[Senate Hearing 117-521]
[From the U.S. Government Publishing Office]



 


                                                        S. Hrg. 117-521
 
    EXAMINING THE SENATE CONFIRMATION PROCESS AND FEDERAL VACANCIES

=======================================================================

                                HEARING

                               before the

                              COMMITTEE ON
               HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS
                          UNITED STATES SENATE

                    ONE HUNDRED SEVENTEENTH CONGRESS


                             SECOND SESSION

                               __________

                             MARCH 3, 2022

                               __________

        Available via the World Wide Web: http://www.govinfo.gov

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             U.S. GOVERNMENT PUBLISHING OFFICE 
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        COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS

                   GARY C. PETERS, Michigan, Chairman
THOMAS R. CARPER, Delaware           ROB PORTMAN, Ohio
MAGGIE HASSAN, New Hampshire         RON JOHNSON, Wisconsin
KYRSTEN SINEMA, Arizona              RAND PAUL, Kentucky
JACKY ROSEN, Nevada                  JAMES LANKFORD, Oklahoma
ALEX PADILLA, California             MITT ROMNEY, Utah
JON OSSOFF, Georgia                  RICK SCOTT, Florida
                                     JOSH HAWLEY, Missouri

                   David M. Weinberg, Staff Director
                    Zachary I. Schram, Chief Counsel
         Matthew T. Cornelius, Senior Professional Staff Member
               Emily I. Manna, Professional Staff Member
                  Jaqlyn Alderete, Research Assistant
                Pamela Thiessen, Minority Staff Director
       Amanda H. Neely, Minority Director of Governmental Affairs
                    Allen L. Huang, Minority Counsel
                     Laura W. Kilbride, Chief Clerk
                     Thomas J. Spino, Hearing Clerk

                            C O N T E N T S

                                 ------                                
Opening statements:
                                                                   Page
    Senator Peters...............................................     1
    Senator Portman..............................................     2
    Senator Rosen................................................    16
    Senator Lankford.............................................    21
    Senator Carper...............................................    24
    Senator Hawley...............................................    27
Prepared statements:
    Senator Peters...............................................    31
    Senator Portman..............................................    33

                               WITNESSES
                        Thursday, March 3, 2022

Anne Joseph O'Connell, Ph.D., Adelbert H. Sweet Professor of Law, 
  Stanford Law School............................................     5
Kristine Simmons, Vice President of Government Affairs, 
  Partnership for Public Service.................................     7
Adam White, Co-Executive Director, C. Boyden Gray Center for the 
  Study of the Administrative State, George Mason University, and 
  Senior Fellow, American Enterprise Institute...................     9

                     Alphabetical List of Witnesses

Joseph O'Connell, Anne Ph.D.:
    Testimony....................................................     5
    Prepared statement...........................................    37
Simmons, Kristine:
    Testimony....................................................     7
    Prepared statement...........................................    57
White, Adam:
    Testimony....................................................     9
    Prepared statement...........................................    69

                                APPENDIX

Thomas A. Berry, Research Fellow, Robert A. Levy Center for 
  Constitutional Studies, CATO Institute Statement for the Record    83
Responses to post-hearing questions for the Record:
    Ms. O'Connell................................................    89
    Ms. Simmons..................................................   106
    Mr. White....................................................   111


    EXAMINING THE SENATE CONFIRMATION PROCESS AND FEDERAL VACANCIES

                              ----------                              


                        THURSDAY, MARCH 3, 2022

                                     U.S. Senate,  
                           Committee on Homeland Security  
                                  and Governmental Affairs,
                                                    Washington, DC.
    The Committee met, pursuant to notice, at 10:29 a.m., via 
Webex and in room 342, Dirksen Senate Office Building, Hon. 
Gary C. Peters, Chairman of the Committee, presiding.
    Present: Senators Peters, Carper, Hassan, Sinema, Rosen, 
Ossoff, Portman, Johnson, Lankford, Scott, and Hawley.

            OPENING STATEMENT OF CHAIRMAN PETERS\1\

    Chairman Peters. The Committee will come to order.
---------------------------------------------------------------------------
    \1\ The prepared statement of Senator Peters appears in the 
Appendix on page 31.
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    Sorry for the tardy start. I had some votes in Commerce 
Committee and came over as fast as I could. But I certainly 
would like to thank our witnesses for joining us today to help 
examine the Senate confirmation process for our Presidential 
appointees and evaluate potential reforms that could help 
streamline the process and address vacancies and extended 
confirmation delays to strengthen leadership at our Federal 
agencies.
    Every administration deserves to choose qualified leaders 
to helm critical agencies and to help effectively govern our 
Nation. Providing a swift confirmation process, without 
excessive bureaucratic roadblocks, for these nominees is key to 
not only exercising the Senate's responsibility to advise and 
to consent but also ensuring Presidential appointees will be 
accountable to Congress and to the American people.
    In recent administrations, we have seen firsthand how 
vacancies at top Federal positions, in many cases caused by a 
prolonged confirmation process, have compounded significant 
challenges the Federal Government must tackle. For example, 
there are currently more than 180 Biden administration nominees 
being considered by this body. Many of these very qualified 
individuals could be helping to address the problems that 
Americans face, from the Coronavirus Disease 2019 (COVID-19) 
pandemic to significant threats to our national security. 
Instead, they are still waiting on this body to act before they 
can start their important work.
    The Constitution grants the Senate with an essential check 
on executive power, the authority to provide advice and consent 
on many Presidential appointments, but the number of 
appointments and the increasingly arduous process to nominate 
and to confirm appointees has become burdensome and far, far 
beyond what the framers envisioned. Recent reports estimate 
that the Senate has taken an average of 103 days to confirm 
President Biden's nominees. The average confirmation process 
took about twice as long for the two previous administrations. 
Not only do these extended timelines delay getting qualified 
leaders into vital positions, but protracted vacancies also 
limit Congress's ability to conduct effective oversight.
    Today's hearing is an important opportunity for this 
Committee to discuss potential reforms that will help address 
these concerns. This is not the first time the Senate has 
considered this issue. Ten years ago, the Committee helped pass 
into law the bipartisan Presidential Appointment Efficiency and 
Streamlining Act of 2011, which reduces the number of positions 
requiring Senate confirmation and established working groups 
that provided additional recommendations on how to make the 
Presidential appointment process more efficient, including by 
streamlining the paperwork and the background check process for 
nominees.
    While this bipartisan bill was an important step forward 
since it was signed into law, even more Senate confirmed 
positions have been created, and many recommendations from the 
working group have not yet been implemented. This has 
contributed to an increasingly complex confirmation process for 
nominees that can eat into valuable time the Senate could be 
voting to important legislation efforts and limiting an 
administration's capacity to implement a policy agenda.
    In addition to improving the government's efficiency and 
effectiveness, Federal vacancy experts and good government 
groups have argued that additional reforms, including reducing 
the number of Senate-confirmed positions, can also save 
taxpayer dollars. The Congressional Budget Office (CBO) 
estimated those savings could be as much as $82 million.
    Today, I am pleased to welcome a group of experts who can 
provide unique perspectives on how we can reform the 
Presidential appointment process, address the growing number of 
Federal vacancies, and incentivize every administration to 
quickly submit nominees. I am hopeful that on a nonpartisan 
basis we can examine the facts and ensure that our Federal 
Government is able to better serve the American people for 
generations to come.
    Now I will turn over to Ranking Member Portman for his 
opening comments.

