  clear relationship to the agency’s workforce reshaping goals and  overarching strategic goals. This will help ensure that employees  critical to the mission of an agency are retained.
Design buyout and early retirement incentives that consider  employees’ needs. Programs that do not do so may cause damage to  the agency’s reputation or negatively affect employee morale and  productivity.
Develop a communications strategy early in the process. Regular  communication with employees increases transparency in the process  used to determine which positions may be eliminated. This in turn  increases employee trust and maintains employee morale.
Establish an evaluation system to identify and report relevant data on  recipients of buyout and early retirement incentives. Agencies can use  these data to assess how well the buyout and early retirement  incentives are meeting or have met reshaping goals and whether they  need to adjust their strategies.
Of the six practices above, five are generally reinforced in the provisions  of the Chief Human Capital Officers Act and OPM regulations  implementing it. The one practice above that is not reflected in statutory  and OPM requirements relates to establishing an evaluation system to  identify and report relevant data on recipients of buyout and early  retirement incentives.
section_title: Size of the Workforces of USDA Service Center Agencies Decreased, but Other Workforce Characteristics Largely Remained Constant
paragraphs: From fiscal years 2003 to 2012, the size of the workforces decreased at  all three USDA service center agencies and the average number of  employees per supervisor decreased at two of them. The decrease in the  size of the workforces of USDA’s service center agencies accelerated in  fiscal year 2012 (see figs. 1 and 2). Specifically, in each of the last 10  years, the average decrease was approximately 4.5 percent in FSA, 1.4  percent in NRCS, and 3.3 percent in RD. From fiscal years 2011 to 2012,  the decrease was 9.2 percent in FSA, 3.8 percent in NRCS, and 14  percent in RD. Other characteristics of their workforces, such as grade  levels and occupation types, largely remained the same during this  period.
At USDA’s service center agencies, workforce decreases were smaller in  headquarters operations than in field locations and smaller for career  permanent employees than for employees with other appointments, such  as temporary employees (see table 1). Specifically, from fiscal years 2003  to 2012, the size of the workforce of each of the agencies’ headquarters  operations decreased at a slightly slower average annual rate than the  workforce of the agencies’ field locations. According to agency officials,  workforce decreases over this 10-year period were attributed to various  factors. At FSA, these decreases were due to budget constraints; at  NRCS, officials said they were due to changes associated with the Farm  Security and Rural Investment Act of 2002 (2002 Farm Bill) and the  2008 Farm Bill; and at RD, officials said they were due to the need to stay  within appropriated funding levels while other expenses increased, such  as those associated with information technology, office space rental  costs, and staff pay. We also reviewed the percentage change in the size  of the service center agencies’ workforces from fiscal years 2011 to 2012  and found that the workforce decreases were smaller in headquarters  operations than in the field for FSA and RD, but they were larger in  headquarters operations than in the field for NRCS. Based on our  analysis, some of these changes may be due to staff reduction efforts  undertaken by the agencies, while others may be attributed to natural  attrition. As it relates to the average annual decline in the number of  employees by appointment type, the number of career permanent  employees, which make up the majority of the agencies’ workforces, was  less than the average annual decline in the number of other employees,  such as temporary employees. This was also the case for the  percentage change in the size of the workforces from fiscal years 2011 to  2012. Most of the agencies’ temporary employees were in field locations  in fiscal year 2012. FSA officials told us that their temporary workers  perform many of the same functions as their career permanent  employees. For example, program technicians who implement  procedures, regulations, and operations of a county office’s administrative  program area, can be temporary or career permanent employees.
From fiscal years 2003 to 2012, the average number of employees per  supervisor, characterized in a supervisor-to-employee ratio, decreased at  FSA and RD but remained relatively constant at NRCS (see fig. 3).
NRCS officials told us that their supervisory ratio has not declined in the  past 10 years because of restructuring and additional responsibilities  assumed by its workforce as a result of the 2002 Farm Bill. During this  10-year period, there were more employees per supervisor in FSA’s  headquarters operations compared with its field locations. At NRCS and  RD, there were generally fewer employees per supervisor at their  headquarters operations than at their field locations. For example, in  fiscal year 2012, the supervisor-to-employee ratio in FSA’s headquarters  operations was approximately 1:5 compared with 1:4 in its field locations.  At NRCS, the supervisor-to-employee ratio in its headquarters operations  was approximately 1:6 compared with 1:14 in its field locations. At RD,  the supervisor-to-employee ratio in its headquarters operations was  approximately 1:6 compared with 1:8 in its field locations.
The median pay grades of the workforces of USDA’s service center  agencies remained relatively constant. Specifically, from fiscal years  2003 to 2012, the median pay grade for FSA stayed at pay grade 7, and  for NRCS and RD it stayed at pay grade 11. The median pay grades for  the service center agencies’ headquarters operations from fiscal years  2003 to 2012 were higher than in the field locations at FSA and NRCS but  the same, at 11, at RD. For example, at NRCS, the median pay grade  from fiscal years 2003 to 2012 was 12 or 13 in the agency’s headquarters  operations and 11 in its field locations. With respect to the grade  distribution of supervisors, these remained relatively constant at FSA and  RD, but the pay grades of the majority of supervisors increased at NRCS.  From fiscal years 2003 to 2012, the majority of supervisors at FSA were  in pay grades 10 to 12, and at RD, the majority of supervisors were in pay  grades 13 to 15. At NRCS, the majority of supervisors were in pay grades  10 to 12 in fiscal year 2003, but by fiscal year 2012, the majority were in  pay grades 13 to 15. NRCS officials told us that the pay grades of the  majority of supervisors have increased in the last 10 years due to the  increasing complexity of the agency’s work, primarily driven by changes  enacted in the 2002 Farm Bill.
The occupational makeup of USDA’s service center agencies also  remained relatively stable over the 10-year period (see fig. 4).  Specifically, the majority of the FSA and RD workforces were employed in  administrative and management occupations, such as loan specialists  who provide loan servicing and counseling assistance to borrowers. The  majority of the NRCS workforce was employed in professional and  scientific occupations, such as civil engineers, some of whom were  responsible for providing technical guidance and leadership in the overall  planning, design, installation, and maintenance of the engineering phases  of soil and water conservation projects. Additional information on the  workforces of USDA’s service center agencies in fiscal year 2012, such  as ethnicity and race, mission-critical occupations, length of service, and  retirement eligibility, is available in appendix II.
section_title: USDA’s Policy on Supervisory Ratios Did Not Align with OPM Guidance in Fiscal Year 2012
paragraphs: In fiscal year 2012, USDA policy on supervisory ratios, which targeted a  uniform supervisory ratio of one supervisor for at least nine employees at  all USDA agencies, did not align with OPM guidance. OPM’s guidance  states that analyzing customer needs and workload distribution can help  agencies achieve the right balance of supervisory and nonsupervisory  positions to support their missions. USDA policy, issued in October 2010,  did not reflect such an approach, but rather it stated that all agencies  should aim for a target ratio of one supervisor for at least nine employees  (1:9). USDA officials were not able to provide us with a documented basis  for this target ratio. In fiscal year 2012, our analysis showed that NRCS’s  supervisory ratio, at 1:12, met the USDA target of one supervisor for at  least nine employees, but FSA and RD—at 1:4 and 1:7, respectively—did  not. FSA and RD officials told us that they made improving their  supervisory ratios a management goal, but that meeting USDA’s target  may be difficult. Specifically, FSA officials told us that it may not be  feasible for FSA to meet the department’s target ratio because, due to  staff reductions, more county executive directors were involved in direct  program delivery in addition to supervising others performing that work.  RD officials told us that managing the supervisory ratios in accordance  with the USDA target was difficult as RD downsized its workforce in  recent years. However, the service center agencies were striving to meet  a target that may not have supported their missions because USDA’s  policy did not ask agencies to determine a supervisory ratio target based  on a documented analysis of their customer needs and workload  distribution.
