Human Capital: Implementing an Effective Workforce Strategy Would
Help EPA to Achieve Its Strategic Goals (31-JUL-01, GAO-01-812). 
								 
During the last decade, as most federal agencies downsized, the  
Environmental Protection Agency's (EPA) workforce grew by about  
18 percent. Much of this growth occurred in EPA's 10 regional	 
offices, which carry out most of the agency's efforts to	 
encourage industry compliance with environmental regulations.	 
Currently, EPA's workforce of 17,000 individuals includes	 
scientists, engineers, lawyers, and environmental protection	 
specialists, and mission-support staff. Some Members of Congress 
have questioned whether EPA is giving enough attention to	 
managing this large and diverse workforce. The workforce	 
management practices of EPA's Office of Enforcement and 	 
Compliance Assurance (OECA)--which takes direct action against	 
violators of environmental statutes and oversees the		 
environmental enforcement activities of states--have come under  
particular scrutiny because enforcement activities span all of	 
EPA's programs and regions. Although EPA has began several	 
initiatives during the last decade to better organize and manage 
its workforce, they have not received the resources and senior	 
level management attention needed to realize them. This report	 
reviews the (1) extent to which EPA's strategy includes the key  
elements associated with successful human capital strategies, (2)
the major human capital challenges EPA faces in the successful	 
implementation of its strategy, and (3) how OECA deploys the	 
enforcement workforce among EPA's 10 regions to ensure that	 
federal environmental requirements are consistently enforced	 
across regions either by OECA or by states with enforcement	 
programs that OECA oversees. GAO found that EPA's November 2000  
human capital strategy is a promising first step towards	 
improving the agency's management of its workforce, but it lacks 
some of the key elements that are commonly found in the human	 
capital strategies of high-performing organizations. EPA's major 
challenges in human capital management involve assessing the work
requirements for its employees, ensuring continuity of leadership
within the agency, and hiring and developing skilled staff. OECA 
does not systematically deploy its workforce to ensure the	 
consistent enforcement of federal regulations throughout all EPA 
regions and bases deployment decisions on outdated and incomplete
information regarding key regional workload factors.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-812 					        
    ACCNO:   A01393						        
  TITLE:     Human Capital: Implementing an Effective Workforce       
             Strategy Would Help EPA to Achieve Its Strategic Goals           
     DATE:   07/31/2001 
  SUBJECT:   Environmental monitoring				 
	     Human resources training				 
	     Human resources utilization			 
	     Personnel management				 
	     Personnel recruiting				 
	     Senior Executive Service Candidate 		 
	     Program						 
								 

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GAO-01-812
     
Report to the Ranking Minority Member, Subcommittee on VA, HUD, and
Independent Agencies, Committee on Appropriations, U. S. Senate

United States General Accounting Office

GAO

July 2001 HUMAN CAPITAL Implementing an Effective Workforce Strategy Would
Help EPA to Achieve Its Strategic Goals

GAO- 01- 812

Page i GAO- 01- 812 EPA's Human Capital Letter 1

Results in Brief 3 Background 4 EPA's Human Capital Strategy Is a Promising
First Step but Lacks

Key Elements 7 EPA Faces Agencywide Human Capital Challenges That, if Not

Addressed, Will Limit Its Ability to Achieve Its Mission 10 OECA's Workforce
Deployment Does Not Ensure the Consistent

Enforcement of Environmental Requirements Across Regions 18 Conclusions 24
Recommendations for Executive Action 25 Agency Comments 26

Appendix I Scope and Methodology 28

Appendix II EPA's Structure and Environmental Enforcement Activities 31

Appendix III Information Reported by EPA on the Status of the Agency's Human
Capital Management 35

Tables

Table 1: Objectives and Planned Implementation Actions of EPA's Human
Capital Strategy 8 Table 2: EPA's Strategic Goals 9 Table 3: GAO's Human
Capital Framework 29 Table 4: Status of EPA's Human Capital Management
Activities, as

Reported by Agency Officials 35

Figures

Figure 1: EPA's Total FTEs, by Organizational Unit, Fiscal Years 1990- 1999
5 Figure 2: Geographic Areas Serviced by EPA's Ten Regional Offices 6
Contents

Page ii GAO- 01- 812 EPA's Human Capital

Figure 3: Percentage of Total Senior Executive Service Staff Eligible to
Retire By 2006, By EPA Unit/ Region 13 Figure 4: Percentage of EPA Staff in
Selected Scientific/ Technical