            OPENING STATEMENT OF SENATOR PORTMAN\1\

    Senator Portman. Thank you, Mr. Chairman. I am glad we are 
having this hearing. We have had a chance to visit with the 
witnesses before us today, and we look forward to having others 
virtually.
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    \1\ The prepared statement of Senator Portman appears in the 
Appendix on page 33.
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    We spend a lot of time on vetting executive nominees, and 
it is an important part of our constitutional duty, so we 
should. This Committee in particular sees a lot of nominees. 
The process can be long and difficult. I understand that. I 
went through two confirmations myself. But there is a reason 
for that. We want to make sure the nominees are well qualified 
and well qualified to serve the American people.
    In the past year, we have seen a number of troubling issues 
with nominees, and let me give you a few examples. The 
Comptroller of OMB's Office of Federal Financial Management 
(FFM) is required by statute to have a ``demonstrated ability 
and practical experience in accounting, financial management, 
and financial systems and extensive practical experience in 
financial management in large governmental or business 
entities.'' Now there is a reason Congress put those criteria 
in place in statute, but the President's nominee for the 
position was unable to explain in my view, and in the view of 
others on the Republican side of the dais here, how she met 
those qualifications or express a basic understanding of public 
accounting and financing. Her nomination passed out of the 
Committee, but it did so on a party-line vote and has yet to 
come before the Senate.
    We also have received distressing allegations regarding the 
conduct of nominees to serve on the Federal Labor Relations 
Authority (FLRA). We have asked the Inspector General (IG) to 
look into these allegations, so I do not want to prejudge the 
issue. But they are very serious allegations and a significant 
concern to me and many of my colleagues, and yet those nominees 
were on their way to this Committee before we insisted that we 
give the Inspector General a chance to look into it.
    Finally, multiple nominees for positions, such as a recent 
nominee to the Merit Systems Protection Board (MSPB), which is 
intended to serve Federal workers of all political persuasions 
and in fact has a role to play there to be totally 
nonpartisan--anyway, some of these nominees have tweeted 
extremely partisan statements. These statements have included, 
by the way, insults and partisan attacks against Members of 
this Committee and also fellow members of the Senate, our 
colleagues, at a time when we should be trying our best to 
return to saner times, when both parties can work together in a 
bipartisan fashion to serve all Americans.
    My point is, I guess, it is also about the quality of the 
nominees. It is hard to imagine these nominees being put 
forward, by the way, if we still had a 60-vote threshold to end 
debate on a nomination. When the President's party has 
controlled the Senate and a nominee only needs a simple 
majority to be confirmed, the majority party tends to overlook 
serious concerns sometimes with these nominees' qualifications 
in my view, and that might otherwise not be true if bipartisan 
support were necessary.
    Maybe that is what has been happening recently. Maybe that 
explains it entirely. I do not know. But this concern applies 
to both parties, by the way. The same was true during the 
previous administration with some nominees.
    One can argue that this weakens congressional oversight 
because nominees who do not have to get support from Senators 
of the other party might think, even if wrongly, that they do 
not need to be responsive to those Senators concerns once they 
are confirmed. Obviously, we have seen some of that in this 
Committee, where we have asked for information we have not been 
able to receive on both sides of the aisle.
    We probably cannot turn the clock back. We are where we 
are. But I do think we need to continue to take our advice and 
consent role seriously. I understand some of our witnesses are 
going to propose reducing the number of Senate-confirmed 
positions and explore some ways to make the process more 
efficient so we can attract the best people to government.
    By the way, the Chairman talked earlier about the arduous 
process. Let us be honest. The arduous process includes the 
lengthy and sometimes bureaucratic pre-confirmation process at 
the Executive Branch as well. Anyway, I believe some of these 
reforms, including reducing the number of Senate-confirmed 
positions, have merit and could work if carefully crafted.
    I am also glad that the witnesses will discuss the 
importance of having confirmed Inspectors General. Chairman 
Peters and I have led Members of this Committee from both 
parties in sending letters to President Trump and now President 
Biden that urged them to nominate IGs expeditiously and offered 
the Committee's assistance in identifying qualified candidates.
    But again, I want to say at the outset that no matter what 
reforms we discuss nominees need to be qualified and it is our 
role to vet these nominees. We have to encourage the Executive 
Branch to send us nominees that do not have some of the 
concerns that I raised earlier, and the confirmation process 
needs to be thorough and nonpartisan, or bipartisan at least.
    I thank the witnesses for testifying. I look forward to 
hearing what they have to say about these issues, and we look 
forward to engaging in a dialog on them.
    Thank you, Mr. Chairman.
    Chairman Peters. Thank you, Ranking Member Portman.
    It is the practice of the Homeland Security and 
Governmental Affairs Committee (HSGAC) to swear in witnesses, 
so if our witnesses would please stand and raise your right 
hand, including our witness who is joining us virtually. Do you 
swear the testimony you will give before this Committee will be 
the truth, the whole truth, and nothing but the truth, so help 
you, God?
    Ms. O'Connell. I do.
    Ms. Simmons. I do.
    Mr. White. I do.
    Chairman Peters. All have answered affirmatively. You may 
sit down.
    Our first witness is Anne O'Connell. Ms. O'Connell is the 
Adelbert H. Sweet Professor of Law at Stanford Law School. She 
is also a contributor to the Center on Regulation and Markets 
at the Brookings Institution and an appointed senior fellow of 
the Administrative Conference of the United States (ACUS). Most 
recently, her work has focused on acting officials and 
delegations of authority in Federal agencies, the loyalty and 
competence of agency appointees and Inspectors General. Her 
research and teaching also focuses on administrative and 
constitutional law.
    Ms. O'Connell, welcome to the Committee, and you may 
proceed with your opening comments.

TESTIMONY OF ANNE JOSEPH O'CONNELL, PH.D.,\1\ ADELBERT H. SWEET 
            PROFESSOR OF LAW, STANFORD SCHOOL OF LAW

    Ms. O'Connell. Thank you. Chairman Peters, Ranking Member 
Portman, and Members of the Committee, thank you for the 
opportunity to participate in today's important hearing.
---------------------------------------------------------------------------
    \1\ The prepared statement of Ms. O'Connell appears in the Appendix 
on page 37.
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    I would like to make three points. First, the current 
appointments process for filling key Federal agency jobs is 
broken at the White House and in the Senate. Second, vacancies 
in Federal agency leadership, particularly if frequent and 
lengthy, have detrimental consequences for our government. 
Third, nonpartisan reforms that preserve the political 
branches' constitutional roles are possible.
    First, there are vast gaps in confirmed agency leadership 
up and down the organization charts. Those gaps result from 
lags in nomination and delays in confirmation.
    A note, all my figures I will mention exclude Article III 
judicial nominations but include all agency picks.
    The last three completed administrations--George W. Bush, 
Obama, Trump--did not submit a single nomination in their first 
two years for, on average, nearly 30 percent of vacant agency 
positions. At the end of December compared to the past four 
administrations, President Biden has submitted fewer agency 
nominations than all of his predecessors except for President 
Trump.
    Official nominations are just the start of the appointments 
process. At the end of December, the Senate had approved fewer 
agency nominees under President Biden than Presidents Obama, 
Bush, and Clinton. President Biden just beat out President 
Trump in absolute numbers, but in percentage terms of 
submitting nominations, President Biden fell last. Just 53 
percent of his agency picks were confirmed.
    At the 13-month mark of the Biden presidency, so through 
February 19th, the Senate had confirmed 370 agency nominees, 65 
percent by voice vote, 35 percent by recorded vote, and not a 
single one by unanimous consent (UC). At the same point in 
President Trump's term, the Senate had confirmed 348 agency 
nominations, 76 percent by voice vote, 24 percent by recorded 
vote. For Obama, the Senate had confirmed 100 more nominees 
than President Biden by the close of month 13, 488; 95 percent 
were by voice vote and only 5 percent by recorded vote. 
President Clinton was the last President to have agency 
nominees confirmed by unanimous consent in his first year.
    Second, vacancies undermine agency performance. The MSPB 
has been practically unable to function since 2017 when it lost 
its quorum. The Senate did confirm two of the three pending 
nominees on Tuesday. Its backlog currently stands at around 
3,600 cases.
    Vacancies also foster confusion and lower morale among 
nonpolitical employees and undermine both agency legitimacy and 
constitutional safeguards. These delays also deter potential 
nominees from pursuing government service at the highest level.
    In many agencies, acting officials and delegations of 
authority do help to fill the gaps but not without exacting 
costs of their own. Even though acting leaders have the same 
formal authority as confirmed leaders, they are less able to 
wield it; they get less buy-in from the employees who work 
beneath them, relevant congressional committees such as yours, 
and the public. In addition, decisions made by acting leaders 
may face increased legal risks.
    I should note that some delay is necessary, even good. It 
takes time to find compelling, qualified, and diverse leaders 
and to properly vet them.
    Third, the process could be improved while respecting the 
political branches' constitutional roles. I focused here on 
three proposals: one, decrease the number of Senate-confirmed 
positions, two, streamline the vetting of nominations, and 
three, incentivize quicker nominations from the White House as 
part of changes to the Federal Vacancies Reform Act of 1998 
(FVRA).
    The most significant action Congress could take to improve 
vacancies is to cut the number of Senate-confirmed jobs. The 
easiest place to cut is likely for part-time positions. They 
could be moved into cabinet departments where the Secretary 
would pick members without Senate involvement to meet any 
appointment clause concerns. The next place to look would be 
positions that have not received nominees in the first half of 
a Presidential administration in both recent Democratic and 
Republican presidencies. The Partnership for Public Service 
(PPS), who you will also hear from today, has additional 
compelling proposals.
    If the goal is to decrease vacancies, it might be better to 
permit agency heads to select leaders, at least for some jobs, 
instead of the President alone as was done in the 2012 cuts. 
More choosers, less time.
    Fourth, the Senate and the White House should commit to 
revisiting the recommendations of the Working Group on 
Streamlining Paperwork for Executive Nominations, most of which 
have not been implemented, which was established by the 2012 
Act.
    Finally, I support the Accountability for Acting Officials 
Act. It would nearly halve the permitted time limits for acting 
officials outside of pending nominations in the most important 
agency positions. It would also restrict Acting Inspectors 
General to senior staff in IG offices. I would actually go 
beyond the Accountability for Acting Officials Act and expand 
that to cover other confirmed IGs. It would resolve ambiguities 
in the Vacancies Act that generated litigation in the Trump 
administration.
    There is one reform with regard to acting officials and 
delegations of authority that is more expansive of Presidential 
power, and that would be that I would also allow more nominees, 
those who have been confirmed to another post, to serve in an 
acting capacity while their nominations are pending. In 2017, 
the Supreme Court interpreted the Vacancies Act narrowly to 
allow a nominee to simultaneously serve as the acting official 
only if she had been confirmed to the first assisted position 
or had been in the first assisted position for a particular 
length of time. Mark Esper, in the last administration, had to 
relinquish his acting title when the Senate formally received 
his nomination for Secretary of Defense in 2019, which 
contributed to get another Acting Secretary of Defense and the 
Senate expediting its process.
    I look forward to your questions and thank you very much 
for this opportunity.
    Chairman Peters. Thank you, Ms. O'Connell, for your 
statement.
    Our next witness is Kristine Simmons. Ms. Simmons serves as 
the Vice President of Government Affairs at the Partnership for 
Public Service, a nonpartisan, nonprofit organization whose 
mission is to build a better democracy and a stronger 
government, including programming that specializes in 
Presidential transitions and improving Congress.
    Prior to her time at the Partnership, she served in the 
Administration of President George W. Bush as a Special 
Assistant to the President for Domestic Policy and advised the 
President and the White House senior staff on issues pertaining 
to government operations, reform, and management.
    She was also the Staff Director of the U.S. Senate 
Governmental Affairs Committee Subcommittee on Oversight of 
Government Management.
    Ms. Simmons, welcome to the Committee. You may proceed with 
your opening comments.