In addition, USDA did not ensure that the service center agencies  followed its guidance when calculating their specific supervisory ratios.  Regardless of what ratio agencies are aiming to achieve, federal internal  control standards state that managers should exercise control to achieve  reasonable assurance that the objectives of the agency are being  achieved. USDA’s guidance to its agencies on implementing its policy  on supervisory ratios specified the formula agencies should use when  calculating supervisory ratios, such as the type of employees to consider  as supervisors. However, none of USDA’s service center agencies  followed the departmental guidance. Specifically, the service center  agencies considered more types of employees as supervisors than those  identified in the USDA guidance. USDA officials could not provide  documentation that the guidance was communicated to the service center  agencies but told us the guidance would have been circulated at the time  of the policy’s issuance, in 2010, to the mission areas’ human resources  directors. Further, USDA officials told us that supervisory ratios are one of  several measures that could be used to inform reorganization efforts.  However, because the service center agencies did not follow the USDA  guidance, their calculated supervisory ratios—a workforce analytic that  department management could use to help make human capital  decisions—were not comparable to one another. Without comparable  information on supervisory ratios, USDA cannot have a reasonable  assurance that the data it uses to support its human capital objectives,  such as those regarding reorganizations, are sound.
section_title: USDA’s Service Center Agencies Generally or Partially Followed Leading Practices When Closing Offices and Reducing Staff in Fiscal Year 2012
paragraphs: In fiscal year 2012, USDA’s service center agencies followed or partially  followed four leading practices when closing offices. In addition, FSA  was subject to specific office closure provisions in the 2008 Farm Bill, and  officials provided information related to those provisions for its fiscal year  2012 office closure decisions. FSA and NRCS followed or partially  followed six leading practices when using buyout and early retirement  incentives, and RD followed or partially followed five of those six.
subsections: section_title: USDA’s Service Center Agencies Followed or Partially Followed Leading Practices for Office Closures
paragraphs: USDA’s service center agencies partially or fully followed all four leading  practices we reviewed for successful office closures. Specifically, NRCS  fully followed three of the four leading practices and partially followed one.  FSA and RD fully followed two of the four leading practices and partially  followed two others. Figure 5 lists these leading practices and the extent  to which each service center agency followed them when implementing  fiscal year 2012 office closures.
All three service center agencies identified and agreed upon goals for  their office closures  (FSA  reported, defining goals can help decision makers understand what  problems need to be fixed, how to balance differing objectives, and how  to achieve long-term goals. The broad goals of each agency’s fiscal year  2012 office closures were defined by USDA’s Blueprint for Stronger  Service initiative, which officials said is intended to streamline operations,  cut costs, and make more effective use of USDA’s employees to improve  service to USDA customers and increase efficiency. In addition, each of  the service center agencies defined other goals for their fiscal year 2012  office closures. Specifically, FSA officials told us that the agency aimed to  improve service by having fewer but better-staffed offices. NRCS  , as shown in fig. 5). As we previously  documented specific goals associated with its closures, such as  improving its technical services and recruiting a more diverse workforce  while retaining current employees by ensuring offices were in more  desirable locations. At RD, officials told us that their goals included  streamlining operations in small offices and better leveraging resources.
subsections: section_title: Present a Business-Case or Cost-Benefit Analysis
paragraphs: NRCS followed and FSA and RD partially followed the leading practice of  presenting a business-case or cost-benefit analysis (FSA , NRCS ,  RD , as shown in fig. 5). According to the National Research Council, a  business-case analysis can make clear underlying assumptions,  alternatives considered, the full range of costs and benefits, and the  potential consequences for an organization and its missions. OMB  guidelines for agencies to consider when conducting a cost-benefit  analysis of federal programs say that such analysis should include a  policy rationale, explicit assumptions, an evaluation of the alternatives,  and a plan to verify program results. Further, federal internal control  standards call for federal agencies to document key decisions and to  manage and maintain the documentation and make it available for  examination. USDA has a policy on making organizational changes that  requests agencies to submit information on proposed closures that  include some elements of a business-case analysis, such as a detailed  explanation of the circumstances giving rise to the proposed closure and  verification from agency management that internal control policies have  been met. However, according to a USDA official, the Secretary of  Agriculture waived the department’s requests for such proposals for the  fiscal year 2012 office closures associated with the department’s  Blueprint for Stronger Service, saying that agencies had already done  work to assist in making decisions on the closures. In addition, the policy  does not ask agencies to document other elements of a business-case  analysis, such as underlying assumptions and alternatives considered.
NRCS prepared a written business-case analysis that explained its  decision making. This analysis included information that outlined the  current state of the agency’s Soil Science Division; reasons for proposed  organizational changes; and options considered, including pros and cons  for each. According to NRCS officials, the agency had prepared  documentation describing the case for office closures before USDA  waived its request for such documentation. NRCS officials used its  business-case documentation to aid in communication by sending the  document to external stakeholders to explain the rationale behind their  decisions.
Unlike NRCS, FSA and RD officials told us that they considered a variety  of office closure options to achieve their stated goals, but FSA officials  told us that no business-case or cost-benefit analyses were prepared,  and RD officials stated that due to leadership turnover they could not  locate any analyses that may have been prepared. For example, FSA  officials told us the agency considered alternatives, such as closing more  offices than were eventually closed. RD officials told us they considered  several factors in their decision regarding selecting offices for closures,  such as the type of communities where offices were located and whether  other USDA agencies were planning to close offices at that location, and  consulted with focus groups. However, neither FSA nor RD documented  these considerations in a business-case or cost-benefit analysis. A USDA  official said the agencies did not prepare written analyses because USDA  waived the policy for the office closures associated with the department’s  Blueprint for Stronger Service. The policy that was waived was USDA’s  policy on making organizational changes. However, this policy does not  include all elements of a business-case or cost-benefit analysis, such as  considering alternatives and documenting underlying assumptions.  Without presenting business-case or cost-benefit analyses, FSA and RD  cannot demonstrate to their workforces, agricultural producers, and other  stakeholders the alternatives they considered in their decision making  and the steps they took to make effective use of public funds in support of  their missions. For example, representatives of employee unions at RD  told us that it was unclear how RD management chose offices to close. At  FSA, employee group representatives raised questions about why the  agency was choosing to close field offices rather than consolidate offices  above the field office level. In addition, employee group representatives  and those commenting on the proposed closures during public meetings  raised questions about whether the decisions made sense from a  budgetary perspective or whether criteria used to close FSA’s unstaffed  offices took into account factors such as workload or the number of  beginning, older, and disadvantaged producers served by these offices.  FSA officials acknowledged that producing a formal business-case or  cost-benefit analysis would have provided a stronger basis for the  agency’s decision making.
section_title: Identify Relevant Stakeholders and Develop a Two-Way Communications Strategy
paragraphs: The three service center agencies fully followed the leading practice of  identifying relevant stakeholders and developing a two-way  communications strategy (FSA , NRCS , RD , as shown in fig. 5).  We have reported that stakeholders often view actions such as office  closures as working against their own interests, and that it is critical for  agencies to identify the relevant stakeholders and develop an ongoing  two-way communications strategy that addresses stakeholder concerns  but also conveys a rationale for and benefits of the closures. Specific  stakeholder groups varied for each agency, but all agencies identified  local officials and affected employees as stakeholders. To communicate  with stakeholders, each agency used specific procedures as follows:
FSA officials told us that the primary takeaway from the agency’s  office closures in 2006 was the importance of clear, consistent, and  thorough communication throughout the closure process. For its 2012  closures, FSA advertised and held public meetings in each county  where an office was proposed for closure. At its public meetings, FSA  provided information on the reasons for the proposed office closures,  noted the concerns of stakeholders about the closures, and allowed  for questions and answers. To communicate with internal  stakeholders, according to information provided by FSA officials, state  executive directors sent memos to affected employees and invited  them to contact their state executive director with any questions or  concerns.