"Critical Occupations" Eligible To Retire By 2006 16 Figure 5: Percentage of
Biological Scientists Eligible to Retire by

Fiscal Year 2006, By EPA Unit/ Region 17 Figure 6: Percentage of Total
Regulated Facilities Inspected Under

the Clean Air Act During Fiscal Year 2000, by EPA Region 20 Figure 7: Number
of State Inspections Under the Clean Water Act

During Fiscal Year 2000 per EPA Staff Available to Oversee Such Inspections,
by EPA Region 21 Figure 8: EPA's Organizational Structure 31

Abbreviations

EPA Environmental Protection Agency FTE Full- time equivalent GAO General
Accounting Office GPRA Government Performance and Results Act OECA Office of
Enforcement and Compliance Assurance OMB Office of Management and Budget OPM
Office of Personnel Management SES Senior Executive Service

Page 1 GAO- 01- 812 EPA's Human Capital

July 31, 2001 The Honorable Christopher S. Bond Ranking Minority Member,
Subcommittee on VA, HUD, and

Independent Agencies Committee on Appropriations United States Senate

Dear Senator Bond: During the past decade, as most federal agencies reduced
their staffing, the Environmental Protection Agency's (EPA) workforce grew
by about 18 percent. Much of this growth occurred in EPA's 10 regional
offices (regions), which carry out most of the agency's actions to encourage
or compel industry compliance with environmental regulations. Currently,
EPA's workforce of scientists, engineers, lawyers, environmental protection
specialists, mission- support staff, and others consists of over 17,000
people across the country, and some Members of Congress have questioned
whether EPA is giving sufficient attention to managing this large and
diverse workforce. Particular interest has been expressed regarding the
workforce management practices of EPA's Office of Enforcement and Compliance
Assurance (OECA)- which takes direct action against violators of
environmental statutes and oversees the environmental enforcement activities
of states- because enforcement activities span all of EPA's programs and
regions. 1

As we reported in March 2000, 2 while EPA has implemented several
initiatives during the past decade to better organize and manage its
workforce, they have not received the resources and senior- level management
attention needed to realize their goals. In June 1998, EPA initiated a study
to assess its workforce. While this study identified the general
competencies, such as communication and computer skills, needed to carry out
EPA's missions, it was not designed to result in a

1 In this report we refer to EPA's activities to enforce environmental
regulations and to encourage industries to voluntarily comply with these
regulations as "enforcement" activities.

2 Human Capital: Observations on EPA's Efforts to Implement a Workforce
Planning Strategy (GAO/ T- RCED- 00- 129, Mar. 23, 2000).

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 01- 812 EPA's Human Capital

workforce planning system for determining how many employees needed such
competencies or how they should be deployed among strategic goals, across
program areas, and in various parts of the country. Building on its
workforce assessment project, in November 2000, EPA developed a strategy to
refine its human capital policies and practices. This strategy identifies
the agency's vision for its employees and six major human capital objectives
for the next 2 years, including the development of a workforce planning
system. In addition, it discusses implementation plans for achieving these
objectives and identifies the agency units responsible for carrying out the
implementation plans.

In response to your continuing interest in EPA's management of its human
capital, we reviewed (1) the extent to which EPA's strategy includes the key
elements associated with successful human capital strategies and (2) the
major human capital challenges EPA faces in the successful implementation of
its strategy. In addition, we reviewed one specific aspect of human capital
management within OECA: how it deploys the enforcement workforce among EPA's
10 regions to ensure that federal environmental requirements are
consistently enforced across regions either by OECA or by states with
enforcement programs that OECA oversees.

To address these issues, we reviewed EPA's human capital strategy and
analyzed the nature and status of EPA's key human capital management
initiatives. We discussed these initiatives with officials of EPA's Office
of Human Resources and Organizational Services, OECA, and each of EPA's 10
regions. In this regard, we asked agency officials to respond to questions
based on GAO's human capital self- assessment "checklist," 3 an assessment
tool that identifies human capital elements and underlying values that are
common to high- performing organizations. We used the checklist as a
framework for organizing and evaluating their responses. Furthermore, we
obtained and analyzed data from EPA's 10 regions on their enforcement
workforce and workload. (See app. I for details on our scope and
methodology.)

