The National Defense Authorization Act for Fiscal Year 2004 provided DOD with authority to establish (1) a pay and performance management system, (2) an appeals process, and (3) a labor relations system—which together comprise NSPS. The legislation permits significant flexibility for designing NSPS, allowing for a new framework of rules, regulations, and processes to govern how defense civilian employees are hired, compensated, promoted, and disciplined. The law granted DOD certain exemptions from laws governing federal civilian personnel management found in Title 5 of the U.S. Code. The Congress provided these flexibilities in response to DOD’s position that the inflexibility of federal personnel systems was one of the most important constraints to the department’s ability to attract, retain, reward, and develop a civilian workforce to meet the national security mission of the 21st century. The initial proposals for NSPS were developed by DOD and were based on a 2002 compilation of best practices generated by demonstration projects that experimented with different personnel management concepts. After these proposals were sent to OPM for review, OPM identified a broad range of legal, policy, and technical concerns, and also noted that the labor- management relations proposal was developed without any prior OPM involvement or union input. OPM also indicated that the initial proposals had been crafted with only token employee involvement, and it noted a high level of concern expressed by congressional oversight committees, stakeholders, and constituent groups. In addition to OPM, assistant secretaries for the military services’ manpower organizations also expressed concerns that NSPS as designed would not work. Subsequently, the Secretary of Defense established a 3-week reassessment of system requirements, process issues, personnel and communication strategies, and program schedules and milestones. The Overarching Integrated Product Team (OIPT), an advisory group co-chaired by the Principal Deputy Under Secretary of Defense for Personnel and Readiness and OPM, and including the military services’ assistant secretaries for manpower and reserve affairs, oversaw this reassessment. NSPS labor relations provisions will be implemented across the entire department once final NSPS regulations are issued and effective, and they will apply to all DOD employees currently covered by the labor relations provisions of Title 5, U.S. Code, Chapter 71. In contrast, NSPS regulations governing the new pay and performance management system and appeals process will be phased in and will not apply to some employees, as stipulated by law (e.g., intelligence personnel and employees in DOD’s laboratory demonstration organizations). The authorizing legislation stipulates that these latter regulations may not apply to organizations with more than 300,000 employees until the Secretary of Defense determines and certifies that the department has a performance management system in place that meets the statutory criteria established for NSPS. The first phase of implementation—Spiral One—will provide the basis for this certification prior to the deployment of Spiral Two. Spiral One includes approximately 300,000 general schedule defense civilian employees, who will be converted to the new system over a period of 18 months. DOD currently plans to initiate Spiral One, beginning in early fiscal year 2006. Spiral Two will include the remainder of DOD’s eligible workforce, including wage-grade employees. Spiral Three will apply to demonstration laboratory employees no earlier than October 1, 2008, and then only to the extent the Secretary of Defense determines that NSPS provides greater personnel management flexibilities to the laboratories than those currently implemented. According to DOD, almost two-thirds of its more than 700,000 civilian employees are represented by 43 labor unions, including over 1,500 separate bargaining units. Table 1 in appendix II lists current DOD labor unions, the estimated number of employees represented by each union, and which unions belong to the United Defense Workers Coalition. According to a DOD official, since 2000, defense civilian employee membership in DOD’s labor unions has remained about the same; however, the number of unions has dropped from about 60 unions to the current 43 unions, primarily the result of mergers and consolidation among the unions. In our prior work, we identified key practices and lessons learned from major public and private sector organizational mergers, acquisitions, and transformations. This work was undertaken to help federal agencies implement successful cultural transformations in response to governance challenges. While no two mergers or transformation efforts are exactly alike and the "best" approach depends on a variety of factors specific to each context, there was general agreement on a number of key practices, which are as follows: 1. Ensure top leadership drives the transformation. Leadership must set the direction, pace, and tone and provide a clear, consistent rationale that brings everyone together behind a single mission. 2. Focus on a key set of principles and priorities at the outset of the transformation. A clear set of principles and priorities serves as a framework to help the organization create a new culture and drive employee behaviors. 3. Set implementation goals and a timeline to build momentum and show progress from day one. Goals and a timeline are essential because the transformation could take years to complete. 4. Dedicate an implementation team to manage the transformation process. A strong and stable team is important to ensure that the transformation receives the needed attention to be sustained and successful. 5. Establish a communication strategy to create shared expectations and report related progress. The strategy must reach out to employees, customers, and stakeholders and engage them in a two-way exchange. 6. Involve employees to obtain their ideas and gain their ownership for the transformation. Employee involvement strengthens the process and allows them to share their experiences and shape policies. DOD’s current process to design NSPS is divided into four stages: (1) development of options for the personnel system, (2) assessment of the options and translation into recommended proposals, (3) issuance of proposed regulations, and (4) a statutory public comment period, a meet and confer period with employee representatives, and a congressional notification period. As discussed earlier, DOD’s initial process to design NSPS was unrealistic and inappropriate. However, after a 3-week reassessment, DOD adjusted its approach and attempted to create a more cautious and deliberate process that would involve all of the key stakeholders, including OPM. At this time, DOD adopted a management framework to guide the design of NSPS based on DOD’s acquisition management model and adopted an analytical framework to identify system requirements as well as a phased approach to implementing the new system, also based on the acquisition management model. Figure 1 presents the four stages in DOD’s current process in terms of the key organizational elements, inputs, and outputs. In the first stage, the NSPS PEO convened six multidisciplinary design teams—called working groups—that were functionally aligned to cover the following personnel program areas: (1) compensation (classification and pay banding); (2) performance management; (3) hiring, assignment, pay setting, and workforce