TESTIMONY OF KRISTINE SIMMONS,\1\ VICE PRESIDENT OF GOVERNMENT 
            AFFAIRS, PARTNERSHIP FOR PUBLIC SERVICE

    Ms. Simmons. Thank you very much, Chairman Peters, Senator 
Portman, Members of the Committee. I appreciate the opportunity 
to be here with you this morning. We also thank the Committee 
for your bipartisan commitment to making our government work 
better and for holding today's hearing on ways to improve the 
Senate confirmation process and ensure that our government has 
qualified and accountable leaders in place.
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    \1\ The prepared statement of Ms. Simmons appears in the Appendix 
on page 57.
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    My comments today are specific to the appointment and 
confirmation of positions in the Executive Branch and rooted in 
deep respect for the Senate's constitutional duty to advise and 
consent on executive nominations.
    A new President must make 4,000 political appointments, and 
about 1,200 of those are subject to Senate confirmation. Our 
data show that by almost any measure the appointment and 
confirmation process is in dire need of improvement. As the 
process is operating today, everyone loses. Numerous data 
points show that each recent President has found the 
confirmation process harder and longer than it was for his 
predecessor. The average time to confirm a nominee has nearly 
tripled since the Reagan Administration, and the Senate 
confirmation rate of nominees in a President's first year, when 
volume is highest, has dropped precipitously over the past four 
administrations.
    Widespread and long-term vacancies harm agency 
effectiveness, and that is not good for government or the 
people it serves. Many Senate-confirmed positions have been 
vacant for years across multiple administrations. According to 
Vanderbilt University's David Lewis and Mark Richardson, in the 
first two years of the Bush, Obama, and Trump administrations, 
30 percent of Senate-confirmed positions never received a 
nomination.
    The lengthy and arduous confirmation process can further 
discourage qualified people from joining public service. 
Serving the American people in a Presidential appointment is a 
privilege, and it is appropriate that individuals nominated for 
important positions are subject to the Senate's review.
    However, the confirmation process exacts a toll on nominees 
and sometimes on their families. Nominees subject their lives 
and families to public scrutiny. Many leave jobs to avoid even 
the appearance of a conflict of interest, hire lawyers and 
accountants to ensure their paperwork is free from error, sell 
assets and take other steps to mitigate financial conflicts, 
and make plans to move their homes and families at personal 
expense with no clear indication of when the Senate will 
consent to, or even consider, their nomination.
    The high number of positions subject to Senate confirmation 
actually decreases the Senate control when so many are vacant, 
and considering them takes valuable time that the Senate could 
be spending on oversight, legislation, constituent service, 
confirmation of other more senior or more important positions, 
and other pressing needs of the American people. Between 1960 
and 2016, the number of Senate-confirmed positions increased by 
nearly 60 percent, and in the last 11 years alone, roughly 60 
new Senate-confirmed positions have been created.
    Along with more positions, the burden of considering them 
is growing. The number of nominations returned at the end of a 
President's first year under Senate Rule 31 has increased for 
each recent President, meaning nominations must be resubmitted 
and much of the process gets repeated. The number of cloture 
motions on Executive Branch nominations has risen in each of 
the past five administrations, meaning more floor time spent on 
confirmations and less time for other Senate business.
    What can the Senate do about this? We have five 
recommendations.
    First, reduce the number of positions subject to 
confirmation. Twelve hundred positions are more than the Senate 
can reasonably process given your other important 
responsibilities. This Committee led the way 10 years ago in 
reducing the number of Senate-confirmed positions by 163 and 
can do so again.
    Second, consider changes to the Senate's privileged 
nominations calendar, Senate Rule 31 on return nominations, and 
other Senate processes. Nominations on the privilege calendar 
take longer now than they did before the privilege calendar was 
created.
    Third, expand the holdover norm and consider adopting fixed 
terms for Senate-confirmed positions, for example, the U.S. 
Department of Veterans Affairs (VA's) Under Secretary for 
Health, that require unique expertise and have become difficult 
to fill.
    Fourth, implement the recommendations of the Working Group 
on Streamlining Paperwork for Executive Nominations. The 
recommendation for a smart form, for example, would make the 
process more efficient and ease the burden for nominees.
    Finally, we encourage you to revisit the Federal Vacancies 
Reform Act and modernize the Plum Book. Greater transparency 
would improve congressional oversight and agency 
accountability. Senator Carper has introduced, along with 
Senators Braun and Merkley, the Periodically Listed Update to 
Management (PLUM Act), and we applaud him for doing so.
    Thank you, and I am happy to answer your questions.
    Chairman Peters. Thank you, Ms. Simmons.
    Our final witness is Adam White. Mr. White is a senior 
fellow at the American Enterprise Institute and Co-Executive 
Director of George Mason University's C. Boyden Gray Center for 
the Study of the Administrative State. He serves on the 
Administrative Conference of the United States, and he is Vice 
Chair of the American Bar Association's Section on 
Administrative Law and Regulatory Practice.
    Last year, President Biden appointed Mr. White to the 
Presidential Commission on the Supreme Court of the United 
States. After graduating from the University of Iowa and 
Harvard Law School, he clerked for Judge David Sentelle on the 
U.S. Court of Appeals for the D.C. Circuit.
    Mr. White, welcome to the Committee. You may proceed with 
your opening comments.

 TESTIMONY OF ADAM WHITE,\1\ CO-EXECUTIVE DIRECTOR, C. BOYDEN 
 GRAY CENTER FOR THE STUDY OF THE ADMINISTRATIVE STATE, GEORGE 
   MASON UNIVERSITY, AND SENIOR FELLOW, AMERICAN ENTERPRISE 
                           INSTITUTE