3 Human Capital: A Self- Assessment Checklist for Agency Leaders (GAO/ OCG-
00- 14G; Sept. 2000).

Page 3 GAO- 01- 812 EPA's Human Capital

EPA's November 2000 human capital strategy is a promising first step towards
improving the agency's management of its workforce. However, it lacks some
of the key elements that are commonly found in the human capital strategies
of high- performing organizations. EPA's strategy identifies the agency's
vision, core values, and six major human capital objectives for the next 2
years; discusses implementation actions for achieving its human capital
objectives; and identifies the EPA units responsible for carrying out the
actions. Despite these positive features, the strategy does not (1) explain
how achieving its human capital objectives will improve the agency's
performance in meeting its strategic goals for protecting the environment,
(2) identify the resources needed and the specific milestones for
implementing the human capital objectives, or (3) provide results- oriented
(outcome) measures that track the agency's progress and evaluate its success
in achieving these objectives. Filling these gaps in its strategy would
allow EPA to better ensure the most effective use of its workforce. This
report recommends that the Administrator, EPA, link the agency's human
capital strategy to the fulfillment of EPA's strategic goals, identify the
milestones and resources needed to implement the strategy, and establish
results- oriented performance measures for human capital objectives.

Like many other federal agencies, EPA faces major human capital management
challenges in implementing its strategy. These challenges involve assessing
the work requirements for its employees, ensuring continuity of leadership
within the agency, and hiring and developing skilled staff. Specifically,
EPA currently (1) does not know the appropriate size, skills- mix, and
deployment of staff needed to achieve its strategic goals; (2) is unprepared
for the potential loss in leadership and institutional knowledge that is
likely to occur as more than half of its senior executives become eligible
to retire over the next 5 years; and (3) has no systematic means to recruit
and develop staff with the scientific and technical skills needed to
effectively carry out environmental programs. Although EPA's human capital
strategy recognizes these challenges, the agency has yet to implement
actions to meet them. This report recommends that, while developing plans to
implement EPA's human capital strategy, the Administrator, EPA, ensure that
specific actions are taken to remedy problems in the agency's workforce
allocation and deployment system, succession plans, and recruitment and
training practices, consistent with the best practices for these areas
followed by high- performing organizations.

OECA does not systematically deploy its workforce in a way that ensures the
consistent enforcement of federal regulations throughout all EPA Results in
Brief

Page 4 GAO- 01- 812 EPA's Human Capital

regions. In this regard, it bases deployment decisions on outdated and
incomplete information on key regional workload factors. For example,
workforce deployment decisions do not fully consider changes that have
occurred over the past decade in the extent to which states enforce federal
environmental laws. Nor is information available on the amount of time
required for EPA staff to oversee the state enforcement activities. Without
current and complete information on the enforcement workload, OECA cannot
determine the proper size of its enforcement staff relative to the regions'
enforcement workload. As a result, workload imbalances may exist and
contribute to inconsistencies in EPA's enforcement efforts. Furthermore, the
lack of information on the enforcement workload and the current utilization
of staff limit EPA's ability to systematically determine where staffing
increases or reductions- such as the 8- percent reduction proposed for
fiscal year 2002- should be made. This report recommends that the
Administrator, EPA, obtain and use workforceplanning data needed to provide
a firm basis for deploying regional enforcement staff in a manner to ensure
greater consistency and effectiveness in enforcing environmental
requirements. Furthermore, in redirecting enforcement resources to states
and tribes, we recommend that the Administrator, EPA, before reducing the
enforcement staff by 270 positions, collect and review more complete and
reliable workforceplanning information than is currently available on the
enforcement workload and the workforce capabilities of EPA's 10 regional
offices.

EPA is organized into 13 major headquarters offices (including OECA) that
are located in Washington, D. C. (App. II shows EPA's organizational
structure.) These offices receive administrative, investigative, and
laboratory support from numerous headquarters field offices located
throughout the country. 4 EPA also maintains 10 regional offices to
implement federal environmental statutes and to provide oversight of related
state activities. EPA's staff or full time equivalents (FTEs) grew by about
18 percent from fiscal year 1990 through fiscal year 1999 (see fig. 1). 5
Over this period, the staff in EPA's headquarters- including headquarters
field offices located outside of Washington, DC- and its regions grew at

4 EPA's headquarters field offices include scientific laboratories, data
processing centers, and other similar facilities. 5 Full- time- equivalent
(FTE) is a measure of staff hours equal to those of a full- time employee
working 40 hours per week over the course of a year. Background

Page 5 GAO- 01- 812 EPA's Human Capital

about the same pace, with less than half of the agency's total staff located
in the regions.