shaping; (4) employee engagement; (5) adverse action and appeals; and (6) labor relations. The working groups were co- chaired by DOD and OPM, and they were largely staffed from the defense components. The working groups reviewed and analyzed data from alternative federal personnel systems and laboratory and acquisition demonstration projects, research materials from the Department of Homeland Security’s personnel system design process, and private industry practices. According to DOD, the working groups also received input and participation from DOD human resources practitioners, attorneys, financial management experts, and equal employment opportunity specialists. The working groups also reviewed input gathered from DOD employee and employee representatives. The PEO was responsible for conducting outreach to employees and employee representatives, in conjunction with NSPS program managers in the DOD components; their efforts included 106 focus groups, more than 50 town hall meetings worldwide, and 10 meetings with DOD employee representatives. The working groups provided a broad range of options for the OIPT in September and October 2004; they did not prioritize the design options. In the second stage of the design process, OIPT assessed the design options, and then submitted them to the NSPS Senior Executive in November 2004. The Senior Executiveappointed by the Secretary of Defense to design and implement NSPS on his behalf—reviewed and approved the design options and presented them as proposed enabling regulations to submit to the Secretary of Defense and the Director of OPM for a decision. Throughout this period, the OIPT, PEO, and working group members continued to participate, both in drafting and reviewing the proposed regulations. In the third stage, the Secretary of Defense and Director of OPM reviewed the proposals submitted by the NSPS Senior Executive. After finalizing the proposed regulations, the Secretary and Director jointly released them for public comment in the Federal Register on February 14, 2005. In the fourth stage, the NSPS proposed regulations were subjected to a statutory 30-day public comment period, after which DOD held a 30-day meet and confer period (which began on April 18, 2005), with employee representatives to discuss their views; the meetings were facilitated by the Federal Mediation and Conciliation Service. As allowed by statute, DOD extended the meet and confer process. Lastly, DOD is to engage in a 30-day congressional notification period. As called for in the authorizing legislation, the proposed regulations are subject to change based on consideration of formal comments received during the 30-day public comment period and the results of a 30-day meet and confer process with employee representatives. As provided for in the authorizing legislation, DOD can immediately implement those parts of the regulations upon which they have reached agreement with employee representatives. DOD can implement those parts of the proposed regulations not agreed to only after another 30 calendar days have elapsed after (1) notifying the Congress of the decision to proceed with implementation and (2) explaining why implementation is appropriate. DOD’s NSPS design process generally reflects four of six key practices we identified that have consistently been found at the center of successful transformations. The design process generally reflects the following four practices. First, DOD and OPM have developed a process to design the new personnel system that is supported by top leadership in both organizations. Second, from the outset, a set of guiding principles have guided the NSPS design process. Third, DOD has a dedicated team in place to design and implement NSPS and manage the transformation process, to include program managers from DOD components. Fourth, DOD has established a timeline, albeit ambitious, and implementation goals for implementing its new personnel system. The design process, however, does not fully reflect two other key practices. First, DOD developed and implemented a written communication strategy document, but it is not comprehensive. Second, while the NSPS design has involved employees through town hall meetings and other mechanisms, it has not included employee representatives on the working groups that drafted the design options for the new system. DOD and OPM have developed a process to design DOD’s new human capital resources management system that is supported by top leadership in both organizations. As previously discussed, DOD’s initial process to design NSPS was unrealistic and inappropriate; however, after a strategic reassessment, DOD adjusted its approach to reflect a more cautious, deliberative process that involved top DOD and OPM leadership. In our report on key practices for successful transformations, we noted that top leadership that is clearly and personally involved in transformations provides stability and an identifiable source for employees to rally around during tumultuous times. In addition, we noted that leadership should set the direction, pace, and tone for the transformation. In our prior reports and testimonies, we observed that top leadership must play a critical role in creating and sustaining high-performing organizations. Senior leaders from DOD and OPM are directly involved in the NSPS design process. For example, the Secretary of Defense tasked the Secretary of the Navy to be the NSPS Senior Executive overseeing the implementation of NSPS. Also, the Under Secretary of Defense for Personnel and Readiness and the NSPS Senior Executive provided an open letter to all DOD civilian employees stating that DOD is tasked to design a transformation system for the department’s civilian employees that supports its national security mission while treating workers fairly and protecting their rights. In addition, the Principal Deputy Under Secretary of Defense for Personnel and Readiness, the Assistant Secretaries for Manpower and Reserve Affairs from each military service, and the OPM Senior Advisor to the Director for the Department of Defense are members of an integrated executive management teamthe OIPTthat, among other things, provides overall policy and strategic advice on the implementation of NSPS. Similarly, senior-level executives from DOD and OPM are members of a group, known as the Senior Advisory Group, that provides advice on general NSPS conceptual, strategic, and implementation issues. Finally, senior leaders from DOD and the military components participated in town hall meetings at DOD installations worldwide to discuss the concept and design elements of NSPS. Experience shows that successful major change management initiatives in large private and public sector organizations can often take at least 5 to 7 years. This length of time and the frequent turnover of political leadership in the federal government have often made it difficult to obtain the sustained and inspired attention to make needed changes. The development of the position of Deputy Secretary of Defense for Management, who would act as DOD’s Chief Management Officer, is essential to elevate, integrate, and institutionalize responsibility for the success of DOD’s overall business transformation efforts, including its new personnel management system. As DOD embarks on a large-scale change initiative, such as DOD’s new personnel management system, ensuring sustained and committed leadership is crucial in developing a vision, initiating organizational change, maintaining open