    Mr. White. Thank you very much. Thank you, Chairman Peters, 
Ranking Member Portman, and Members of the Committee.
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    \1\ The prepared statement of Mr. White appears in the Appendix on 
page 69.
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    I generally agree with much of the diagnosis that has been 
offered so far. Too many offices require Senate confirmation. 
There are too many vacancies for too long and too many acting 
officers serving in offices that should require, or currently 
require, Senate confirmation. But I think the implications run 
further, the fixes are more difficult, because the underlying 
causes of this problem run much deeper.
    Let me begin with constitutional underpinnings of the 
Senate role. Needless to say, the Executive Branch is primarily 
responsible for administration, but the Senate is crucial in 
foreign affairs and also in domestic policy, particularly in 
terms of the Senate's responsibility to grant or withhold its 
advice and consent to the appointment of officers.
    As Alexander Hamilton famously wrote in Federalist 76, this 
role of the Senate is crucial for the steady administration of 
the laws. The Executive brings energy, but the Senate must 
bring stability and security. The Senate has a key role, but 
for that very reason it must marshal its resources very 
carefully.
    In light of those constitutional foundations, the current 
situation is very troubling. Too many offices require Senate 
advice and consent, at least relative to the Senate's capacity 
to carry out those duties with respect to all of those offices. 
There are too many vacancies for officers that the Constitution 
or Congress wanted to be filled with the Senate's advice and 
consent. I would be in favor in general of reducing the number 
of offices requiring Senate advice and consent but precisely so 
that the Senate can be more effective in the remainder of its 
advice and consent role, to focus on the most important offices 
and hold them accountable for the rest of the agencies' work.
    I want to emphasize the root cause of all this actually 
runs deeper, though. I think the root cause of much of this is 
the broad delegations of power that Congress has vested in 
agencies, great power, great discretion, and great 
responsibility, which makes each of these offices--the 1,200 
offices we are referring to--all the more consequential. 
Indeed, it is no surprise that Congress would have wanted the 
Senate's advice and consent when it created these offices given 
the powers that these offices are responsible for 
administering.
    I hope the Committee will keep in mind that the advice and 
consent issue we are discussing today is a problem but it is a 
symptom of much deeper problems. For that reason, I think that 
any reforms will have much broader ramifications. For example, 
if you reduce the number of offices requiring Senate advice and 
consent, the top-level agency offices will necessarily require 
and receive much more scrutiny both from the public and also 
from the Senate.
    To the extent that offices are taken out of Senate advice 
and consent, and removed all the way down to Civil Service, out 
of Presidential appointment altogether--and, of course, there 
are constitutional questions surrounding any shift along those 
lines. But to the extent that offices are transferred out to 
Civil Service, that will only further exacerbate the debates we 
have right now about the State of our Civil Service and the 
political debates surrounding our civil servants.
    To the extent that the Senate concludes that it can carry 
out its oversight function less in terms of advice and consent 
and more in terms of Congress's power of the purse, of course, 
that raises the deeper problems regarding Congress's 
appropriations and the appropriations process.
    I do hope that any reforms keep in mind the underlying 
problem of the powers, responsibility, and discretion wielded 
by these offices. I hope that any reforms to the process are 
coupled to the extent possible with reforms to substance, the 
substantive powers of the agencies.
    I mentioned earlier Alexander Hamilton, our founding 
generation's greatest thinker on constitutional administration. 
When I think about these issues, I often return to a line he 
offered in Federalist 68. He said: The true test of any 
constitution is its tendency and aptitude to produce good 
administration. That is pretty astonishing for all the things 
that Hamilton wrote about the Constitution. For him to say that 
the true test of our Constitution is the administration that it 
produces, that is amazing. In fact, he said it once in 
Federalist 68, and then he quotes himself later in 76 to make 
the point once again.
    In his time, administration was the true test of 
government. It remains so in our time, and I am grateful for 
this Committee for considering the importance of the issue and 
the need for reform.
    Chairman Peters. Thank you, Mr. White.
    Ms. O'Connell and Ms. Simmons, according to the Washington 
Post Political Appointee Tracker, an average of 4 in 10 Biden 
nominees have been waiting on Senate confirmation. This is not 
uncommon. Every recent President has experienced delays. But 
the delays, they just appear to be getting longer and longer. 
The time it takes for Congress to confirm Presidential nominees 
has been growing during every single administration since 
President Ronald Reagan.
    You both mentioned several causes for delays when you 
presented your testimony to us. What do you believe, however, 
are the most significant reasons for these delays, and what 
actions from Congress should we consider to address them? Maybe 
give me a priority or two, what you think is really significant 
that we should be thinking about. We will start with Ms. 
Simmons and then, Ms. O'Connell, if you would respond as well.
    Ms. Simmons. Thank you, Mr. Chairman. From the perspective 
of the Partnership, the sheer volume makes it very challenging 
and contributes to just a greater bottleneck. We would 
encourage fewer positions as stated in my testimony. We think 
it would allow the Senate to focus on positions that most 
warrant your review and scrutiny and would make the best use of 
the Senate's time.
    We also think the process is extremely complicated as a 
result of the very challenging paperwork. All of the paperwork 
serves a purpose, and it is meaningful with respect to 
adjudicating issues in someone's background, financial 
conflicts. But the questions that are asked are inconsistent, 
confusing, and it is very common for paperwork to go through 
multiple rounds and corrections because it is very difficult 
for nominees to get it right the first time. There is a great 
amount of delay that occurs before the Senate even gets the 
nomination because there is so much involved in preparing the 
package that comes to the Senate. We think simplifying the 
paperwork would also contribute to a more efficient and 
expedient process.
    Chairman Peters. Thank you. Ms. O'Connell.
    Ms. O'Connell. Thank you, Chairman. I think the two biggest 
reasons for these increasing delays on the Senate side--and 
there are delays on the White House side as well. The first, I 
agree with Ms. Simmons from the Partnership that the sheer 
number of positions and the amount of time each position takes 
in terms of the vetting process has slowed it down. In terms of 
reform I do think that the most important thing that Congress 
could do would be to cut the number of Senate-confirmed 
positions.
    But I think what happens in its replacement is critical. In 
the Streamlining Act enacted in 2012, those approximately 170 
positions went from Senate-confirmed to President-alone, and 
there were delays even when it is just the President alone. I 
think giving a lot of thought to which of those positions could 
be done by heads of departments to help speed up the process as 
well.
    The second greatest reason I believe for the delays has to 
do with changing norms in the Senate. In earlier 
administrations--I am thinking President Reagan, President 
George Herbert Walker Bush, President Clinton--the norm was 
especially in the first year that agency nominees were 
confirmed by unanimous consent. And that, since President 
Clinton, does not happen anymore.
    It is not because in the end the votes are close. If you 
look at the recorded votes of President Biden's nominees 
through February 19th, over half of the recorded votes, there 
are more than 60 votes to confirm. But I think now a vote on an 
assistant secretary--and this is true both for Democrats and 
for Republicans--is a sign of party fealty. And so kind of the 
cooperative norms that existed do not exist in the same way, 
and so that has contributed as well.
    Now in terms of reform there, I hesitate in terms of 
recommendations to changes in Senate rules. But to the extent 
that the Senate could establish some more cooperative norms, at 
least on a subset of critical nominations, say in the national 
security space, that would also be helpful.
    Chairman Peters. Thank you. Thank you both for that answer.
    I am going to ask you another question, both of you, and we 
will start with you again, Ms. Simmons. Under the Appointments 
Clause of the Constitution, Congress has the right to 
determine, as you know, which positions require Senate 
confirmation. If we are going to reevaluate these positions 
that require the confirmation, would you please tell the 
Committee what criteria or factors do you recommend that we 
consider if we go down this path? Ms. Simmons, if you would 
start.
    Ms. Simmons. Sure, I am happy to. Thank you for that 
question. We strongly believe that every position should be 
evaluated by the Senate to determine whether it is a principal 
officer or an inferior officer. Titles themselves do not tell 
you a lot. There is a variety of responsibility assigned to 
different positions.
    Some assistant secretaries are Senate confirmed; some are 
not. But we recognize that there is a great opportunity to look 
at assistant secretaries and make a determination and perhaps 
start with the presumption that they do not need to be Senate 
confirmed, particularly if they are reporting to another 
appointee who is more senior, who is subject to Senate 
confirmation. That is a basic test of the Supreme Court, 
whether a position is under the supervision and direction of 
another Senate-confirmed leader, and we think that is an 
important place to start and obviously would support ensuring 
that you have the control and accountable officials that you 
need to do your jobs.
    Chairman Peters. Thank you. Ms. O'Connell.
    Ms. O'Connell. So functionally, we have already cut the 
number Senate-confirmed positions with the vast use of acting 
officials and delegations of authority, but the choice has been 
in the White House's hands in terms of where those acting 
officials and delegations take place.
    I support strongly the Congress taking an affirmative role. 
The place that I would look to first, the working group, after 
the Streamlining Act enacted in 2012, pointed out that around 
30 percent of still remaining Senate-confirmed positions are 
part-time positions, requiring under 60 days of service in a 
calendar year, and I think many of those positions where Senate 
confirmation could be cut. In that push the Senate did in mid-
December to get a bunch of nominees through, we saw several 
confirmations to these part-time boards, to the Barry Goldwater 
Scholarship Foundation, the Corporation of National Service. 
Those seem like places to look in addition to the suggestions 
laid out in the longer Partnership for Public Service report.
    Chairman Peters. Thank you.
    Ranking Member Portman, you are recognized for your 
questions.
    Senator Portman. First, thanks to all three of you. You 
have made some good suggestions. I still go back to the two 
points I raised in the opening. One is the point that this not 
all about the Senate. Having been one of the Associate Counsels 
to the President for George H.W. Bush, who looked at nominees 
and their financial disclosure forms and so on, we thought it 
was pretty arduous at the time, but it has become much more so. 
The point you made today I think was that 30 percent of 
vacancies never receive a nomination.
    We talked a little about--Professor O'Connell just talked 
about acting officials and how that has increased. In effect, 
actings have taken away the Senate role for confirmation.
    Anyway, I will not ask for more on that today except to say 
that we would like for the record--and maybe the Partnership is 
the place to look to give us some more specific suggestions on 
the pre-Senate nomination process, the appointment process. 
That is within the purview of this Committee, so it is part of 
our oversight responsibilities.
    Second is the quality of the candidates. We heard a lot 
today about making the process more efficient. Again, I think 
there is a lot of merit to that, but also I get back to my 
point about improving the quality for nominees. Are there any 
changes to Senate procedures, perhaps short of going back to 
the 60-vote margin, to incentivize that more qualified nominees 
be recruited and nominated? I open that up to all three of you.
    Ms. Simmons. Senator Portman, I am happy to start and 
invite my fellow panelists to chime in. One of the things that 
we were surprised to discover as we began some of our work 
around Presidential transitions and the high number of 
appointees that a new administration must confirm is how few 
positions are associated with position descriptions. We have 
actually created over 400 position descriptions that did not 
exist and are not available. In some cases, it would be helpful 
for the Senate to have a better understanding of what the real 
job is for some of these positions. You articulated positions 
where you are very familiar with what is required, and the 
Senate has even put statutory qualifications in place.
    We think a place to start is to consider whether there are 
adequate descriptions around the qualifications that you want 
in particular nominees for key roles in government, making sure 
that there is an understanding even among people who are being 
considered for those positions as to what the job actually 
requires.
    Senator Portman. Mr. White, any thoughts on that?
    Mr. White. To your point about Senate procedures, I do 
think this is crucial. I understand there are arguments, there 
are strong arguments, for reducing the threshold for 
confirmation in terms of cloture on nominees. But the fact is 
the Senate's procedures have begun, as the Committee knows more 
than anybody, ever more sort of straight majority rule in more 
and more situations, with less and less deference given to the 
judgments and the procedural powers of individual Senators. We 
are seeing that filter through to the quality of the 
nominations.
    I think in general the underlying problem here is that--and 
this goes beyond just appointments, but in general--the 
administration is ever more identified exclusively with the 
President, not the President and the Senate. The administration 
is seen as something the Executive takes care while the Senate 
worries about other things. I think it is crucial for the 
Senate to reconsider its procedures surrounding advice and 
consent to slow things down for the most important nominations 
and use them as real points of leverage for oversight of the 
agencies in general.
    Senator Portman. Fewer nominees but those that are 
important positions, that are from a policy perspective most 
important, to spend more time on vetting those individuals and 
perhaps therefore improving the quality of those individuals.
    Mr. White. Absolutely. If I may, in terms of the criteria 
for removing offices out of the Senate advice and consent role, 
I think it is important to keep in mind each particular 
agency's substantive powers. Of course, the offices vary from 
agency to agency, but the agencies themselves vary in terms of 
their responsibilities overall. I would urge the Senate to be 
more cautious--or, the Congress to be more cautious in removing 
the Senate advice and consent role for the agencies that have 
the most impact on day-to-day life.
    Of course, that is measured in a number of ways. The Office 
of Information and Regulatory Affairs (OIRA), of course, keeps 
tallies of the costs and benefits of rules imposed by agencies, 
and so it might be worth keeping that in mind when you decide 
which offices and which agencies to remove from advice and 
consent.
    Senator Portman. Professor O'Connell, you talked about 
this; you said that 30 percent of these jobs are part-time 
jobs, usually boards and commissions. We talked earlier about 
30 percent of the vacancies never receive a nomination at all. 
In other words, in effect, there may be some overlap there but 
probably not much.
    Sixty percent are either not nominated because an acting is 
chosen, so the administration never even nominates somebody, 
and another thirty percent are for part-time jobs. In effect, 
it is a relatively smaller group, less than half probably that 
are actually getting attention that are substantive policy 
positions. Is that fair to say, Professor O'Connell, or have I 
missed my math there?
    Ms. O'Connell. I am not exactly sure. The 30 percent that 
do not receive a single nomination in the first two years, from 
the research of Professor Lewis and Mark Richardson, does not 
overlap considerably, as I understand it, with the part-time 
positions because many of those part-time positions are ways of 
rewarding those who helped with a campaign. In that push in 
mid-December, seven, I think, of the nominees that were 
confirmed in the final week in December kind of came from those 
boards whereas like assistant secretaries were still sitting.
    But I do think, right, you could remove some of these part 
time positions, of course, within the confines of the 
Appointments Clause. The Senate could really focus on these key 
policy positions which also have constitutional implications, 
as Mr. White has explained. And so that would be important.
    I would just say, one thing back to your question on 
qualifications is I guess I do think that many of agency 
officials who are put up by the President, confirmed by the 
Senate, and even those that present some hurdles, are 
extraordinarily well qualified, and they are undergoing 
considerable sacrifices to serve our government. I do think by 
reducing some of the vetting and the forms, not to weed, of 
course, we want to have qualified people.
    But what we have now is an insider game. Just the 
percentage of people coming from the D.C. area is quite high. 
There are well-qualified people, as you know, from States other 
than Maryland, Virginia, and D.C., and some of the changes 
could help expand the pool to get more diverse voices into the 
Federal Government.
    Senator Portman. Yes, I could not agree with you more and 
particularly with regard to Ohio. Thank you.
    But seriously, again I have gone through two of these 
confirmations. But I will say prior to 2013, when there was a 
60-vote margin required, I think the quality of the candidates 
was better; I just think that. I think some of these people 
that we end up passing with a strict party-line vote would 
never have been nominated had there been a 60-vote margin.
    The same is possibly true with regard to our judges 
because, let us face it, it would require more bipartisanship. 
Now the counter to that would be that the Senate has become 
more partisan, which I think is also true.
    But I must say I think the quality of nominees since 2013 
has changed. Again, I do not think some of these nominees that 
are now being nominated, who again have been online--I guess 
there were not many people worried about what Twitter was 
saying back in 2013. But some of the things they have said and 
done, and in the positions they are being put up for, like we 
talked with the Merit Systems Protection Board--someone who is 
openly and overtly partisan. It just does not make sense. There 
has to be, out of the hundreds of millions of people in America 
someone else who can step forward, maybe from outside the D.C. 
bubble, who is qualified for those kinds of positions.
    Anyway, I do not disagree that the process is too arduous 
and ultimately what we want to do is attract the best people to 
government. Yet, I do think that the reality is that the 
quality of the candidates matters, and also that the Senate 
does have an important role to advise and consent, and we have 
to figure out how to make that work for those important 
positions that really matter.
    With that, Mr. Chair, I will turn it back to you. Again, I 
thank our witnesses very much and look forward, if you could, 
from the Partnership, Kristine, following up with some more 
specific recommendations for us. Thank you.
    Ms. Simmons. I am happy to. Thank you.
    Chairman Peters. Thank you, Ranking Member Portman.
    Ms. O'Connell, you studied the impact of vacancies in 
political positions, including adverse effects from having many 
positions without confirmed officials for long periods of time. 
Obviously, vacancies always occur for many reasons. But 
regardless of the reason, could you explain to the Committee 
the actual impact these vacancies have on agencies?
    Ms. O'Connell. Thank you, Mr. Chairman. I think that 
vacancies, particularly if they are lengthy and frequent, have 
several detrimental consequences.
    The first is in regard to performance. Sometimes agencies 
cannot act. Although the Federal Vacancies Reform Act of 1998 
gives long service for acting officials, that Act applies only 
to cabinet departments and single-headed executive agencies for 
the most part, which means that independent regulatory 
commissions and boards, like the Merit Systems Protection 
Board, do not have recourse to acting officials. For those 
agencies who cannot use acting officials and who have quorum 
requirements, then you have real effects, like you get the 
3,600 case backlog at the MSPB, for example.
    Even in agencies which are able to use acting officials, 
performance is also impacted because acting officials are 
hesitant to take on big new projects because they perceive 
themselves generally as caretakers. Rulemaking, for example, in 
the first year of Federal agencies is lower than in other years 
as agencies staff up. Of course, rulemaking can be both 
regulatory and deregulatory.
    A second consequence of longer vacancies has to do with 
employee morale. The Partnership of Public Service has run 
various surveys of agency employees, and they have found a 
connection between agencies who lack Senate-confirmed leaders 
with what they call static or declining employee engagement. 
Employees seem to be less happy at agencies who do not have 
confirmed leaders.
    Then a third consequence is that in the agencies that can 
use acting officials there are detrimental consequences to long 
use of acting officials. When those time limits run out to the 
delegations of authority, in addition to undermining the 
Senate's role, there are some legal questions that arise.
    I think that there are often many detrimental consequences.
    Chairman Peters. Senator Rosen, you are recognized for your 
questions.