Figure 1: EPA's Total FTEs, by Organizational Unit, Fiscal Years 1990- 1999

Source: GAO?s analysis of EPA data.

Data from the Office of Personnel Management (OPM) indicate that, as of the
end of fiscal year 2000, about 35 percent of EPA's permanent staff were
located in its Washington headquarters, 17 percent in headquarters field
offices, and 48 percent in its regional offices.

EPA uses contractors to perform much of its work. The agency estimates that
it would need an additional 11,000 to 15,000 employees if it did not receive
appropriations to fund contractors. Therefore, EPA's workforce must be adept
both at delivering services directly and at effectively managing the cost
and quality of services delivered by third parties on the government's
behalf.

OECA, with more than 3,500 FTEs nationwide, is responsible for developing
policies to ensure that industries and other entities that are regulated
under environmental statutes comply with the requirements of the law. Over
2,600 of these FTEs are allocated to implement enforcement

Page 6 GAO- 01- 812 EPA's Human Capital

policies in each of EPA's 10 regions (see fig. 2). The regional enforcement
staff are specifically responsible for (1) inspecting and monitoring certain
industrial and other facilities that are regulated under federal
environmental statutes; (2) taking enforcement actions against those who
have violated environmental statutes and regulations; (3) helping industries
comply with environmental regulations; and (4) overseeing enforcement
activities that EPA has delegated to states. (App. II discusses OECA's
enforcement process and activities in greater detail.)

Figure 2: Geographic Areas Serviced by EPA's Ten Regional Offices

Source: EPA

As reflected in GAO's human capital checklist, our past work has
demonstrated that effective performance- based management depends on

Page 7 GAO- 01- 812 EPA's Human Capital

senior managers' willingness and ability to strategically manage all of the
agency's resources- including its human capital- to achieve its missions and
goals. Specifically, it requires aligning strategic and program planning
systems with explicit strategies for identifying (through workforce
planning) the needed mission- critical competencies, 6 and for recruiting,
hiring, and training leaders and staff to fill identified competency gaps.
These are critical components of effective human capital management and
among the building blocks to achieving an organization's mission and
strategic goals (see app. I).

EPA's human capital strategy is a promising initial effort to develop a
framework for managing the agency's workforce. Nevertheless, it does not
include all of the key elements that we have identified as essential
components of an effective human capital strategy. In this regard, EPA's
strategy does not (1) fully integrate its human capital objectives with its
strategic environmental goals; (2) identify the specific activities,
milestones, and resources needed to implement the strategy; and (3)
establish results- oriented performance measures to track the strategy's
implementation and success. By including these elements in its strategy, EPA
could better ensure that its workforce is deployed to effectively meet its
strategic goals. (App. III summarizes the current status of EPA's human
capital management practices and its efforts to implement its human capital
strategy).

EPA and federal agencies in general have not given adequate attention to
human capital management in the past. However, EPA is among the agencies
that have become more acutely aware of challenges facing the government in
the human capital area and have taken steps to improve their approaches to
building and managing their workforces. EPA's strategy recognizes the
importance of better managing the agency's human capital. As we noted in our
human capital checklist, an agency should develop strategies to enhance the
value of its employees and focus its efforts on the agency's shared vision-
its mission, vision for the future, core values, and goals and objectives.
Overall, EPA's strategy is detailed and addresses most of the issues that we
identified in our checklist. For example, the strategy clearly identifies
the agency's vision for its people, its core values, and six major human
capital goals for the next 2 years, such as attracting and retaining a
highly skilled workforce and improving

6 Competencies are knowledge, skills, and abilities and other
characteristics. EPA's Human Capital

Strategy Is a Promising First Step but Lacks Key Elements

Page 8 GAO- 01- 812 EPA's Human Capital

teamwork and collaboration among its employees. In addition, the strategy
(1) discusses implementation plans, including actions for achieving each of
its six human capital goals; (2) identifies the units within the agency that
are responsible for developing and carrying out the implementation plans;
and (3) for the most part, directly links the implementation plans to each
human capital objective (see table 1).