communications, and creating an environment that is receptive to innovation. Without the clear and demonstrated commitment of agency top leadership, organizational cultures will not be transformed and new visions and ways of doing business will not take root. During the strategic reassessment of the NSPS design process, DOD and OPM senior leadership developed a set of guiding principles to direct efforts throughout all phases of NSPS development. We have reported that in bringing together the originating components, the new organization must have a clear set of principles and priorities that serve as a framework to help the organization create a new culture and drive employee behaviors. Principles are the core values of the new organization and can serve as an anchor that remain valid and enduring while organizations, personnel, programs, and processes may change. Focusing on these principles and priorities helps the organization maintain its drive towards achieving the goals of the new transformation. According to DOD, its guiding principles translate and communicate the broad requirements and priorities outlined in the legislation into concise, understandable requirements that underscore the department’s purpose and intent in creating NSPS. The NSPS guiding principles are put mission first—support national security goals and strategic respect the individual—protect rights guaranteed by law, value talent, performance, leadership and commitment to public service, be flexible, understandable, credible, responsive, and executable, ensure accountability at all levels, balance personnel interoperability with unique mission requirements, be competitive and cost effective. Senior DOD and OPM leadership also approved a set of key performance parameters, which define the minimum requirements or attributes of NSPS. The key performance parameters are high-performing workforce and management: employees and supervisors are compensated and retained based on performance and contribution to mission, agile and responsive workforce management: workforce can be easily sized, shaped, and deployed to meet changing mission requirements, credible and trusted: system assures openness, clarity, accountability, fiscally sound: aggregate increases in civilian payroll, at the appropriations level, will conform to Office of Management and Budget fiscal guidance, and managers will have flexibility to manage to budget, supporting infrastructure: information technology support, and training and change management plans are available and funded, and schedule: NSPS will be operational and demonstrate success prior to November 2009. These principles and key performance parameters can serve as core values for human capital management at DODvalues that define the attributes that are intrinsically important to what the organization does and how it will do it. Furthermore, they represent the institutional beliefs and boundaries that are essential to building a new culture for the organization. Finally, they appropriately identify the need to support the mission and employees of the department, protect basic civil service principles, and hold employees accountable for performance. As previously discussed, DOD established a team to design and implement NSPS and manage the transformation process. Dedicating a strong and stable design and implementation team that will be responsible for the transformation’s day-to-day management is important to ensuring that it receives the focused, full-time attention needed to be sustained and successful. Specifically, the design and implementation team is important to ensuring that various change initiatives are sequenced and implemented in a coherent and integrated way. Because a transformation process is a massive undertaking, the implementation team must have a “cadre of champions” to ensure that changes are thoroughly implemented and sustained over time. Establishing networks can help the design and implementation team conduct the day-to-day activities of the merger or transformation and help ensure that efforts are coordinated and integrated. To be most effective, establishing clearly defined roles and responsibilities within this network assigns accountability for parts of the implementation process, helps reach agreement on work priorities, and builds a code of conduct that will help all teams to work effectively. The Secretary of Defense appointed a NSPS Senior Executive to, among other things, design, develop, and establish NSPS. Under the Senior Executive’s authority, the PEO was established as the central policy and program office to conduct the design, planning and development, deployment, assessment, and full implementation of NSPS. Specifically, its responsibilities include designing the labor relations, appeals, and human resource/pay for performance systems; developing a communication strategy and training strategy; modifying personnel information technology; and drafting joint enabling regulations and internal DOD implementing regulations. As the central DOD-wide program office, the PEO provides direction and oversight of the components’ NSPS program managers who are dual-hatted under their parent component and the NSPS PEO. These program managers also serve as their components’ action officers and participate in the development of NSPS and plan and implement the deployment of NSPS. Figure 2 shows the organization of the NSPS design and implementation team. DOD established an ambitious 18-month timeline and implementation goals for completing the design process and beginning the phased implementation of NSPS. We have reported that successful practices of mergers and transformations have noted that the establishment of a timeline with specific milestones allows stakeholders to track the organization’s progress towards its goals. Figure 3 shows the current timeline and implementation goals for designing and implementing NSPS. Although DOD established a clear timeline with specific implementation goals, they have allotted about 6 months for completing the design process and beginning implementation of NSPS (as shown in the shaded area of figure 3). Specifically, the authorizing legislation provides for a meet and confer process for not less than 30 calendar days with the employee representatives in order to attempt to reach agreement. However, as allowed by statute, DOD extended the 30-day meet and confer period with employee representatives. After the meet and confer process is concluded, the Secretary of Defense must notify the Congress of DOD’s intent to implement any portions of the proposal where agreement has not been reached, but only after 30 calendar days have elapsed after notifying the Congress of the decision to implement those provisions. In addition, DOD and OPM must jointly develop and issue the final NSPS regulations, which must go through an interagency coordination process before they are published in the Federal Register. Also, DOD must develop and conduct in- depth and varied training for its civilian employees, military and civilian supervisors, and managers. Moreover, DOD must modify its existing automated human resource information systems, including personnel and payroll transaction process systems departmentwide, before NSPS can become operational. Finally, DOD plans to roll out the NSPS labor relations system and establish the National Security Labor Relations Board before the initial roll out of the NSPS performance management system in early fiscal year 2006. The board must be staffed with both board