               OPENING STATEMENT OF SENATOR ROSEN

    Senator Rosen. Thank you, Chair Peters, and of course, I 
see Ranking Member Portman there. I want to thank the witnesses 
for their insights today.
    All of this is critical, and I am worried about our 
critical services for veterans. Ms. Simmons, in your testimony, 
you referenced the VA's Under Secretary for Health, a position 
that has not had a Senate-confirmed leader since 2017. This 
position leads the Veterans Health Administration (VHA), which 
is the country's largest integrated health system. It serves 9 
million enrolled veterans each and every year, more than 1,200 
sites, and an annual budget of $61 billion. Nevada is home to 
over 225,000 veterans. I am deeply concerned that the VA had to 
stand up a commission last year just to identify candidates to 
lead and manage the VHA.
    Ms. Simmons, what can Congress do to ensure that positions 
like these, that are not as high as cabinet level but still 
oversee critically important government services, including for 
our veterans, that they do not go without permanent leaders for 
years at a time? This really hurts our country.
    Ms. Simmons. Thank you, Senator, for that question. We are 
very much in favor of trying to find creative ways to fill 
these positions that are truly management in nature and require 
high levels of professional and technical expertise and are 
really apolitical. I think service to our veterans is certainly 
a place where we can do more to think about how to provide 
continuity of leadership and to think about the positions 
differently.
    One idea is to change the norm, think differently about 
whether these positions actually turn over with a change in 
administrations. Inspectors General are positions that are 
Senate-confirmed, but by tradition they are not expected to 
turn over when a new administration comes in. There is a 
potential to think differently about some of these management 
jobs and adopt that same kind of norm or tradition of not 
having them turn over.
    Another suggestion would be to think about providing a set 
term, a longer term, with professional qualifications so that 
you have greater assurance that someone stepping into the role 
would understand that they had a runway that went beyond one 
administration and that they were there for their professional 
expertise. You could even build performance measures around 
that position.
    Another thing we think is important is to think about 
having performance plans for political appointees. This is 
something I think would speak to Senator Portman's concern 
about the quality of nominees. We strongly feel that people in 
these important positions need to be qualified leaders. They 
should be developed and trained as leaders. They should be held 
accountable for their performance. Being clear what good 
performance looks like, and setting some terms and extended 
terms, would allow them to have more continuity in some of 
these key positions, especially in areas as apolitical and 
important as service to our veterans.
    Senator Rosen. That is great. I think we also have to be 
sure that we identify how we identify those quality candidates, 
get them into the pipeline. Implementing some of the things you 
are thinking of and others is a good thing.
    I would also like to talk a little bit about regional 
appointments because last week President Biden announced 13 
regional appointments for the Federal Emergency Management 
Agency (FEMA), the Environmental Protection Agency (EPA), and 
the Department of Agriculture (USDA), including the Nevada 
State Executive Director for the Farm Service Agency (FSA). The 
nominee, Janice Kolvet, she has experience as a career Federal 
employee working on Federal farm programs, as a cattle rancher 
in Elko, Nevada. She is a Nevadan.
    Regional appointments like these are so important, 
especially in western States, where the local economy, 
industry, and climate challenges are not always familiar to 
Federal Government workers here in Washington, DC.
    Ms. Simmons, I understand these regional appointments are 
not subject to Senate confirmation. So why is it that it can 
take so long to fill these critical roles in a new 
administration, and what effect does the Senate confirmation 
process in general have on these appointments even though it is 
not required for a particular position?
    Ms. Simmons. Thank you for that question. This speaks to 
something that Professor O'Connell raised, which is the value 
of reaching outside of Washington for candidates and filling 
these important positions with people who bring diverse 
perspectives from around the country and can really bring their 
personal expertise and experience to bear in service to the 
public.
    When there are so many positions subject to Senate 
confirmation, it is almost essential that a very small Office 
of Presidential Personnel (PPO) devotes their attention there, 
and that tends to take up a lot of the time that could be spent 
sourcing candidates for some of these more regional positions, 
positions not subject to Senate confirmation.
    It is also true sometimes that some of these regional 
positions or other positions that are not Senate-confirmed, are 
not filled until the Senate-confirmed position is filled above 
it. So that can also contribute.
    Finally, I do not have specific knowledge of the situation 
at USDA, but when the government is operating under a 
continuing resolution (CR), there also might be financial 
reasons why they are not able to fill particular positions that 
they need to fill until full-year appropriations are passed.
    Those are a few of the comments, and I would invite my 
other panelists to chime in.
    Senator Rosen. Yes, because government services really 
suffer in our regional areas when these positions are not 
filled. Professor O'Connell, would you like to comment on this 
as well, please?
    Ms. O'Connell. Thank you, Senator. I agree with Ms. Simmons 
from the Partnership about the various reasons.
    I would just add with regard to the Presidential Personnel 
Office is that we have seen a lot of turnover in PPO across 
Democratic and Republican administrations. In President Obama's 
administration, for example, the head of PPO, while trying to 
fill all these Plum jobs across Federal agencies, decided that 
he wanted to take a Plum job as Ambassador to South Africa and 
so was gone from the Presidential Personnel Office within six 
months of the start of that administration. For President 
Biden, the first Director of Presidential Personnel has also 
left.
    I think it is also important for Republicans and 
Democrats--and there was turnover in PPO as well in the Trump 
administration--to have experienced people in Presidential 
personnel, to have the staff, and then have the various 
computer systems, the online systems, to help process more 
quickly people both for Senate-confirmed positions and then for 
these other political jobs.
    Senator Rosen. Thank you. I appreciate that.
    I see my time is expired. I just think we really have to 
also address the Federal Vacancies Reform Act, its relationship 
to agency-specific succession schemes. We have a lot to do 
here. People need services.
    I appreciate everyone for being here. Thank you, Mr. Chair.
    Chairman Peters. Thank you, Senator Rosen.
    Ms. Simmons, the Partnership for Public Service's 
unconfirmed report States that there are both economic and 
performance costs related to the current number of appointments 
and the pace at which they assume that office.
    Could you elaborate for this Committee on what those 
economic and performance costs are and how they specifically 
relate to the effectiveness of our agencies?
    Ms. Simmons. I am happy to, Mr. Chairman. It really speaks 
to the importance of government operating at its very best, 
particularly given the many challenges that our government is 
facing and the need to serve the American people as effectively 
and efficiently as possible.
    We know that having vacancies in critical positions 
contributes to delayed decisionmaking. Many acting officials 
are toggling between two jobs, which means they are often not 
able to fully commit to either position and to give it as much 
attention as it may require, and that could de-optimize the 
effectiveness of agencies. We know that legal challenges are 
possible when people are serving in acting roles, and it is 
questionable in terms of how they stepped into those roles. We 
also think that there is national security implications for 
positions that are not filled, and this is something that the 
9/11 Commission recognized as well.
    I will also note that there have been bills introduced in 
the past that had a variety of different cost estimates 
associated with the savings that would be realized from 
reducing the number of positions subject to Senate 
confirmation, even going back to a bill that Senator McCain had 
introduced, capping the number of Senate-confirmed positions, 
and it had a very high estimate of the amount of money that 
that would save.
    Chairman Peters. I am going to ask another question for 
you, Ms. Simmons, as well as Ms. O'Connell. The Federal 
Vacancies Reform Act of 1998 allows the President to fill 
vacant positions requiring Senate confirmation with an acting 
officer, but the acting officer may serve for a 300-day period 
at the beginning of the administration and a 210-day period 
later on in the administration while the President decides who 
they will nominate.
    If each of you could briefly share with this Committee what 
happens when the time period runs out and the impact that this 
has on the agency and on congressional oversight. Ms. Simmons?
    Ms. Simmons. Thank you for that question. What happens when 
that time period runs out is often not transparent to Congress 
or to the public. We did some research on this and found a 
variety of titles that were put in place. At times it appears a 
position has been unfilled altogether. Other people will fill 
it with titles of a principal official performing the duties 
of. There are deputies that step in. It is a patchwork of ways 
in which administrations respond, but the fact is that the work 
needs to get done.
    This is why we are encouraging a fresh look at the 
Vacancies Act, to try to fix some of the ambiguities in the 
law. One of the things we strongly recommend is to allow 
someone who has been nominated to also serve as the acting 
leader of that agency, and this is something that Professor 
O'Connell also mentioned in her statement. We think that there 
are opportunities to fix some of the places where the Act is 
unclear.
    We think more timely reporting is also essential. There is 
a requirement now that agencies report to the General 
Accounting Office when there is a vacancy. It is very spotty 
and very slow. Again, there is not much transparency as it 
exists today.
    Chairman Peters. Thank you. Ms. O'Connell.
    Ms. O'Connell. The time limits for the Vacancies Act are 
long, Chairman. So you get in the first year 300 days if there 
is a nomination, all throughout the nomination; if that 
nomination is returned, an additional 210 days. You get the 
time for a second nomination; if that nomination is returned or 
withdrawn, a final 210 days. It is possible under the Vacancies 
Act to have over two years of acting service.
    Now what typically happens is we do not see those pending 
nominations. After the 300-day mark, the acting title is gone 
from those leadership pages, and instead we typically have 
delegations of authority. So under current case law, functions 
that are not exclusive to the vacant position are delegated 
down.
    Mr. Berry from the Cato Institute, I believe, has submitted 
a written statement talking more about some of the legal 
issues. He and I disagree about kind of what to do in some 
regard to that. But basically, then you have senior officials 
performing the duties and functions of the vacant office 
occurring when the time limits run out.
    As Ms. Simmons indicated, there are transparency problems. 
Although you have reporting under the Vacancies Act for acting 
service, there are reporting requirements with regard to 
delegations. It is incredibly hard to find information about 
delegations. I was a consultant to ACUS on a project on acting 
officials and delegations of authority. It was very hard to 
track down not just acting officials but then, when the time 
limits ran out, what was happening with regard to those vacant 
positions.
    Now it is a tricky balance because you want transparency, 
you want accountability, you want the Senate's role, but you 
also want government agencies to function and we have a 
dysfunctional appointments process. But somehow we need acting 
officials and delegations of authority for the stop gaps, but 
we need to reduce the time of those stop gaps.
    Chairman Peters. Thank you.
    Ranking Member Portman is recognized for a question.
    Senator Portman. Thank you, thank all three of you. Great 
point about acting. We also talked earlier about career because 
I think, Mr. White, in your testimony, you say that if some 
Senate-confirmed positions are converted to career roles then 
the Federal Civil Service should be reformed also.
    Senator Lankford is here, and I want to turn to him now to 
make sure he has a chance to ask his questions. But if you 
could just for the record provide us some specifics on that, 
that would be helpful in terms of should we choose to have more 
career roles, what kind of reforms to Civil Service might be 
appropriate.
    Thank you, Mr. Chairman.
    Mr. White. Thank you for your question. I want to be very 
clear at the outset the Constitution places limits on which 
offices could be removed outside of the political appointments 
altogether and returned down to Civil Service.
    Setting that aside, in my testimony, when I referred to the 
connection between the appointments issue and the Civil Service 
issue, I was referring to the broader debates that we have been 
having in Washington and beyond for years now over the State of 
our Civil Service, the political criticism of it, some of it 
well founded, some of it not at all well founded, and questions 
about the policymaking discretion that is in the hands of some 
civil servants who have less accountability to the agency heads 
or to the President. In my testimony, I was merely pointing out 
that to the extent that more agency authority is taken out of 
Presidential or Senate-confirmed appointments and moved down 
into the Civil Service, it will only ratchet up the temperature 
surrounding debates on whether and how to reform Civil Service.
    Senator Portman. Yes, that is why I asked the question. 
Again, if you would provide some more for the record, that 
would be great. But if we were to go down that track, as an 
example, reduce the number of confirmed positions, have more of 
them be career, it might be an opportunity to make some long-
awaited changes in the Civil Service as well, and that is why I 
was interested in your response.
    Thank you, Mr. Chairman.
    Chairman Peters. Thank you, Ranking Member.
    Senator Lankford, you are recognized for your questions.