NRCS officials told us that prior to the office closure announcement,  they discussed the possibility of office closures with selected internal  and external stakeholders to gather their input. Following the  announcement, officials told us that they communicated with internal  stakeholders largely through regular teleconferences such as weekly  telephone meetings to keep them updated on the status of the  closures. NRCS officials said a few stakeholders expressed concern  with the closures or provided alternatives, but the agency was not  able to fully respond to their input due to lack of time. Officials  acknowledged that giving stakeholders an opportunity to participate in  the process can be helpful in enhancing their partnerships.
RD officials said that state leaders used various means to  communicate with both internal and external stakeholders. For  example, prior to making closure decisions, RD officials told us they  used focus groups to gather input from stakeholders and, following  the announcements, state leaders shared information about the  closures through town hall meetings, local media, and written  communications. RD officials also told us that their state leaders were  in close contact with union representatives and that they did not need  to formally bargain with the unions or address grievances.
section_title: Use Change Management Practices
paragraphs: USDA’s service center agencies partially followed the leading practice of  using change management practices (FSA , NRCS , RD , as  shown in fig. 5). The leading practices state that to minimize the duration  and the significance of any reduced productivity and effectiveness,  agencies should use change management practices such as having (1)  active, engaged leadership at the highest possible levels; (2) a dedicated  implementation team; and (3) a strategy for measuring progress toward  goals and using lessons learned. The service center agencies followed  most of these practices, but they did not measure progress toward all  goals.
Departmental and agency leaders were actively involved in the service  center agencies’ fiscal year 2012 office closures. At the departmental  level, the Secretary announced all proposed closures in January 2012. In  addition, leaders such as FSA’s administrator and deputies, and RD  officials told us that their state directors and other senior leaders were  directly involved. As our leading practices for office closures state, having  such leadership involvement can help set the direction, pace, and tone of  the closures, and provide a clear, consistent rationale for agency staff.
Each service center agency also used an implementation team to  manage the work of the closures. FSA officials told us they had an  implementation team consisting of representatives from most of FSA’s  divisions and several departmental offices, including officials from FSA’s  field operations, Information Technology Services Division, and USDA’s  Office of Civil Rights. At NRCS, officials told us that they assembled  teams of senior leaders to develop proposals for and implement the  closures. At RD, officials told us that their property management directors,  among others, were part of their implementation team, and that those  directors met monthly with their counterparts at FSA and NRCS to plan  for the closings and the possible impact on the service center agencies.
Each agency documented that they tracked cost savings—a major goal of  the office closures. However, the service center agencies did not have  specific strategies in place to measure progress toward other stated office  closure goals such as NRCS’s goal to improve technical services or  FSA’s goal to improve service. For example, NRCS provided us with  information showing that the number of activities it has undertaken  associated with its technical soil services steadily increased from fiscal  years 2011 to 2013. However, these activities were only partially related  to work performed by soil survey offices, and NRCS did not provide us  with information on how those metrics were affected by its soil survey  office closures. At RD, officials told us that closing offices had helped  them with their goals to leverage resources and streamline operations,  but they could not demonstrate these benefits using specific metrics.  Similarly, FSA officials said that overall, agricultural producers’  participation in FSA programs has not decreased following the office  closures, but they did not provide specific participation information in  areas where offices had closed. USDA’s policy on making organizational  changes asks agencies to detail the circumstances giving rise to the  proposed changes, but it does not ask agencies to measure progress  toward office closure goals. However, our leading practices for office  closures state that agencies closing offices should have metrics of  success that should show progress toward achieving an intended level of  performance or results. In addition, standards for internal control in the  federal government call for agencies to ensure that performance  measures and indicators have been established and that actual  performance data are compared and analyzed against goals. Without  metrics, officials may lack information to help them make any needed  midcourse corrections, improve policy and operational effectiveness  following the closures, or inform stakeholders on progress or outcomes.
Officials from all three agencies told us they used lessons learned from  prior rounds of office closures to execute their fiscal year 2012 office  closures. As we previously reported, using lessons learned is a leading  practice that can aid in successful office consolidations such as office  closures. FSA officials used a checklist that the agency created as part of  its 2006 office closures to help implement the closures and ensure  specific steps were taken. FSA officials told us that using this checklist  helped smooth the closure process. NRCS officials stated that the agency  used experiences from 2011 office closures in its Resource Conservation  and Development Division to inform elements of its fiscal year 2012  closures such as devising a placement strategy for affected employees.  RD officials told us that they close offices on a regular basis and have  extensive knowledge of how to do so. They also told us that they worked  to capture lessons learned by, for example, helping to update USDA’s  Real Property Leasing Handbook to better address leasing issues related  to office closures based in part on lessons learned from the fiscal year  2012 closures.
section_title: The 2008 Farm Bill and the Farm Service Agency’s Office Closures
paragraphs: In fiscal year 2012, FSA’s office closure decisions were subject to section  14212(b) of the 2008 Farm Bill, which specifies an order for FSA office  closures and requires public meetings and congressional notifications of  proposed office closures. Under section 14212(b), offices that have two  or fewer permanent full-time employees and that are located less than 20  miles from another FSA office are required, to the maximum extent  practicable, to be closed before closing any office located more than 20  miles from another FSA office. We found that FSA decided to close 125  offices in fiscal year 2012. Of the 125 offices closed, 27 had no  permanent full-time employees and were located more than 20 miles from  another FSA office. The 98 other closed offices had two or fewer  permanent full-time employees and were located less than 20 miles from  another office but were not necessarily closed first. FSA officials told us  that the agency determined the timing of office closures based on  information collected from state directors on when the offices could notify  employees, schedule physical moves, and take other necessary actions  to close. FSA held a public meeting within 30 days of announcing the  proposed closure in each county where the office proposed for closure  was located. FSA also provided us with documentation of notifications  sent to congressional committees and members of the proposed office  closures showing that they were sent more than 90 days before FSA  made its final decision regarding the office closures. Additional  information on the FSA office closures and applicable provisions in the  2008 Farm Bill can be found in appendix III.
section_title: USDA’s Service Center Agencies Followed or Partially Followed Most Leading Practices for Using Buyout and Early Retirement Incentives
paragraphs: USDA’s service center agencies partially followed or fully followed most of  the six leading practices we have identified for using buyout and early  retirement incentives. FSA fully followed two of the leading practices  and partially followed four others. NRCS fully followed five leading  practices and partially followed one. RD fully followed four leading  practices, partially followed one, and did not follow one. Figure 6 lists  these leading practices and the extent to which each service center  agency followed them when implementing fiscal year 2012 buyout and  early retirement incentives.