members as well as about 100 professional staff, which will support the board. A large-scale organizational change initiative, such as DOD’s new personnel management system, is a substantial commitment that will take years before it is completed, and therefore must be carefully and closely managed. As a result, it is essential to establish and track implementation goals and establish a timeline to pinpoint performance shortfalls and gaps and suggest midcourse corrections. While it is appropriate to develop and integrate personnel management systems within the department in a quick and seamless manner, moving too quickly or prematurely can significantly raise the risk of doing it wrong. Having an ambitious timeline is reasonable only insofar as it does not impact the quality of the human capital management system that is created. In recent hearings on the NSPS proposed regulations, we testified that DOD’s new personnel management system will have far-reaching implications for the management of the department and for civil service reform across the federal government. We further testified that NSPS could, if designed and implemented properly, serve as a model for governmentwide transformation. However, if not properly designed and implemented, NSPS could impede progress toward a more performance- and results-based system for the federal government as a whole. DOD developed and implemented a written communication strategy document that provides a structured and planned approach to communicate timely and consistent information about NSPS, but this strategy is not comprehensive. It does not contain some elements that we have identified as important to successful communication during transformations. As a result, the written communication strategy document may not facilitate two-way communication between employees, employee representatives, and management, which is central to forming effective partnerships that are vital to the success of any organization. Specifically, the strategy does not identify all key internal stakeholders and their concerns. For example, the strategy acknowledges that employee representatives play an important role in the design and implementation of NSPS, but it does not identify them as a key stakeholder. Instead, DOD’s written communication strategy document characterizes union leadership as a “detractor,” in part due to their criticism of NSPS. Consequently, DOD identified the following four objectives as its most urgent communications priorities, which are to (1) demonstrate the rationale for and the benefits of NSPS, (2) express DOD’s commitment to ensuring that NSPS is applied fairly and equitably throughout the organization, (3) demonstrate openness and transparency in the design and process of converting to NSPS, and (4) mitigate and counter any potential criticism of NSPS from such detractors as unions and their support groups. Experience shows that failure to adequately consider a wide variety of people and cultural issues can lead to unsuccessful transformations. Furthermore, although the written communication strategy document identified key messages for those internal and external stakeholders that are identified, it does not tailor these messages to specific stakeholder groups. For example, the strategy does not tailor key messages to such groups of employees as human resource personnel, DOD executives and flag officers, supervisors, and managers, even though these employees may have divergent interests and information needs. Tailoring information helps employees to feel that their concerns are specifically addressed. We have reported that organizations undergoing a transformation should develop a comprehensive communications strategy that reaches out to employees, customers, and stakeholders and seeks to genuinely engage them in the transformation process and facilitate a two-way honest exchange with and allow for feedback from employees, customers, and stakeholders. While the design process has involved employees through many mechanisms, including focus groups, town hall meetings, a NSPS Web site for employee comments, and meetings with employee representatives, it has not included employee representatives on the working groups that drafted the design options. The composition of the team is important because it helps employees see that they are being represented and that their views are being considered in the decision-making process. A successful transformation must provide for meaningful involvement by employees and their representatives to, among other things, gain their input into and understanding of the changes that are occurring in the organization. Employee involvement strengthens the transformation process by including frontline perspectives and experiences. Further, employee involvement helps increase employee’s understanding and acceptance of organizational goals and objectives, and gain ownership for new policies and procedures. Involving employees in planning helps to develop agency goals and objectives that incorporate insights about operations from a front-line perspective. It can also serve to increase employees’ understanding and acceptance of organizational goals and improve motivation and morale. The PEO sponsored a number of focus group sessions and town hall meetings at various sites across DOD and around the world to provide employees and managers an opportunity to participate in the development of NSPS. During a 3-week period beginning in July 2004, over 100 focus groups were held throughout DOD, including overseas locations. The purpose of the focus groups was to elicit perceptions and concerns about current personnel policies and practices as well as new ideas from the DOD workforce to inform the NSPS design process. Separate focus groups were held for employees, civilian and military supervisors, and managers and practitioners from the personnel, legal, and equal employment opportunity communities. According to DOD officials, bargaining unit employees and employee representatives were invited to participate. DOD officials stated that over 10,000 comments, ideas, and suggestions were received during the focus group sessions and were summarized and provided to NSPS working groups for use in developing options for the labor relations, appeals, adverse actions, and personnel design elements of NSPS. In addition, town hall meetings were held and, according to DOD, are still being conducted at DOD facilities around the world. According to DOD officials, these town hall meetings have provided an opportunity to communicate with the workforce, provide the status of the design and development of NSPS, and solicit thoughts and ideas. The format for town hall meetings included an introductory presentation by a senior leader followed by a question and answer session where any employee in the audience was free to ask a question or make a comment. To facilitate the widest possible dissemination, some of the town hall meetings were broadcast live, as well as videotaped and rebroadcast on military television channels and Web sites. DOD’s NSPS Web site was available for DOD employees as well as interested parties to view and comment on the proposed regulations as well as for the most recent information and announcements regarding NSPS. After the proposed NSPS regulations were published in the Federal Register, there was a 30-day public comment period, providing all interested parties the opportunity to submit comments and recommendations on the content of the proposal. The proposed