             OPENING STATEMENT OF SENATOR LANKFORD

    Senator Lankford. Mr. Chairman, thank you and thanks for 
all the input on this. This is one of those things that most 
folks outside of D.C. are not going to pay attention to at all 
but is extremely important for the functioning of not only the 
Senate but the Administration and trying to be able to get the 
right people in the right place. I appreciate all of you 
spending so much time helping us think through some of these 
issues and to be able to talk about it.
    I do want to talk about some different things on this. One 
of them is for individuals that are going through the 
Presidential nomination process they have to divest from their 
business, they have to divest from their stocks, and all kinds 
of things they have to walk away from. Then they spend a year 
or two or three awaiting the confirmation process on this. That 
definitely encourages people not to take these jobs, and we 
create a discouragement from people, to say: I would do that 
job, but it may take two years to go through it, and I am not 
going to do two years without my business, without income, and 
have to be able to sell my business and then not even be 
certain if the Senate is going to even take up my nomination at 
all.
    That is a terrible process. How do we get good people to be 
able to step into these roles when there is so much uncertainty 
at the beginning?
    What would your suggestions be on how we handle personal 
finances of individuals while they are going through the 
process? Would it be a recommendation to say they have to 
divest from all those different investments if they take the 
role and are actually confirmed, or do they have to take it 
while they are going through the nomination process?
    Ms. Simmons. Senator, thank you for that question. I am 
happy to start, and I invite my fellow panelists to chime in.
    I am not an expert on the Ethics in Government Act which 
governs the financial disclosure process, but I will share that 
what we hear from nominees and from transition teams and from 
people on Capitol Hill working on these issues is that as the 
financial products have become, so much more sophisticated that 
the Act has not really kept up. There are so many challenges 
nominees face in understanding how different things they own 
will be treated and viewed, and it often will be months into 
the process before they are told that a particular managed 
account is not a mutual fund or not treated the same way and 
needs to be disposed of or mitigated in a different way. It can 
be very challenging. So bringing additional clarity as early as 
possible will help people complete their forms and do so in an 
accurate way.
    We also think it is important for people to understand what 
these jobs require, what public service requires. It is a 
different place. There is the responsibility of public trust. 
People need to have a clear understanding of both the privilege 
of serving in a Presidentially appointed role and also the 
sacrifices that go with it before they say yes.
    Senator Lankford. Yes. There is a different set of 
sacrifices, though, to be able to say to someone, I am going to 
need you to sell your business, walk away from all your 
investments, and live isolated financially for the next year 
and a half before we will give you an answer if you are going 
to get this job.
    Ms. Simmons. Right.
    Senator Lankford. That is not right. Again, if they take 
the job on, that is different than you have to sacrifice all 
this stuff and then we will tell you later whether you are 
actually going to get it or not. That is what I am driving at.
    I have no problem with maintaining ethics for individuals 
that are serving in government, but we are talking about those 
that are literally in the application process at that point, 
that the Senate is still considering advice and consent on 
that. That is a whole different issue for me, and so I do think 
it is an area that we have to be able to address.
    There has been some conversation about reducing the list, 
and I fully take on the responsibility of constitutional and 
trying to be able to deal with advice and consent on this. But 
there are some rules that are out there, for instance, the 
legislative affairs person for several of these agencies. Why 
are we doing Senate confirmation for someone that the agency is 
picking to be in a relationship with us? So that seems 
nonsensical.
    Now I am not asking for a full list of it, but if you go 
through different positions like that, like the legislative 
affairs individuals and others that are out there, we are 1,200 
some odd at this point now that are going through the process. 
The number, I am not trying to get to a magic number. I am 
trying to look at it.
    As you look through the list, do any of the three of you 
see a number, to say, this is more reasonable based on some of 
these positions that may not need the same kind of Senate 
oversight on it? Is it 800? Is it 900? Is it 1,150? Adam, do 
you want to take that on?
    Mr. White. Yes, although I must admit I do not have a 
number for you.
    Senator Lankford. Yes. But I am not looking for a magic 
number. I am just trying to get a guess.
    Mr. White. Having highlighted the example of the Office of 
Legislative Affairs and other agency offices that do not have 
significant policymaking authority and are primarily either 
ministerial activities on behalf of the agency head or fact 
finding, 25 percent.
    Senator Lankford. Yes, a decent guess. Ms. Simmons, do you 
want to take a guess at that?
    Ms. Simmons. I will. There are 137, approximately, Senate-
confirmed assistant secretary positions. We would recommend 
starting with the presumption that those do not need to be 
Senate-confirmed unless the Senate affirmatively decides they 
need to be because of the responsibilities of the job.
    Right there, if you take the legislative affairs positions, 
you have over a dozen that you would take off the rolls of 
Senate-confirmed.
    Then Professor O'Connell has spoken also about part time 
boards and commissions. There are dozens of them that are 
advisory in nature and we think could easily, without detriment 
to the mission, be converted.
    Senator Lankford. Ms. O'Connell, do you want to be able to 
add into that as well?
    Ms. O'Connell. Thank you, Senator. I think the number is 
below a thousand. Of course, what is desirable is not always 
politically feasible. I would start with the part-time boards.
    Senator, if I could just quickly go back to your paperwork 
question and financial conflicts of interest, I do think there 
is a difference between the nomination phase and what happens 
once someone joins the government and we need to spend more 
time thinking about what happens in that initial phase and how 
that may discourage people from entering government service.
    I do think there is some that could be done with 
streamlining that financial paperwork as that working group in 
2012 indicated. Some of their recommendations are targeted 
toward financial disclosure.
    Senator Lankford. Right. Going through the Presidential 
nomination process is the equivalent of a full-body cavity 
search through everything in your life and everything in your 
history and everything in your finances. It is a brutal process 
for individuals to be able to go through. So people need to 
know if you are going to step into this responsibility there is 
a lot of background that we are going to look at for those 
individuals, rightfully so. But then to discourage them from 
even taking it on or to have to live without an income while 
they go through the process is a very different issue on this.
    One last question that I had on this--I know I have run out 
of time. And that is the issue of how do we incentivize the 
Administration to nominate people. We have had multiple 
administrations in a row that have not nominated, for instance, 
IGs. They will not put someone up. That is a problem. Not only 
do we need to have good oversight of it, but we need 
administrations to actually nominate individuals to these 
roles. We have several roles that there was literally never a 
nomination for.
    What would you suggest as far as leverage or engagement to 
be able to actually make sure we do get nominees for areas 
where we need nominees, Mr. White?
    Ms. O'Connell Senator, I guess I could take that on. I 
mean, right now, as you know, three of the 15 cabinet 
departments do not have a confirmed Inspector General; two of 
those three do not even have a nominee. The number was even 
greater in August 2020, where I believe seven cabinet 
departments lacked a nominee for IG positions.
    So what can be done? I think these positions where they are 
done without regard to partisanship--that is also true for the 
Under Secretary of Health that we have talked about, Ms. 
Simmons talked about, in the Veterans Administration--those 
positions are harder to fill. I think that White Houses turn to 
the more political positions first.
    I think that the Council on IGs with regard to 
recommendations, pressure being placed on the White House, and 
then cabining who gets to serve as an acting IG so we do not 
have some of what we saw in the Trump administration with the 
firing of IGs and then having acting IGs who are not drawn from 
other confirmed IGs or from IG staff but instead of political 
appointees. Whether you are on the left or the right, Congress 
needs IGs who either confirmed or acting, who are nonpartisan, 
doing critical oversight work.
    Senator Lankford. Yes, just to be able to keep this 
nonpartisan as well. The Obama Administration, in eight years, 
had several IG positions they just refused to ever nominate 
someone for, and they did not want the oversight in that area. 
This is a nonpartisan issue, but we do have to have important 
individuals in that spot.
    Mr. White, you were about to say something.
    Mr. White. If I may, the bluntest tool for creating 
incentives for agencies to nominate and fill these positions 
would be to tie to the effectiveness of their substantive 
regulations. Any agency with policymaking power that they try 
to effectuate through rulemaking, any rules, effectiveness 
could be tied to the filling of those offices. Require the 
agency to have the full complement of Senate-confirmed offices 
in place before any new regulations could go into effect. That 
would certainly create an incentive for the agency to act.
    Senator Lankford. OK. Thank you.
    Thank you, Mr. Chairman.
    Chairman Peters. Thank you, Senator Lankford.
    Senator Carper, you are recognized for your questions.