USDA’s service center agencies followed the leading practice of  identifying reshaping goals when using buyout and early retirement  incentives (FSA , NRCS , RD , as shown in fig. 6). As we  previously reported, identifying reshaping goals can help agencies link  buyout and early retirement incentives to specific organizational  objectives. As was the case with office closures, all three agencies cited a  need to address budget reductions as a primary goal in their decisions to  offer buyout and early retirement incentives in fiscal year 2012. The  agencies also stated additional goals. For example, in a request to USDA  on the need to use the incentives in fiscal year 2012, FSA listed a number  of organizational objectives, including reducing administrative complexity,  optimizing service delivery, and increasing supervisory ratios. In its  request to USDA, NRCS stated that using buyout and early retirement  incentives could help the agency implement goals such as improving its  science and technology support delivery systems by, among other things,  reorganizing its Soil Survey Program. In its request to USDA, RD stated  that using the incentives would assist them in eliminating unnecessary  duplication of functions.
subsections: section_title: Develop Strategies That Fully Consider Alternative Methods
paragraphs: USDA’s service center agencies followed the leading practice of  developing strategies that fully consider alternative methods when using  buyout and early retirement incentives (FSA  shown in fig. 6). As we previously reported, considering alternatives to  using buyout and early retirement incentives can help agencies identify  whether the alternatives may more effectively meet their reshaping goals  and how the incentives could work in conjunction with other options. In  their proposals to use the incentives, all three agencies reported  considering other options to address budget shortfalls and used  incentives in conjunction with other options to achieve their workforce  reshaping goals. Specifically, they reported considering such tools as  furloughs and Reductions in Force and provided various reasons for  choosing not to implement them. For example, RD officials told us that  using buyout and early retirement incentives instead of furloughs and  Reductions in Force helped them avoid negative impacts such as  disruption to the workforce, decreased employee morale, and decreases  in diversity that can happen when implementing a Reduction in Force. In  addition to buyout and early retirement incentives, all three agencies  reported using additional workforce reshaping options such as hiring  freezes, reassigning employees, or reducing temporary positions.
section_title: Demonstrate a Clear Linkage to Workforce Reshaping or Overarching Strategic Goals
paragraphs: NRCS followed, FSA partially followed, and RD did not follow the leading  practice of demonstrating a clear linkage to workforce reshaping or  overall strategic goals when using buyout and early retirement incentives  (FSA  , as shown in fig. 6). We have reported that  designing programs that demonstrate a clear relationship between an  agency’s workforce reshaping goals helped agencies achieve those  goals. NRCS presented clear linkages to its workforce reshaping goals by  offering the buyout incentive only to employees directly associated with its  soil survey reshaping plan. Specifically, NRCS’s proposal to use buyout  and early retirement incentives discusses how using the incentives will  create savings to help improve its science and technology delivery  support systems by reorganizing its Soil Survey Program and reducing  the number of Soil Survey Offices in operation. The request also  discusses how workforce planning will help the agency address both a  projected loss of positions and any impact on agency operations. Further,  the agency’s fiscal year 2013-2017 workforce plan, which includes  information on the fiscal year 2012 reorganization, projected that buyout  and early retirement incentives might increase expected retirements,  thereby creating a need to enhance mentoring and on-the-job training  programs to assist in knowledge transfer.
FSA partially linked its buyout and early retirement incentives to its  workforce reshaping and overarching strategic goals using a selection  priority that targeted certain locations and positions to help ensure its  continued capacity to deliver core mission programs. However, while FSA  completed a broad workforce analysis in 2011, it had not updated its  human capital plan or workforce plan at the time it was making decisions  to offer buyout and early retirement incentives, and agency officials told  us that this analysis was not likely used to determine FSA’s selection  priority. As a result, FSA could not demonstrate whether they had  workforce goals that linked to their offerings, and they could not show  whether the remaining workforce had the right balance of skills in the right  locations to support its mission. FSA’s buyout and early retirement  incentives may have created unintended shortages of employees with  certain skills or created imbalances that could hamper mission  accomplishment. For example, FSA officials told us that they are  assigning new responsibilities to employees to redistribute work  performed by employees who took the buyout and early retirement  incentives. FSA officials also noted that because the incentives were  voluntary, the agency did not have control over which employees  accepted them.
RD’s buyout and early retirement incentives were not linked to workforce  reshaping or overarching strategic goals. Unlike the actions taken at FSA  and NRCS, RD’s incentives were not targeted and were available to any  staff member eligible for retirement or early retirement, except for  employees in two occupations. According to our analysis of OPM data,  there were about 2,400 RD employees eligible for retirement or early  retirement, and RD exempted approximately 100 employees from the  incentives, or about 4.2 percent of those eligible. In addition, RD officials  did not have a human capital or workforce plan to clearly document links  between its incentives and its workforce reshaping goals. RD officials told  us that the agency needed to reduce its workforce by as many people as  possible to address significant budget decreases. However, by offering  incentives to much of its workforce, RD lost a significant portion of its  ability to control the makeup of its workforce, which could impact its ability  to accomplish its mission. Specifically, without linking buyout and early  retirement incentives to workforce reshaping or broader strategic goals,  RD could not show whether its remaining workforce has the right balance  of skills in the right locations to support its mission. For example, our  analysis of OPM data indicates that, of the approximately 600 employees  who accepted buyout or early retirement incentives in fiscal year 2012,  approximately 455 employees served in occupations defined by RD as  mission critical.
section_title: Consider Employees’ Needs
paragraphs: NRCS and RD followed and FSA partially followed the leading practice of  considering employees needs when using buyout and early retirement  incentives (FSA , RD , NRCS  , as shown in fig. 6). As we have  reported, designing programs that consider employees’ needs can help  employees cope with changes. Officials told us that employees from the  three service center agencies were able to take department-wide  retirement training. In addition, RD officials told us they hosted their own  counseling sessions to help their employees decide whether to accept the  incentives. FSA and NRCS also requested to use buyout and early  retirement incentives in conjunction with office closures. Officials from  NRCS told us that the agency attempted to relocate employees to  locations that would not pose undue hardship. In addition, NRCS  conducted a Civil Rights Impact Analysis to review office closures and  noted that using buyout and early retirement incentives was intended to  mitigate negative impacts on affected employees. FSA officials said that  unions expressed some concerns about the agency’s notification  procedures, their ability to bargain on some issues, and the short period  of time that employees were given to decide whether to accept the  incentives. FSA officials told us that they were not able to offer much time  for employees to make decisions because the agency needed to separate  employees as early as possible in the fiscal year. However, FSA officials  said they built more time into the process when using the incentives in  fiscal year 2013. Officials from all three agencies reported that no  grievances were filed as a result of their buyout and early retirement  incentives.