regulations were published on February 14, 2005, and the 30-day comment period ended on March 16, 2005. During this time period, according to DOD, it received more than 58,000 comments. Prior to the publication of the proposed NSPS regulations, DOD and OPM conducted 10 joint meetings with officials of DOD’s 43 labor unions to discuss NSPS design elements. According to DOD officials, these meetings involved as many as 80 union leaders at any one time, addressed a variety of topics, including (1) the reasons change is needed and the department’s interests; (2) the results of departmentwide focus group sessions held with a broad cross-section of DOD employees; (3) the proposed NSPS implementation schedule; (4) employee communications; and (5) proposed design options in the areas of labor relations and collective bargaining, adverse actions and appeals, and pay and performance management. According to DOD officials, these meetings provided the opportunity to discuss the design elements, proposals under consideration for NSPS, and solicit employee representative feedback. According to DOD, the focus group sessions and town hall meetings, as well as the working groups and union meetings, assured that DOD employees, managers, supervisors, employee representatives, and other stakeholders were involved in and given ample opportunity to provide input into the design and implementation of NSPS. Opportunities for employee involvement were limited between the conclusion of the town hall meetings and focus groups in July 2004 and the publishing of the proposed NSPS regulations in February 2005; the primary means for employees to provide feedback during this time was through the NSPS Web site. As DOD implements its new personnel management system, it will face multiple implementation challenges in both the early and later stages of implementation. At recent hearings on the proposed NSPS regulations, we highlighted multiple challenges: (1) establishing an overall communications strategy, (2) providing adequate resources for the new system, (3) involving employees and other stakeholders in implementing the system, (4) ensuring sustained and committed leadership, and (5) evaluating the new personnel management system after it has been implemented. Establishing an overall communications strategy. A significant challenge for DOD is to ensure an effective and ongoing two-way communications strategy, given its size, geographically and culturally diverse audiences, and different command structures across DOD organizations. We have reported that a communications strategy that creates shared expectations about, and reports related progress on, the implementation of the new system is a key practice of a change management initiative. The communications strategy must include the active and visible involvement of a number of key players, including the Secretary of Defense, and a variety of communication means and mediums for successful implementation of the system. DOD acknowledges that a comprehensive outreach and communications strategy is essential for designing and implementing its new personnel management system, but the proposed regulations do not identify a process for continuing involvement of employees in the planning, development, and implementation of NSPS. Providing adequate resources for implementing the new system. Experience has shown that additional resources are necessary to ensure sufficient planning, implementation, training, and evaluation for human capital reform. According to DOD, the implementation of NSPS will result in costs for, among other things, developing and delivering training, modifying automated personnel information systems, and starting up and sustaining the National Security Labor Relations Board. Major cost drivers in implementing pay-for-performance systems are the direct costs associated with salaries and training. DOD estimates that the overall cost associated with implementing NSPS will be approximately $158 million through fiscal year 2008. However, it has not completed an implementation plan for NSPS, including an information technology plan and a training plan; thus, the full extent of the resources needed to implement NSPS may not be well understood at this time. Involving employees and other stakeholders in implementing the system. DOD faces a significant challenge in involvingand continuing to involveits employees, employee representatives, and other stakeholders in implementing NSPS. DOD’s proposed NSPS regulations, while providing for continuing collaboration with employee representatives, do not identify a process for the continuing involvement of employees and other stakeholders in the planning, development, and implementation of NSPS. The active involvement of all stakeholders will be critical to the success of NSPS. The involvement of employees and their representatives both directly and indirectly is crucial to the success of new initiatives, including implementing a pay- for-performance system. High-performing organizations have found that actively involving employees and stakeholders, such as unions or other employee associations, when developing results-oriented performance management systems helps improve employees’ confidence and belief in the fairness of the system and increases their understanding and ownership of organizational goals and objectives. This involvement must be early, active, and continuing if employees are to gain a sense of understanding and ownership of the changes that are being made. Ensuring sustained and committed leadership. As DOD implements this massive human capital reform, its challenge will be to elevate, integrate, and institutionalize leadership responsibility for NSPS to ensure its success. DOD may face a future leadership challenge when the NSPS Senior Executive and the PEO transition out of existence once NSPS is fully implemented. According to a PEO official, at that time, ongoing implementation responsibility for NSPS would come under the Civilian Personnel Management Service, which is part of the Office of the Under Secretary of Defense for Personnel and Readiness. In recent testimony on the transformation of DOD business operations, we stated that as DOD embarks on large-scale business transformation efforts, such as NSPS, the complexity and long-term nature of these efforts requires the development of an executive position capable of providing strong and sustained change management leadership across the department—and over a number of years and various administrations. One way to ensure such leadership would be to create by legislation a full-time executive-level II position for a chief management official, who would serve as the Deputy Secretary of Defense for Management. This position would elevate, integrate, and institutionalize the high-level attention essential for ensuring that a strategic business transformation plan—as well as the business policies, procedures, systems, and processes that are necessary for successfully implementing and sustaining overall business transformation efforts, like NSPS, within DOD—are implemented and sustained. In previous testimony on DOD’s business transformation efforts, we identified the lack of clear and sustained leadership for overall business transformations as one of the underlying causes that has impeded prior DOD reform efforts. Evaluating the new personnel management system. Evaluating the impact of NSPS will be an ongoing challenge for DOD. This is especially important because NSPS would give managers more