              OPENING STATEMENT OF SENATOR CARPER

    Senator Carper. Thanks very much, Mr. Chairman.
    I want to thank our witnesses--I want to thank Dr. 
O'Connell, Kristine Simmons and Adam White for taking time to 
be with us today and share your thoughts and respond to our 
questions.
    Mr. Chairman and to our witnesses and our colleagues, I am 
getting some flashbacks here. I am thinking of, 10 years ago 
when another Senator from Oklahoma--in that case, Tom Coburn--
and I were privileged to lead this Committee, and we focused a 
whole lot of time and attention on trying to make sure that a 
different administration was able to nominate people to serve 
in leadership positions, especially in Homeland Security, but 
to actually get them confirmed in a bipartisan way.
    This is really important stuff. I am grateful that we are 
doing it and grateful to our witnesses for your help.
    I have really three questions. One would be the need for 
Senate-confirmed at the Federal agencies. Another would be the 
PLUM Act, the bipartisan legislation that I have been 
privileged to have some role in crafting. Third is lessons 
learned from previous administrations' use of acting officials 
and delegations of authority.
    The first question goes to the need for Senate-confirmed 
leadership at Federal agencies. This is a question for all of 
our witnesses. Again, alluding to the time several years ago 
when Senator Coburn and I held a number of hearings that pretty 
much remind me of what we are doing and talking about today. We 
invited witnesses from the Department of Homeland Security to 
come and talk about Swiss cheese, not the kind we eat, though. 
Rather, we were discussing the high number of vacancies or 
acting individuals who were serving in top leadership positions 
at that time in the Department of Homeland Security. They 
reminded us then and reminds me today of Swiss cheese.
    I am concerned. Let me say as a recovering Governor I know 
personally how important, it was to be able to get my team in 
place. We have a tradition in Delaware, a highly bipartisan 
tradition that the Governors for the most part are given the 
opportunity to put their teams together. We seem to have gotten 
away from that here, and it is a matter of concern for--it has 
been a matter of concern for me for a long time through the 
present.
    But we have a similar situation today atop several of our 
Federal agencies and how it impacts agencies' abilities to 
deliver results for everyday Americans.
    A question for all three of you, Professor O'Connell, Ms. 
Simmons, Director White. Could each of you please maybe take a 
minute to discuss how a lack of Senate-confirmed leadership and 
longstanding vacancies atop Federal agencies affect workforce 
morale and the ability of agencies to execute their missions 
and deliver results for the public? Professor O'Connell, do you 
want to lead us off, please, and then Ms. Simmons and then 
Director White?
    Ms. O'Connell. Thank you, Senator. So as you indicate, 
there are detrimental consequences, and very briefly, there are 
two sets of them. The first set, as you know, are performance 
related. Given your experience with the Department of Homeland 
Security and this Committee, in particular with regard to 
Homeland Security, vacancies are a problem and they have been a 
problem in administrations since the Department was created and 
got into business in 2003. Both in Republican and Democratic 
administrations, there have been vacancies in DHS that have 
hurt this country.
    The second bucket of consequences has to do with 
accountability and the Senate's role, is when we have vacancies 
we typically do have acting officials in the Department of 
Homeland Security, but they are less accountable. Sometimes, in 
the last administration, they generated litigation with regard 
to their service and some of their actions ended up being 
struck down because of improper use of the succession 
provisions in the Homeland Security Act.
    Senator Carper. Good. Thank you. Thanks. Thanks, Professor.
    Ms. Simmons, please, the same question.
    Ms. Simmons. I agree with what Professor O'Connell offered. 
I would just say, at the end of the day, having Senate-
confirmed leaders in place promotes more efficient and 
effective administration because decisionmaking is clear, the 
accountability of those people to the Senate is greater and to 
the Congress is greater, and the employees that are working in 
the departments and agencies understand who they are getting 
their marching orders and can execute on the agenda. We think 
it is in the best interest of government to have Senate 
confirmed leaders in place.
    Senator Carper. Government and the people, I would say, 
yes.
    Ms. Simmons. Yes.
    Senator Carper. OK, Director White, same question, please. 
Thank you.
    Mr. White. Thank you. In addition to all that has been 
said, I would say that Senate confirmation has an important 
role to play in the quality of the leadership and management of 
the agency. An administration will choose an agency official 
for a number of reasons. Often they are in alignment with the 
policies of the administration. Of course, those are all 
important for energetic execution, but the quality of 
leadership and day-to-day management is also important and so 
is the character of the nominee, his or her sense of the 
mission of the agency, and also the legal constraints upon the 
agency.
    Those are all considerations that transcend any one 
administration, and it is important for the Senate to be an 
outside check on the instincts of any single administration to 
ensure that the agency over time, from administration to 
administration, is well managed, confidence-inspiring, and 
restrained by the rule of law.
    Senator Carper. Thanks. Thanks, Director White.
    I have another question I am going to ask Professor 
O'Connell and Ms. Simmons to respond to here, and then I am 
going to ask questions for the record for a couple of you as 
well.
    But here is the question for Professor O'Connell and Ms. 
Simmons. Both of you mentioned your support for the legislation 
that is called Periodically Listed Update to Management, a 
bipartisan bill championed in the Senate by Senator Braun, 
Senator Merkley, and myself. This legislation promotes a more 
transparent and accountable Executive Branch by requiring the 
Office of Personnel Management (OPM) to modernize our 
government publication that is known as the Plum Book, which is 
published every four years, serves as the comprehensive 
directory of information for senior policy and management roles 
in the Executive Branch.
    Professor O'Connell and Ms. Simmons, how would passing the 
PLUM Act help tackle the issue of longstanding Federal 
vacancies and ensure that political appointees are well 
qualified for positions to which they have been nominated? 
Please proceed, Professor O'Connell and then Ms. Simmons, and 
then I will be quiet. Thank you.
    Ms. O'Connell. Thank you, Senator. Actually, at the very 
end of this set of books, at the very end are some Plum 
volumes. I have hard copies of the Plum Book.
    I strongly endorse and am so grateful for your work on the 
PLUM Act and support it for various reasons. One is a 
transparency mandate. It is hard to figure out who is serving 
in a critical Senate-confirmed position, and the Plum Book 
includes beyond Senate-confirmed positions, other political 
appointees, as well as positions which are carried out by 
senior career workers in Federal agencies. It is important to 
know who is doing that work or if that work is not getting 
done. The PLUM Act would, in addition to the hard volume which 
I keep in my office, would also continually update that 
information electronically, and that is important.
    Second, with regard to staffing these positions, the PLUM 
Act would make clear which positions have which appointment 
structure, fall into which agency, and, along with good 
government organizations like the Partnership developing job 
descriptions, can help potential nominees, help the 
Presidential Personnel Office in terms of staffing them. I hope 
that Congress will enact the PLUM Act very soon.
    Senator Carper. Professor, thank you so much for those 
words.
    Ms. Simmons, just briefly, same question.
    Ms. Simmons. Thank you, Senator. To echo that, first of 
all, having the PLUM Act enacted would allow for a much more 
efficient process. It would ensure that the Plum Book can be 
updated in real time. Right now, it is a snapshot every four 
years, and there is no possibility to correct errors. The most 
recent Plum Book was published not until December 30th, so well 
after the Presidential election. It was missing in the index 
seven agencies, and there was no way to go back and correct 
that. We think that making it more accessible, more 
transparent, providing better accuracy and more efficiency 
would be very good for transparency and good for government and 
the people it serves.
    Senator Carper. Thank you. Thank you so much. Thank you 
both very much for that.
    Then to our Chair, if I can ask a question. I am not going 
to ask for the response right now. Professor O'Connell, it is 
the last question for the record. When is it appropriate for 
the administration to use acting officials and delegations of 
authority? What are some lessons learned from previous 
administrations' use of these temporary measures that Congress 
should keep in mind as we consider proposals to reform the 
current Senate confirmation process and existing Federal 
vacancy law? Again, Professor O'Connell, if you will do that--
it is for the record--I would be most grateful.
    Thank you all for your testimony. This is something that is 
near and dear to my heart, and I think it is very important, 
for our country. Thank you.
    Chairman Peters. Thank you. Thank you, Senator Carper.
    Senator Hawley, you are recognized for your questions.