section_title: Develop a Communications Strategy Early in the Process
paragraphs: NRCS and RD fully followed and FSA partially followed the leading  practice of developing a communications strategy early in the process  when using buyout and early retirement incentives (FSA , NRCS ,  RD , as shown in fig. 6). Prior to receiving authority to use buyout and  early retirement incentives, USDA management notified union  representatives, including those represented by the service center  agencies, that it had applied to OPM for the authority to offer buyout and  early retirement incentives. Once the department received the authority to  use the incentives, and the service center agencies finalized their  incentive offers, each agency issued a notice to its employees that  included key information such as answers to frequently asked questions  and information on how employees could contact human resources staff  for more details. NRCS officials told us that they held regular telephone  and videoconference meetings with staff eligible for the incentives and  provided updates via e-mail. RD officials said they met with employees  who expressed interest in the incentives and conducted multiple sessions  with eligible retirees to ensure that they were aware of their options. FSA  provided uniform notices to employees ahead of each buyout and early  retirement offering that described who was eligible and included  responses to frequently asked questions, but it did not have specified  strategies for communicating on a regular basis with its employees.  Employee group representatives said they were confused or had  concerns about the incentives. For example, FSA’s notice to employees  regarding its incentives did not provide the reasons behind its selection  priority for determining employees’ eligibility, and union representatives  told us that some employees expressed concern that they were excluded  from eligibility for nonmission related reasons or that their location was  being targeted for downsizing. We have reported that developing a  communications strategy early in the process can build an understanding  of the purpose of planned changes, which can improve transparency,  increase employee trust and help maintain employee morale. Subsequent  to fiscal year 2012, FSA has improved its communications to employees  in this area. For example, in its fiscal year 2013-2017 human capital plan,  FSA discusses how it determines buyout eligibility, and that the agency  would likely need to use early retirement incentives to mitigate future  funding reductions. Officials from all three agencies noted that no  grievances were filed in relation to their buyout and early retirement  incentives.
section_title: Establish an Evaluation System
paragraphs: USDA’s service center agencies partially followed the leading practice of  establishing an evaluation system when using buyout and early  retirement incentives (FSA , NRCS , RD , as shown in fig. 6). We  have reported that establishing an evaluation system to review the use of  such incentives after they have been offered and implemented can help  agencies assess the longer-term effectiveness of using the incentives.  For example, agencies could compare the length of service for  employees with employee decisions about accepting buyout and early  retirement incentives. Agencies could then use that information to  determine the composition and timing of future offers. In addition,  agencies could analyze whether the savings generated by buyout and  early retirement incentives would likely provide the best use of resources  in the future compared with other separation strategies, such as  involuntary staff reductions. USDA’s service center agencies kept track of  how many employees took advantage of the incentives and how much  money was saved. They also reported some additional information to the  department on their results. For example, NRCS reported that its  incentives, offered in conjunction with its fiscal year 2012 office closures,  helped the agency manage any negative impact of the closures and lower  the total number of employees needing placement in other positions, and  RD reported to USDA that the use of buyout and early retirement  incentives helped achieve budget savings and that enhanced training  may be needed to offset the loss of institutional knowledge created by  departing employees. However, the agencies did not conduct a broader  evaluation of their use of the incentives or report on the extent to which  the buyout and early retirement incentives met other stated goals to  support their missions. For example, FSA officials told us that they did not  evaluate how the incentives impacted nonbudgetary goals cited in their  agency’s request to use buyout and early retirement incentives, such as  improving supervisory ratios. NRCS officials told us that they did not  establish an evaluation system due to lack of time, but they  acknowledged that such information would be helpful in understanding,  among other things, the impact such incentives have on employees. In  addition, because the agencies did not examine, for example, the length  of service of employees who accepted incentives, how the savings  generated by the incentives compared with other options, such as  Reductions in Force, or what effects the use of incentives had on stated  workforce reshaping goals, agency managers cannot use resulting  information to inform future decisions.
section_title: Conclusions
paragraphs: When issuing its policy on supervisory ratios, USDA has taken important  steps to consider how these ratios relate to the effective management of  human capital. However, because this policy established a uniform  supervisory ratio target for all agencies across the department, it did not  align with OPM guidance on supervisory ratios. Adopting OPM’s guidance  would allow the service center agencies to identify supervisory ratio  targets that would support their unique missions, based on a documented  analysis of their customer needs and workload distribution. Further,  federal internal control standards state that managers should exercise  control to achieve reasonable assurance that the objectives of their  agency are being achieved, but USDA did not exercise control to ensure  that the service center agencies followed its guidance on calculating  supervisory ratios. USDA has not communicated the guidance on how to  calculate supervisory ratios to the service center agencies since 2010.  Ensuring that the service center agencies provide comparable information  on supervisory ratios would allow the department to use this information  to help determine whether its human capital objectives are being met.
Facing fiscal year 2012 budget realities, USDA’s service center agencies  needed to make difficult decisions to close field offices. In doing so, the  agencies followed or partially followed many leading practices associated  with effective implementation of office closures. Nevertheless, given  ongoing budget pressures, agencies may again face similar situations.  USDA’s policy governing organizational changes does not direct agencies  to fully follow leading practices such as presenting all elements of a  business-case or cost-benefit analysis or measuring progress toward  stated goals. Following these practices could improve transparency and  decision making while also helping the agencies meet internal control  standards in support of their missions. Specifically, asking agencies to  follow the leading practice of presenting a business-case or cost-benefit  analysis could help agencies clearly communicate the rationale for their  decisions to all stakeholders and show that they are aiming to make  effective use of public funds as they work to implement their missions. It  could also help them meet internal control standards to document key  decisions. Similarly, asking agencies to follow the leading practice of  measuring progress toward goals could help agencies meet internal  control standards to establish and use performance measures, while also  helping them to make any needed midcourse corrections, improve  effectiveness following office closures, or inform stakeholders on their  progress or outcomes.
USDA’s service center agencies also made important decisions to reduce  staff in fiscal year 2012 by using buyout and early retirement incentives  and, in doing so, they followed most leading practices associated with the  effective use of such tools. However, ongoing budget constraints may  again require considering the use of these incentives. In such instances,  FSA and RD might find it easier to avoid unintended shortages or  imbalances of employees with certain skills that could hamper  accomplishment of their missions if they clearly linked their buyout and  early retirement incentives to their workforce reshaping goals or overall  strategic goals. In addition, establishing and using a system to identify  and evaluate relevant data on use of the incentives would allow USDA’s  service center agencies to better understand whether the incentives they  offer are the best use of their limited resources, which could help to  inform future actions in support of their missions.
section_title: Recommendations for Executive Action
paragraphs: We are making the following five recommendations to the Secretary of  Agriculture:  To ensure appropriate levels of employees’ supervision and guidance for  the workforces of USDA’s service center agencies, we recommend that  the Secretary of Agriculture, through the Chief Human Capital Officer,  take the following two actions:
Consistent with OPM guidance, revise departmental policy targeting a  uniform supervisory ratio so that the service center agencies can  identify appropriate supervisory ratios based on a documented  analysis of their specific customer needs and workload distribution.
Consistent with federal internal control standards, communicate to the  service center agencies the departmental guidance for calculating  supervisory ratios and ensure its use.
To help USDA’s service center agencies effectively implement office  closures and meet internal control standards, we recommend that the  Secretary take action to amend USDA’s policy on organizational changes  to include such leading practices as presenting a business-case or cost- benefit analysis and using the change management practice of measuring  progress toward stated goals.
To improve the use of buyout or early retirement incentives, we  recommend that the Secretary of Agriculture direct its service center  agencies to take the following two actions:
FSA and RD to document clear links between their buyout and early  retirement incentives and their reshaping or overall strategic goals.
FSA, NRCS, and RD to establish a system for identifying and  evaluating relevant data on buyout and early retirement incentive  recipients.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided USDA with a draft of this report for comment. USDA  provided written comments, which are summarized below and reproduced  in appendix IV. In its comment letter, USDA generally agreed with some  of the findings and disagreed with one finding and recommendation.  USDA did not explicitly comment on other recommendations.