authority and responsibility for managing the new personnel system. High-performing organizations continually review and revise their human capital management systems based on data-driven lessons learned and changing needs in the work environment. Collecting and analyzing data will be the fundamental building block for measuring the effectiveness of these approaches in support of the mission and goals of the department. According to DOD, the department is planning to establish procedures to evaluate the implementation of its new personnel management system. During testimony on the proposed NSPS regulations, we stated that DOD should consider conducting evaluations that are broadly modeled on demonstration projects. Under the demonstration project authority, agencies must evaluate and periodically report on results, implementation of the demonstration project, costs and benefits, impacts on veterans and other equal employment opportunity groups, adherence to merit system principles, and the extent to which the lessons learned from the project can be applied governmentwide. We further testified that a set of balanced measures addressing a range of results, and customer, employee, and external partner issues may also prove beneficial. An evaluation such as this would facilitate congressional oversight; allow for any midcourse corrections; assist DOD in benchmarking its progress with other efforts; and provide for documenting best practices and lessons learned with employees, stakeholders, other federal agencies, and the public. DOD’s efforts to design and implement a new personnel management system represent a huge undertaking. However, if not properly designed and implemented, the new system could severely impede DOD’s progress toward a more performance- and results-based system that it is striving to achieve. Although DOD’s process to design its new personnel management system represents a phased, deliberative process, it does not fully reflect some key practices of successful transformations. Because DOD has not fully addressed all of these practices, it does not have a comprehensive written communication strategy document that effectively addresses employee concerns and their information needs, and facilitates two-way communication between employees, employee representatives, and management. Without a comprehensive written communication strategy document, DOD may be hampered in achieving employee buy-in, which could lead to an unsuccessful implementation of the system. In addition, evaluating the impact of NSPS will be an ongoing challenge for DOD. Although DOD has plans to establish procedures to evaluate NSPS, it is critical that these procedures be adequate to fully measure the effectiveness of the program. Specifically, adequately designed evaluation procedures include results-oriented performance measures and reporting requirements that facilitate DOD’s ability to effectively evaluate and report on NSPS’s results. Without procedures that include outcome measures and reporting requirements, DOD will lack the visibility and oversight needed to benchmark progress, make system improvements, and provide the Congress with the assessments needed to determine whether NSPS is truly the model for governmentwide transformation in human capital management. To improve the comprehensiveness of the NSPS communication strategy, we recommend that the Secretary of Defense direct the NSPS Senior Executive and NSPS Program Executive Office to take the following two actions: Identify all internal stakeholders and their concerns. Tailor and customize key messages to be delivered to groups of employees to meet their divergent interests and information needs. To evaluate the impact of DOD’s new personnel management system, we recommend that the Secretary of Defense direct the NSPS Senior Executive and NSPS Program Executive Office to take the following action: Develop procedures for evaluating NSPS that contain results-oriented performance measures and reporting requirements. These evaluation procedures could be broadly modeled on the evaluation requirements of the OPM demonstration projects. DOD provided written comments on a draft of this report. The department did not concur with our recommendation to identify all key internal stakeholders and their concerns. The department partially concurred with our recommendation to tailor and customize key messages to be delivered to groups of employees to meet their divergent interests and information needs. Also, the department partially concurred with our recommendation to develop procedures for evaluating NSPS that contain results-oriented performance measures and reporting requirements. DOD did not concur with our recommendation that the department identify all key internal stakeholders and their concerns. The department stated that, among other things, it adopted a broad-based, event-driven approach to the design and implementation of NSPS that included a multifaceted communications outreach strategy to inform and involve key stakeholders, and that it took great care to ensure that materials and messages addressed stakeholders’ concerns, both known and anticipated. However, our review of DOD’s written communication strategy document showed that not all key internal stakeholders and their concerns were identified. For example, the written communication strategy document does not identify employee representatives as a key stakeholder but, instead, characterizes union leadership as “NSPS’ biggest detractor.” Since the development and implementation of the written communication strategy document, DOD notes that specific plans were developed to identify key internal and external stakeholders and provided key messages and communications products to inform those groups. DOD provided us with these plans after we provided the department with our draft report for comment. Our review of these plans shows that they are not comprehensive. For example, the plans for the most part do not identify employee representatives as a key stakeholder or identify their concerns. Consequently, we continue to believe that our recommendation has merit and should be implemented. DOD partially concurred with our recommendation that the department tailor and customize key messages to be delivered to groups of employees to meet their divergent interest and information needs. The department stated that it believes that it has been successful so far in developing, customizing, and delivering key messages to employees and provided us with several examples to illustrate its efforts. Although DOD’s written communication strategy document contained key messages for some employee groups, the messages were general in content and not tailored to specific employee groups. DOD acknowledges that each stakeholder group has a unique focus and recently released NSPS brochures tailored to such groups of employees as human resource personnel, senior leaders, supervisors and managers, and employees. DOD provided us with these brochures after we provided the department with our draft report for comment. Our review of these brochures shows that they do in fact tailor and customize key messages for some, but not all, employee groups. Furthermore, we believe that DOD’s written communication strategy document should serve as the single, comprehensive source of DOD’s key messages, which are tailored to and customized for groups of employees. Consequently, we continue to believe that this recommendation has merit and should be implemented. DOD partially