              OPENING STATEMENT OF SENATOR HAWLEY

    Senator Hawley. Thank you very much, Mr. Chairman. Thanks 
to all the witnesses for being here. Great to see each of you.
    Professor O'Connell, if I could begin with you. I know that 
this is your field, and I am interested in getting your 
perspective on some of this, particularly some of your 
historical perspective.
    Let me begin, though, with something that you mentioned I 
think in your testimony, and that is in some sense the problem 
of vacancies begins with the Executive Branch. President Trump, 
for instance, if I have my numbers right, he did not nominate a 
single individual for 36 percent of posts. I mean, that is a 
lot. That is a big number. President Obama, similarly, did not 
nominate a single individual for over 25 percent of posts 
during a similar timeframe. That is also a pretty big number. 
What do you think we should infer from that?
    Ms. O'Connell. Senator, thank you for that question. I 
think you could infer several things. First, that there are a 
lot of positions to fill and some positions take priority and 
others do not, and so in the fixed resources, fixed time, some 
positions just do not take a high priority.
    Second, I think you can take that--there is not a lot of 
pressure to fill those positions. Right? As you indicate, 
Senator--and I am quoting here from research by David Lewis and 
Mark Richardson out of Vanderbilt University. Thirty percent of 
positions on average do not receive a single nominee in the 
first two years, looking at the past three completed 
administrations. I think a large part of that is the Federal 
Vacancies Reform Act of 1998. At least for a set of positions, 
where you can have acting officials, the need for Senate-
confirmed person in that position, excuse me, just is not as 
great because you can have an acting official carrying out all 
the duties exclusive and nonexclusive to that Senate-confirmed 
job.
    Then when the time limits run out--and they are very 
generous time limits--what happens in these agencies is you 
have delegations of authority downward for the nonexclusive 
functions. Basically, most of the functions are nonexclusive in 
Federal agencies, and then you have delegations.
    You have at the Department of Homeland Security, across 
Democratic and Republican administrations--you go to that 
leadership page, and you look right now at the under 
secretaries. The majority of them are not Senate-confirmed 
officials, and you have senior officials performing the duties. 
Under these delegations there are no time limits under the 
Vacancies Act. You can have those positions carried out for 
years, for entire Presidential terms, without ever putting 
forward a nominee.
    Senator Hawley. That is very interesting. Do you think is 
one of the takeaways here that maybe the Federal administrative 
apparatus has become so gargantuan that even the person who has 
some directive authority--speaking of the President, but you 
know, it is only some directive authority. But even that person 
does not seem to have an enormous incentive to fill--even he or 
she does not necessarily see the need to fill the entire 
apparatus of an administrative branch that they largely--they 
do not control it of course, but they largely direct or could. 
Yet, they think that they can administer the government, 
rather, without, in President Obama's case, a quarter of 
positions, in President Trump's case, 36 percent.
    I mean, what is your view on that? Is part of the issue 
that the size and scope is just gigantic that it is hard for 
even the President, who has a decided interest in this--it 
would be in their interest, but it is hard for even the 
President to find pressing need to fill these positions, some 
of them?
    Ms. O'Connell. As the economy has changed, we have a large 
administrative state. I think I am more a fan of the 
administrative state than you may be, Senator. But what is 
interesting is that from the 1960s Federal employment has been 
relatively constant. It is not as if the Federal Government has 
expanded in size.
    Now what has happened, research by Professor Paul Light, is 
known as thickening of government, and so you have more of 
these management-type of positions. I am an academic. We see 
this in universities, too, where you have a thickening of the 
management positions and it is not clear that all of those 
management positions are needed. In fact you have greater 
Presidential control if you had fewer of those positions, like 
if the kind of line of accountability was clearer might 
actually be more helpful in terms of the President's interest 
and constitutional role in managing Federal agencies.
    Senator Hawley. That is interesting. Let me ask you--and I 
am probably going to date myself with this next remark and show 
you when I was in law school. But when I was in law school, 
Stephen Skowronek was someone in his work on the administrative 
state and as it related to the political branches and political 
energy. He talked about the waning of political clime in 
America because of, I think, the phenomenon of thickening that 
you just said.
    If I remember--and you could correct me if you know 
Skowronek. And you know, apologies to him if I am terribly 
misrepresenting his work. But my memory of it is that part of 
Skowronek's point is that as the administrative apparatus has 
become thicker, deeper, big, whatever, bigger--I mean, pick 
your adjective of choice--it has become more difficult for 
Presidents--somewhat perhaps, paradoxically, more difficult for 
President to enact their agendas. Of course, it is also more 
difficult for Congress to control these agencies.
    Do you agree with that analysis as I have stated it, in 
rough outline, or do you think that that is off in some 
fundamental way?
    Ms. O'Connell. I think it has to be acknowledged that 
Federal agencies are doing more complex work. When I was 
referring to thickening, I was referring to a different sort of 
thickening. I was referring to the thickening of leadership 
positions----
    Senator Hawley. Right.
    Ms. O'Connell. Like the growth, for example, of assistant 
secretary positions. So we have that.
    Now does that impact Presidential control? That is less 
clear. I think what we have seen in recent administrations on 
the left and on the right is the rise of what now Justice Kagan 
labels a Presidential administration. We have that through 
increasing Presidential directives, whether they are Executive 
Orders (EO) or Presidential memoranda directing Federal 
agencies to take various actions. I think that is a 
counterweight and does allow Presidential control, of course, 
that raises certain concerns, both on the left and the right, 
about the President's role in terms of directing Federal 
agencies when we think about, of course, Congress's role in 
terms of what it delegates and what it wants from Federal 
agencies.
    Senator Hawley. Yes, fair enough. I was going to say my 
time is just about expired. Technically, it has, but one more 
question I will ask this question, and then I will cease and 
desist, Mr. Chairman. I wanted to ask Mr. White to be able to 
weigh in on this, just in terms of the administrative state.
    I mean, my own view, as I was previewing with Professor 
O'Connell, is part of what has happened here is that the 
administrative state it has become so powerful since this body, 
the Congress, delegates so much to the administrative state, 
and there are now so many political positions to fill that even 
Presidents do not find there being a great incentive to fill 
them all.
    Just give us your perspective on this and what you think 
reforms might be. How might we go about thinning this out in a 
way that is constitutionally responsible?
    Mr. White. I agree completely with the point. In my written 
testimony and in my statements earlier, I tried to return time 
and time again to the basic problem of delegation, the problem 
of overbroad delegation exacerbating the issues we are 
discussing.
    Your point about slower and slower execution is right on 
point. In our system, Congress ought to take its time 
legislating, and then once it has made a decision it should 
make a decision that the President and his administration can 
quickly and clearly execute. That is the energy in execution.
    Today, unfortunately, with so much power and discretion 
delegated to the administration, you have the worst of both 
worlds. It takes forever for an administration to formulate the 
policy and then go into execution. We often think of delegation 
as empowering a President. It does in a way, but in terms of 
actual execution it really deforms execution and slows it down.
    Anything that can be done to reduce the breadth of 
discretion of powers delegated at the agency will make 
execution faster, it will take the temperature down on Senate 
confirmation fights, and it will alleviate a number of other 
sort of secondary symptoms of the delegation problem that we 
are grappling with here today and in other issues before the 
Committee.
    Chairman Peters. Thank you, Senator Hawley.
    I would like to take this time to thank our witnesses for 
joining us today for this very important discussion, a 
discussion that I intend to continue to follow through for. We 
are hoping to draft legislation out of this Committee to deal 
with some of these issues, but we want to make sure we have a 
robust discussion among Members of the Committee as well as 
experts like each and every one of you. I appreciate your time 
here today.
    Effective government clearly depends on a reliable and a 
consistent process for filling senior roles. Vacancies in these 
roles lead not only to significant operational and managerial 
risk, but they can also compromise our national security. While 
the Senate must certainly continue to exercise our 
constitutional authority and thoroughly consider nominees' 
qualifications, I remain confident we can better streamline the 
Presidential appointment process to help fill these critical 
positions all across the Federal Government.
    I want to thank my Ranking Member, Senator Portman, for 
holding this hearing with me here today, and I certainly look 
forward to working with him and others on the Committee to 
address this issue in the future.
    The record for this hearing will remain open for 15 days, 
until 5 p.m. on March 18, 2022, for the submission of 
statements and questions for the record.
    Again, thank you for your appearance here today.
    The hearing is now adjourned.
    [Whereupon, at 12:04 p.m., the Committee was adjourned.]

                            A P P E N D I X

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