USDA generally agreed with our findings on the use of leading practices  when closing offices and reducing staff in fiscal year 2012, and did not  comment specifically on our associated recommendations. USDA stated  that actions taken by its service center agencies to close offices and  reduce staff were in response to significant budget cuts and needed to be  implemented in a relatively short time frame. USDA further stated that the  agencies followed requirements in taking these actions, and did an  excellent job linking their workforce decisions to mission. We adjusted our  report’s title to reflect that we believe USDA’s workforce decisions could  benefit from implementation of our findings and recommendations.
USDA did not agree with our finding that USDA’s policy on supervisory  ratios did not align with OPM guidance and our associated  recommendation that USDA revise this policy. USDA stated that OPM’s  guidance on supervisory ratios is written purposefully broad and that the  policy allows the department to hold supervisors and managers  accountable for the responsible stewardship of resources. We agree that  OPM’s guidance is broad and that it allows agencies discretion. As we  reported, it also states that an effective balance of supervisory and non- supervisory positions is achieved when agencies analyze their customer  needs and workload distribution to support their missions. USDA was not  able to provide us with evidence that its policy targeting a ratio of 1  supervisor to at least 9 employees was based on such an analysis or on  other information suggesting that a uniform target was appropriate for all  of the service center agencies given their diverse missions, customer  needs, and workload distribution. Further, USDA stated that its policy  allows agencies to document the reasons for instances in which the  supervisory ratio does not meet the departmental target of 1 supervisor to  at least 9 employees by considering factors such as job complexity and  diversity of assigned functions. However, documenting such deviations  requires that USDA’s agencies show why it is appropriate for them to  deviate from a department-wide policy as opposed to factoring such  analysis into their supervisory ratios initially. Finally, USDA notes that the  policy was effectively communicated to all agencies and staff offices,  along with supplemental guidance on how to calculate supervisor-to- employee ratios. During our review, USDA officials provided us a  guidance document on how to calculate supervisory ratios and said that  they had provided it to the mission areas’ human resources directors in  2010. However, as discussed in our report, USDA officials could not  provide documentation that the guidance was communicated to the  service center agencies, and none of the service center agencies  followed this guidance. Therefore, we continue to believe that USDA  needs to revise departmental policy targeting a uniform supervisory ratio,  communicate to the service center agencies guidance for calculating  supervisory ratios, and ensure its use.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretary of  Agriculture, the Director of the Office of Personnel Management, and the  appropriate congressional committees. In addition, this report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or fennella@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. Key contributors to this report are listed in  appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines: (1) how the workforces of USDA’s service center  agencies changed from fiscal year 2003 to fiscal year 2012, (2) the extent  to which USDA’s policy on supervisory ratios aligned with Office of  Personnel Management (OPM) guidance in fiscal year 2012, and (3) the  extent to which USDA’s service center agencies followed leading  practices when closing offices and reducing staff in fiscal year 2012.
We chose the three USDA service center agencies—the Farm Service  Agency (FSA), Natural Resources Conservation Service (NRCS), and  Rural Development (RD)—because, of the eight USDA agencies that had  announced they would close offices and programs in fiscal year 2012,  these agencies had the largest staffing level percent reductions. We  chose to report workforce data for 10 years, starting with fiscal year 2003,  because this period (1) provided a historical context for the changes that  occurred in fiscal year 2012 and (2) encompassed the agencies’  operations under two farm bills: the Farm Security and Rural Investment  Act of 2002 and the Food, Conservation, and Energy Act of 2008 (2008  Farm Bill).
To determine how the workforces of USDA’s service center agencies  changed from fiscal year 2003 to fiscal year 2012, we analyzed workforce  data from OPM’s Enterprise Human Resources Integration database and  USDA’s National Finance Center; reviewed available reports, plans, and  guidance from OPM and USDA related to human capital management;  and interviewed OPM and USDA officials. Using the OPM and USDA  data, we determined the changes in the workforces of USDA’s service  center agencies, including the General Schedule, Senior Executive  Service, as well as county office employees, who are not federal  employees and are, therefore, not captured in OPM’s database. For  county office employees, we obtained their workforce data from USDA  directly. Our analysis focused on career permanent employees on a full-  or part-time year-round schedule. We generally excluded temporary and  term-limited employees and schedules other than full- and part-time (such  as intermittent or seasonal) because these employees are generally not  eligible for civil service benefits and represent a more transient workforce.  When reporting data on employees by location, we defined headquarters  operations to include the Washington, D.C., locality pay area and other  duty stations that are considered to be part of the headquarters  operations. For FSA, these locations include Kansas City, Missouri; St.  Louis, Missouri; and Salt Lake City, Utah. For NRCS, these include Fort  Collins, Colorado; Fort Worth, Texas; Greensboro, North Carolina;  Lincoln, Nebraska; Little Rock, Arkansas; and Portland, Oregon. For RD,  this includes St. Louis, Missouri. For the purpose of this report,  employees in all other duty stations are considered to be in field  locations. We calculated supervisory ratios by comparing the number of  supervisors or managers with the number of nonsupervisors or  managers, as defined by OPM, in accordance with the USDA’s Office of  Human Resources Management’s guidance. We did not independently  check the agencies’ coding of supervisors.
We completed additional analyses on the workforces of USDA’s service  center agencies at the end of fiscal year 2012 because, during that year,  USDA announced the Blueprint for Stronger Service, an initiative that  included office closures and resulted, in some cases, in the offerings of  buyout and early retirement incentives. Such actions could affect the size  and composition of the workforces of USDA’s service center agencies.
We analyzed USDA’s service center agencies’ ethnicity and race, gender,  pay grade levels, mission-critical occupations, length of federal service,  and retirement eligibility. We used OPM’s standard categories for our  analysis of ethnicity and race and gender. Our analysis of pay grade  levels included employees on the General Schedule, as well as county  office employees, whose grade levels are comparable to the General  Schedule pay plan. We grouped grade levels into three categories; the  middle range covers the median grades of NRCS’s and RD’s workforces,  as well as the FSA headquarters workforce. To analyze mission-critical  occupations, we obtained a list of these occupational series from the  agencies’ workforce plans or agency officials. To provide more detailed  information about mission-critical occupations, we obtained position  descriptions from USDA’s service center agencies. We grouped length of  federal service into five categories based on typical attrition patterns. To  determine the current and projected retirement eligibility, we used  employees’ age at hire, federal government service start date, birth date,  and retirement plan coverage to calculate the date they would become  eligible for voluntary retirement with an unreduced annuity.
We took several steps to ensure the reliability of the data and analytical  process. We discussed the reliability of the USDA data with  knowledgeable officials and collected additional data reliability information  on both OPM and USDA data through interviews with FSA, NRCS, and  RD. In our analysis of OPM and USDA data, we checked for outliers or  obvious errors and followed up with USDA when such issues were  identified. In addition, where we identified anomalies or significant change  in trends in our detailed analysis of the size of the workforces and  supervisory ratios, we corroborated these findings with agency human  capital staff and published reports. Lastly, the programming code for this  analysis was reviewed by an independent specialist to verify its technical  and logical accuracy.
To determine the extent to which USDA policy on supervisory ratios  aligned with OPM guidance in fiscal year 2012, we reviewed OPM  guidance on its Human Capital Assessment and Accountability  Framework and compared it with USDA’s policy on supervisory ratios;  analyzed workforce data from OPM and USDA databases on supervisory  ratios; reviewed reports from USDA’s service center agencies on their  supervisory ratios and compared them with USDA guidance on  calculating supervisory ratios, as well as standards for internal control in  the federal government; and interviewed officials from OPM, USDA, and  USDA’s service center agencies.