concurred with our recommendation to develop procedures for evaluating NSPS that contain results-oriented performance measures and reporting requirements that could be broadly modeled on the evaluation requirements of the OPM demonstration projects. The department stated that it has begun developing an evaluation plan and will ensure that the plan contains results-oriented performance measures and reporting mechanisms. If the department follows through with this effort, we believe that it will be responsive to our recommendation. DOD’s comments are reprinted in appendix III. DOD also provided technical comments, which we have incorporated in the final report where appropriate. We are sending copies of this report to the Chairman and Ranking Member, Senate Committee on Armed Services; the Chairman and Ranking Member, Senate Committee on Homeland Security and Governmental Affairs; the Chairman and Ranking Member, Subcommittee on Oversight of Government Management, the Federal Workforce, and the District of Columbia, Senate Committee on Homeland Security and Governmental Affairs; the Chairman and Ranking Member, House Committee on Armed Services; the Chairman and Ranking Member, Subcommittee on the Federal Workforce and Agency Organization, House Committee on Government Reform; and other interested congressional parties. We also are sending copies to the Secretary of Defense and Director of the Office of Personnel Management. We will make copies available to other interested parties upon request. This report also will be made available at no charge on GAO’s Web site at http://www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512-5559 or by e-mail at stewartd@gao.gov. For further information on governmentwide human capital issues, please contact Eileen R. Larence, Director, Strategic Issues, at (202) 512-6512 or larencee@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of the report. GAO staff who made major contributions to this report are listed in appendix IV. In conducting our review of the Department of Defense’s (DOD) National Security Personnel System (NSPS), we met with officials in key offices within DOD and the Office of Personnel Management (OPM) that have responsibility for designing and implementing DOD’s new performance management system. We also met with DOD employee representatives, whose members are affected by the transformation. We conducted our work in Washington, D.C., at DOD, including the NSPS Program Executive Office (PEO) and NSPS Program Management Offices in the Army, the Navy, the Marine Corps, the Air Force, and Washington Headquarters Service. We also met with members of the NSPS Overarching Integrated Product Team (OIPT) and Senior Advisory Group. At OPM, we met with the Senior Advisor to the Director for the Department of Defense and Senior Policy Advisor and Chief Human Capital Officer in the Office of the Director. We also met with key officials in OPM’s Office of Congressional Relations, Division for Strategic Human Resources Policy, Homeland Security and Intelligence Group in the Division for Human Capital Leadership and Merit System Accountability, and the Office of the Chief Financial Officer. In addition, we met with the OPM co-chairs of each of the DOD working groups that designed NSPS. We met with representatives from the United Defense Workers Coalition, which represents 36 DOD employee unions, as well as employee representatives for the Fraternal Order of Police and National Association of Independent Labor, which are not members of the Coalition. We contacted the other non-Coalition unions, but their representatives told us that they had not been actively involved in the NSPS design process and, therefore, declined our offer to meet with them. Finally, we met in Washington, D.C., with key officials in other federal agencies that are statutorily involved in the NSPS design process: Federal Labor Relations Authority, Federal Mediation and Conciliation Service, and U.S. Merit Systems Protection Board. To describe DOD’s design process, we examined the authorizing legislation and other applicable laws and regulations and collected and analyzed documentary and testimonial information from key sources. We met with the Director and Deputy Director of the NSPS PEO and the DOD and OPM co-chairs of all six working groups; members of the OIPT, including the OPM co-chair, and Senior Advisory Group; DOD employee representatives; and experts in federal labor relations and federal adverse actions and personnel appeals systems. We also examined NSPS policy guidance, directives, draft regulations, instructions, manuals, and memorandums related to the design process and NSPS charters outlining the roles and responsibilities of the OIPT and PEO. To evaluate the extent to which DOD’s process reflects elements of successful transformations, we reviewed prior GAO reports, testimonies, and forums on mergers and organizational transformations to identify assessment criteria, and we applied those criteria to the descriptive information collected for the first objective. Although there are a total of nine key practices of successful transformations, our evaluation focused on six key practices: (1) ensure top leadership drives the transformation, (2) focus on a key set of principles and priorities at the outset of the transformation, (3) set implementation goals and a timeline to build momentum and show progress from day one, (4) dedicate an implementation team to manage the transformation process, (5) establish a communication strategy to create shared expectations and report related progress, and (6) involve employees to obtain their ideas and gain their ownership for the transformation. We did not evaluate the key practice “establishes a coherent mission and integrated strategic goals to guide the transformation” because we have previously reported on the department’s strategic planning efforts for civilian personnel and assessed whether DOD and selected defense components’ goals and objectives contained in strategic plans for civilian personnel were aligned with overarching missions of the organizations. We did not apply two other key practices, “uses a performance management system to define responsibility and assure accountability for change” and “builds a world-class organization” because it would be premature to apply them to the NSPS design process given that DOD has considerable work ahead to design and implement NSPS and assess the overall system. To identify the most significant challenges DOD faced in developing NSPS, we interviewed officials from DOD, OPM, and other federal agencies as well as representatives from DOD unions. We also examined related documentation, previously identified, and reviewed prior GAO reports, testimonies, and observations related to these challenges. Data on DOD labor unions and the number of employees associated with each union were compiled by DOD from three sources: (1) the OPM book, entitled Union Recognition in the Federal Government, (2) data from the Defense Civilian Personnel Data System, and (3) a DOD survey of the military departments and defense agencies. The data are current as of June 2005. To assess the reliability of these data, we interviewed the DOD official responsible for compiling the data and performed some basic reasonableness checks of the data against other sources of information (e.g., previous DOD reports that identified DOD labor unions in past years and information directly from unions). However, we were unable to determine the reliability of the precise numbers of employees represented by each union. Because of this, and since some of the data are not current, these data are only sufficiently reliable for use as estimates rather than precise numbers of union employees. We use these data in appendix II to identify current DOD labor unions, an estimate of the number of employees represented by each union, and which unions belong to the United Defense Workers Coalition. We conducted our review from October 2004 through June 2005 in accordance with generally accepted government auditing standards. We include a comprehensive list of related GAO products on DOD’s civilian personnel management at the end of this report. Table 1 lists current DOD labor unions, the estimated number of employees represented by each union, and which unions belong to the United Defense Workers Coalition. In addition to the contact named above, Sandra F. Bell, Renee S. Brown, Rebecca L. Galek, Barbara L. Joyce, Julia C. Matta, Mark A. Pross, William J. Rigazio, John S. Townes, and Susan K. Woodward made key contributions to this report. Questions for the Record Related to the Department of Defense’s National Security Personnel System. GAO-05-771R. Washington, D.C.: June 14, 2005. Questions for the Record Regarding the Department of Defense’s National Security Personnel System. GAO-05-770R. Washington, D.C.: May 31, 2005. Post-hearing Questions Related to the Department of Defense’s National Security Personnel System. GAO-05-641R. Washington, D.C.: April 29, 2005. Defense Management: Key Elements Needed to Successfully Transform DOD Business Operations. GAO-05-629T. Washington, D.C.: April 28, 2005. Human Capital: Preliminary Observations on Proposed Regulations for DOD’s National Security Personnel System. GAO-05-559T. Washington, D.C.: April 14, 2005. Human Capital: Preliminary Observations on Proposed Department of Defense National Security Personnel System Regulations. GAO-05-517T. Washington, D.C.: April 12, 2005. Human Capital: Preliminary Observations on Proposed DOD National Security Personnel System Regulations. GAO-05-432T. Washington, D.C.: March 15, 2005. Department of Defense: Further Actions Are Needed to Effectively Address Business Management Problems and Overcome Key Business Transformation Challenges. GAO-05-140T. Washington, D.C.: November 18, 2004. DOD Civilian Personnel: Comprehensive Strategic Workforce Plans Needed. GAO-04-753. Washington, D.C.: June 30, 2004. Results-Oriented Cultures: Implementation Steps to Assist Mergers and Organizational Transformations. GAO-03-669. Washington, D.C.: July 2, 2003. Human Capital: Building on DOD’s Reform Efforts to Foster Governmentwide Improvements. GAO-03-851T. Washington, D.C.: June 4, 2003. Human Capital: DOD’s Civilian Personnel Strategic Management and the Proposed National Security Personnel System. GAO-03-493T. Washington, D.C.: May 12, 2003. Defense Transformation: DOD’s Proposed Civilian Personnel System and Governmentwide Human Capital Reform. GAO-03-741T. Washington, D.C.: May 1, 2003. Defense Transformation: Preliminary Observations on DOD’s Proposed Civilian Personnel Reforms. GAO-03-717T. Washington, D.C.: April 29, 2003. DOD Personnel: DOD Actions Needed to Strengthen Civilian Human Capital Strategic Planning and Integration with Military Personnel and Sourcing Decisions. GAO-03-475. Washington, D.C.: March 28, 2003.

Summary: The Department of Defense's (DOD) new personnel system--the National Security Personnel System (NSPS)--will have far-reaching implications not just for DOD, but for civil service reform across the federal government. The National Defense Authorization Act for Fiscal Year 2004 gave DOD significant authorities to redesign the rules, regulations, and processes that govern the way that more than 700,000 defense civilian employees are hired, compensated, promoted, and disciplined. In addition, NSPS could serve as a model for governmentwide transformation in human capital management. However, if not properly designed and effectively implemented, it could severely impede progress toward a more performance- and results-based system for the federal government as a whole. This report (1) describes DOD's process to design its new personnel management system, (2) analyzes the extent to which DOD's process reflects key practices for successful transformations, and (3) identifies the most significant challenges DOD faces in implementing NSPS. DOD's current process to design its new personnel management system consists of four stages: (1) development of design options, (2) assessment of design options, (3) issuance of proposed regulations, and (4) a statutory public comment period, a meet and confer period with employee representatives, and a congressional notification period. DOD's initial design process was unrealistic and inappropriate. However, after a strategic reassessment, DOD adjusted its approach to reflect a more cautious and deliberative process that involved more stakeholders. DOD's NSPS design process generally reflects four of six selected key practices for successful organizational transformations. First, DOD and OPM have developed a process to design the new personnel system that is supported by top leadership in both organizations. Second, from the outset, a set of guiding principles and key performance parameters have guided the NSPS design process. Third, DOD has a dedicated team in place to design and implement NSPS and manage the transformation process. Fourth, DOD has established a timeline, albeit ambitious, and implementation goals. The design process, however, is lacking in two other practices. First, DOD developed and implemented a written communication strategy document, but the strategy is not comprehensive. It does not identify all key internal stakeholders and their concerns, and does not tailor key messages to specific stakeholder groups. Failure to adequately consider a wide variety of people and cultural issues can lead to unsuccessful transformations. Second, while the process has involved employees through town hall meetings and other mechanisms, it has not included employee representatives on the working groups that drafted the design options. It should be noted that 10 federal labor unions have filed suit alleging that DOD failed to abide by the statutory requirements to include employee representatives in the development of DOD's new labor relations system authorized as part of NSPS. A successful transformation must provide for meaningful involvement by employees and their representatives to gain their input into and understanding of the changes that will occur. DOD will face multiple implementation challenges. For example, in addition to the challenges of continuing to involve employees and other stakeholders and providing adequate resources to implement the system, DOD faces the challenges of ensuring an effective, ongoing two-way communication strategy and evaluating the new system. In recent testimony, GAO stated that DOD's communication strategy must include the active and visible involvement of a number of key players, including the Secretary of Defense, for successful implementation of the system. Moreover, DOD must ensure sustained and committed leadership after the system is fully implemented and the NSPS Senior Executive and the Program Executive Office transition out of existence. To provide sustained leadership attention to a range of business transformation initiatives, like NSPS, GAO recently recommended the creation of a chief management official at DOD.