To determine the extent to which USDA’s service center agencies  followed leading practices to close offices and reduce staff in fiscal year  2012, we identified leading practices for both office closures and staff  reductions through the use of buyout and early retirement incentives. For  office closures, we reviewed previous GAO work on consolidating  physical infrastructure to identify four leading practices for successful  office closures. These include: (1) identify and agree upon goals, (2)  present a business-case or cost-benefit analysis, (3) identify stakeholders  and develop a two-way communications strategy, and (4) implement  consolidations using change management practices. For staff reductions,  we reviewed provisions of the Chief Human Capital Officers Act of 2002  that revise the use of voluntary early retirement authority and voluntary  separation incentive payments, regulations and guidance from OPM on  the use of buyout and early retirement incentives, and leading practices  from previous GAO work to identify six leading practices for implementing  buyout and early retirement incentives. These include: (1) identify  reshaping goals, (2) develop strategies that fully consider alternative  methods, (3) demonstrate a clear linkage to workforce reshaping and  overarching strategic goals, (4) consider employees’ needs, (5) develop a  communications strategy early in the process, and (6) establish an  evaluation system. We also reviewed standards for internal control in the  federal government. We gathered information on agency actions by  collecting documentation and interviewing officials from FSA, NRCS, and  RD. We also interviewed representatives of unions and employee  associations at FSA and RD. We assessed each agency’s reported  actions against the identified leading practices to determine the extent to  which each agency’s actions aligned with these practices. Because the  leading practices are not requirements, we did not perform a compliance  review. To communicate the results of our review, we used the terms,  “followed,” “partially followed,” and “did not follow” to reflect in plain  language the extent to which each agency’s actions aligned with identified  leading practices. A determination of “followed” means that the agency  provided evidence that it had taken major actions in alignment with that  leading practice. A determination of “partially followed” means that the  agency provided evidence that it had taken some actions in alignment  with that leading practice. A determination of “did not follow” means that  the agency did not provide evidence that it had taken any actions in  alignment with that leading practice. To determine the number and type of  service center agency staff members who accepted buyout and early  retirement incentives, we used information provided by each agency and  analyzed workforce data from OPM’s Enterprise Human Resources  Integration database. Eligibility for retirement or early retirement is based  on age at hire, birth date, service computation date, and retirement plan.  Because the OPM data we have did not include the specific day of the  month for each employee’s service computation date and birthday, these  results may be off by up to 1 month.
To review FSA’s fiscal year 2012 decisions related to office closures and  requirements in the 2008 Farm Bill, we compared provisions in the 2008  Farm Bill with information from FSA on each office that closed as a result  of the USDA announcement made in fiscal year 2012 related to: (1)  location and distance from the nearest FSA office; (2) the number and  type of employees; (3) the location and date of public meetings; (4) the  dates of congressional notifications; and (5) the actual date closed. To  determine the locations and distances of each closed office, we used  USDA-provided addresses to independently calculate the latitude and  longitude for each street address of each closed office and its next  closest office as identified by USDA. Using these addresses, we  independently calculated the distances between the closed and nearest  offices using our calculated latitude and longitude. In instances where  automated tools could not determine a specific location for a given  address, our analysis relied on manual determination of geocoordinates.  We did not assess whether FSA complied with the 2008 Farm Bill’s office  closure provisions.
We conducted this performance audit from October 2012 to March 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.
section_title: Appendix II: Additional Information on the Workforces of USDA’s Service Center Agencies in Fiscal Year 2012
paragraphs: In fiscal year 2012, the headquarters and field workforces of the USDA  service center agencies were different from each other with respect to  ethnicity, race, gender, and pay grade. As it relates to race and ethnicity,  workforces were more diverse in headquarters operations than field  locations of the service center agencies. In terms of pay grades, a greater  proportion of the workforces in headquarters operations were at pay  grades 13-15 than was the case in field locations of the service center  agencies. USDA and its service center agencies identified a number of  mission-critical occupations, which applied across their headquarters  operations and field locations. Across all locations, over 40 percent of the  workforces of USDA’s service center agencies had 20 or more years of  service. In general, a higher proportion of supervisors was eligible, or  projected to become eligible, for retirement compared with all employees  of USDA’s service center agencies.
subsections: section_title: Composition of the Workforces of USDA’s Service Center Agencies by Ethnicity, Race, and Gender in Fiscal Year 2012
paragraphs: In fiscal year 2012, the career permanent workforces of USDA’s service  center agencies’ headquarters operations were more diverse than their  field locations. As shown in figure 7, white employees constituted about  one-half or two-thirds of the headquarters operations of the workforces of  the three agencies but about 80 percent or more of their field locations’  workforces. In general, African American or black employees made up  the second largest percentage of the workforce in the service center  agencies’ headquarters operations and field locations. For all of the  service center agencies, they made up a larger proportion of the  workforces in headquarters operations than those in field locations.
With respect to gender, women comprised the majority of the career  permanent workforces of Farm Service Agency (FSA) and Rural  Development (RD) (72 percent and 65 percent, respectively), and about  35 percent of the career permanent workforce of Natural Resources  Conservation Service (NRCS). However, women made up a smaller  proportion of supervisors than their share of the workforces of all three  service center agencies—making up about 36 percent of supervisors at  FSA, 28 percent at NRCS, and 39 percent at RD. With respect to  women’s share of the workforce in headquarters operations as compared  with field locations, the service center agencies differed from each other.  At FSA, women made up a smaller portion of the headquarters operations  workforce as compared with the field locations workforce (58 percent and  74 percent, respectively). At NRCS, women made up a higher share of  the workforce at headquarters operations compared with the field  locations (44 percent and 34 percent, respectively). At RD, women’s  share of the workforce was approximately the same at both headquarters  operations and field locations (67 percent and 64 percent, respectively).
section_title: Composition of the Workforces of USDA’s Service Center Agencies by Grade in Fiscal Year 2012
paragraphs: In fiscal year 2012, a greater proportion of the career permanent  workforces of USDA’s service center agencies in headquarters operations  were at pay grades 13-15 than those in field locations (as shown in fig. 8).  In field locations, the majority of FSA employees were in pay grades 1-9;  in NRCS and RD, more employees were at pay grades 10-12 than other  grades.
section_title: Mission-Critical Occupations of USDA and Its Service Center Agencies in Fiscal Year 2012
paragraphs: In fiscal year 2012, USDA designated three mission-critical occupations  (MCO) as its overall departmental MCOs based on considerations related  to recruitment and retention challenges. They are (1) Human Resources  Management (0201), (2) Contracting (1102), and (3) Informational  Technology Management (2210). In addition, in fiscal year 2012, in  response to USDA’s request, each service center agency reported  between three and five MCOs to USDA as listed below.
subsections: section_title: Farm Service Agency
paragraphs: In fiscal year 2012, FSA reported five MCOs to USDA. Approximately 37  percent of employees in headquarters operations and 92 percent of  employees in field locations were classified in one of these occupations.  All of these occupations are classified as administrative and  management. Table 2 lists the MCOs for FSA as reported to USDA in  fiscal year 2012, including occupation codes, titles, and examples of  position descriptions.
In fiscal year 2012, NRCS reported three MCOs to USDA. Approximately  21 percent of employees in headquarters operations and 49 percent of  employees in field locations were classified in one of these MCOs. All of  these MCOs are classified as professional and scientific occupations.  Table 3 lists the MCOs for NRCS as reported to USDA in fiscal year  2012, including occupation codes, titles, and examples of position  descriptions.
In fiscal year 2012, RD reported five MCOs to USDA. Approximately 61  percent of employees in headquarters operations and 79 percent of  employees in field locations were classified in one of these MCOs. All of  RD’s reported MCOs, except for Accounting (0510), which is classified as  a professional and scientific occupation, are classified as administrative  and management. Table 4 lists the MCOs for RD as reported to USDA in  fiscal year 2012, including occupation codes, titles, and examples of  position descriptions.
section_title: Composition of the Workforces of USDA’s Service Center Agencies by Length of Service in Fiscal Year 2012
paragraphs: The proportion of the career permanent workforces of USDA’s service  center agencies with 20 or more years of federal service in fiscal year  2012 was over 50 percent at FSA, over 40 percent at NRCS, and over 45  percent at RD (as shown in fig. 9). Employees may be eligible for early  retirement incentives once they have 20 or more years of service and are  over the age of 50 or have 25 or more years of service regardless of age.  The mean length of service of FSA employees was 19 years, for NRCS it  was 16 years, and for RD it was 18 years. At FSA and NRCS, employees  in headquarters operations have, on average, more federal service years  than those in field locations. At FSA, the mean length of federal service  for the headquarters operations workforce was 21 years and, for the field  locations, it was 18 years. Similarly, at NRCS, the mean length of service  for the headquarters operations workforce was 19 years, and for the field  locations, it was 16 years. At RD, the headquarters operations and field  locations workforces had the same mean length of service of 18 years.
section_title: Current and Projected Retirement Eligibility of the Workforces of USDA’s Service Center Agencies in Fiscal Year 2012
paragraphs: About 15 percent of the career permanent workforces of USDA’s service  center agencies were eligible to retire in fiscal year 2012, as shown in  figure 10. For supervisors, the proportion was higher: at FSA it was 19  percent, at NRCS it was 24 percent, and at RD it was 22 percent. Over  the next 5 years, an additional 17 percent or more of the workforces of  each of the service center agencies and 25 percent or more of their  supervisors will become retirement-eligible for the first time.
section_title: Appendix III: Section 14212(b) of the Food, Conservation, and Energy Act of 2008 and the Farm Service Agency’s Office Closures Initiated in Fiscal Year 2012
paragraphs: Section 14212(b) of the Food, Conservation, and Energy Act of 2008  (2008 Farm Bill) prescribes an order for closure of Farm Service Agency  (FSA) offices after June 18, 2010, and requires public and congressional  notification of proposed closures. Specifically, under section 14212(b), if  the Secretary of Agriculture closes FSA offices after June 18, 2010,  offices that have two or fewer permanent full-time employees and are  located less than 20 miles from another FSA office are required, to the  maximum extent practicable, to be closed before closing offices located  more than 20 miles from another FSA office. In addition, the Secretary  must (1) hold a public meeting in the county where the office is located  within 30 days of proposing its closure and (2) notify the relevant  congressional committees and delegations of a proposed office closure  after the public meetings and not less than 90 days before approving the  office’s closure.
subsections: section_title: FSA Proposed Offices for Closure Based on Staffing and Distance from Other FSA Offices
paragraphs: On January 9, 2012, the Secretary of Agriculture initially proposed closing  131 FSA offices. The list included both offices with two or fewer  permanent full-time employees that were located less than 20 miles from  another FSA office and offices located more than 20 miles from another  FSA office. The offices located more than 20 miles from another office  had no employees. To determine the number of employees in each office,  FSA officials told us that they counted permanent, full-time General  Schedule or county office employees. State-level and temporary  employees did not count toward the total number of employees in an  office. To determine the distances between offices, FSA officials said they  used a mapping software program to determine whether or not an office  was located within 20 miles of another FSA office. FSA officials stated  that they calculated the shortest distance between offices rather than  driving distance. However, according to FSA officials, their software  defaulted to the center of the zip code if a street could not be found, so  FSA used a proxy in those instances rather than an actual address.
section_title: FSA Held Public Meetings and Accepted Comments
paragraphs: FSA held public meetings and accepted comments on the proposed  closures. Between January 19, 2012, and February 8, 2012—within 30  days of proposing the office closures—FSA held a public meeting in each  county where the offices proposed for closure were located. FSA officials  told us that they publicized meetings through newspaper advertisements  and mailers to agricultural producers, among others. During these public  meetings, FSA recorded public comments, and officials said that  concerns were incorporated into their office closure decisions. For  example, public meeting participants said that FSA program participation  would decline as a result of the office closures, particularly among  beginning, elderly, and disadvantaged producers who may endure extra  hardships from traveling greater distances to the next-closest FSA office.  Participants also said that the distances calculated by FSA did not  accurately reflect the amount of time it takes producers to reach FSA  offices. As a result of public meeting participant concerns, FSA officials  told us that in the event that producers could not reach an FSA office—for  example, if producers were elderly or disabled—FSA would send an FSA  employee to meet them at more convenient locations. In addition, FSA  accepted written comments for up to 10 days after the date of the meeting  from those who could not attend in person.
section_title: FSA Approved Its Office Closures More Than 90 Days after Sending Notices to Congressional Committees and Members
paragraphs: FSA provided us with documentation of notifications sent to congressional  committees and members of the proposed office closures on February  27, 2012. The scope of our review did not include an assessment of  whether the notifications met the requirements of section 14212(b) of the  2008 Farm Bill. On May 29, 2012, 92 days after the date on the  congressional notifications FSA provided us, the Secretary announced  the closure of 125 FSA offices. Six offices that had been proposed for  closure were not closed because, based on concerns raised during the  public meetings, FSA recalculated the distance between these offices and  the next closest FSA offices and found the distance was more than 20  miles.
section_title: FSA Closed Offices between June 2012 and March 2013
paragraphs: FSA closed 125 offices between June 1, 2012, and March 1, 2013. FSA  officials told us that the timing of office closures was based on information  that state executive directors provided in surveys on when the offices  could notify employees, schedule physical moves, and take other  necessary actions to close. Of the 125 offices closed, 98 offices had two  or fewer permanent full-time employees and were located less than 20  miles from another FSA office. However, we found that, in two instances,  FSA used an office that was slated to be closed as the nearest office in  calculating the distance rather than an office that would remain open.  Specifically, FSA identified the Shelby County, Texas, and San Augustine  County, Texas, offices as being less than 20 miles from each other, and  then closed both. As a result, the nearest open FSA office, according to  our analysis, is in Nacogdoches County, Texas, over 30 miles from each  of these offices. FSA officials told us that these offices were closed  because both offices had one or two employees and were located less  than 20 miles from another office. The other 27 closed offices had no  permanent full-time employees and were located more than 20 miles from  another FSA office. However, the offices located less than 20 miles from  another office were not closed before the offices located more than 20  miles from another office were closed. We did not assess whether FSA  complied with section 14212(b).
section_title: Appendix IV: Comments from the Department of Agriculture
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Thomas M. Cook (Assistant  Director), Karen Jones (Assistant Director), Cheryl Arvidson, Candace  Carpenter, David Garcia, Armetha Liles, Rebecca Shea, Jeanette Soares,  and Ruth Solomon made key contributions to this report.