Table 1: Objectives and Planned Implementation Actions of EPA's Human
Capital Strategy Human Capital Objective Implementation Action EPA attracts
and retains a diverse and highly skilled workforce.

 Develop and implement an agency workforce planning system.

 Develop and implement national and local recruitment strategies based on
workforce plans.

 Develop strategic approaches to retaining employees with critical
expertise and competencies.

 Maximize flexibility in using workplace programs that contribute to EPA's
attractiveness as an employer and that help employees achieve a balance
between work and nonwork life.

EPA's people perform to their highest potential.

 Link employee development to mission needs.

 Instill a culture of continuous learning, ethical behavior, and
professionalism.

 Build effective leadership at all levels within the agency.

 Strengthen EPA's performance management programs to reinforce
accountability at all levels of the organization.

 Identify the effects of implementing the 1: 11 average span of control
(manager- to- staff ratio) and take action to fix problems.

Innovation, creativity, and risk- taking are demonstrated by all EPA people
at all levels of the organization.

 Create and set expectations that innovation, creativity, and risk- taking
are demonstrated by all employees throughout the agency

 Institute new ways to share information on innovations and creative
approaches within EPA and across organizational boundaries.

The respect with which people and their contributions are treated affects
performance, productivity, and retention.

 Fully apply and comply with the Merit Principles in selection, promotion,
development, recognition, and work assignment decisions.

 Institute processes to recognize and embrace differences that each
employee brings to the organization; facilitate the contribution by all
employees to the work of the organization.

 Institute feedback mechanisms that facilitate full and open communication
and accountability at all levels in the agency.

Teamwork and collaboration are routinely practiced with internal and
external partners.

 Build consensus and constructive labor/ management relations through
improved communication and information sharing.

 Improve and support teamwork within organizations and across
organizational boundaries.

EPA's human resources systems are integrated with planning, budgeting, and
accountability processes.

 Institute mechanisms to ensure that workforce impact and support needs are
identified and planned for early in strategic planning, preparations for new
initiatives, and other planning processes.

 Align administrative and support plans and resources with the agency's
mission priorities.

Although the strategy is a positive step towards addressing the agency's key
human capital issues, it falls short in several areas. First, it does not
fully integrate its human capital objectives with the agency's 10 strategic

Page 9 GAO- 01- 812 EPA's Human Capital

goals for protecting human health and the environment. These goals, which
are identified in EPA's strategic plan prepared under the Government
Performance and Results Act (GPRA), are shown in table 2.

Table 2: EPA's Strategic Goals Goal 1 Clean Air

Goal 2 Clean and Safe Water

Goal 3 Safe Food

Goal 4 Preventing Pollution and Reducing Risk in Communities, Homes,
Workplaces, and Ecosystems

Goal 5 Better Waste Management, Restoration of Contaminated Waste Sites, and
Emergency Response

Goal 6 Reduction of Global and Cross- Border Environmental Risks

Goal 7 Quality Environmental Information

Goal 8 Sound Science, Improved Understanding of Environmental Risk, and
Greater Innovation to Address Environmental Problems

Goal 9 A Credible Deterrent to Pollution and Greater Compliance with the Law

Goal 10 Effective Management

While EPA acknowledges the importance of effectively managing the agency's
staff to meet its strategic goals, it does not describe how various human
capital activities will help the agency to achieve these goals. EPA
officials told us that, in updating the agency's strategic plan, they will
integrate EPA's human capital objectives and strategies with specific
strategic environmental goals. Under GPRA, the strategic plan must be
updated by September 30, 2003, and may be updated earlier at EPA's
discretion. EPA officials told us that they have not yet made a decision on
whether to update the plan before the date required under GPRA.

Second, EPA has not identified the specific activities or time required to
implement its strategy. EPA's strategy identifies 18 implementation actions
and related tasks for achieving its six human capital objectives. For
example, to achieve the human capital objective of attracting and retaining
a diverse and highly skilled workforce, EPA's strategy contains an action to
develop and to implement a workforce planning system. One of the general
tasks for developing this system is to establish standardized workforce
planning requirements and a methodology to be used throughout the agency.
During 2001, EPA plans to undertake tasks related to 11 of the 18
implementation actions. However, EPA's strategy does not identify specific
milestones for completing any of the implementation actions or their related
tasks.

Page 10 GAO- 01- 812 EPA's Human Capital

Finally, like many other federal agencies, EPA has found it difficult to
establish results- oriented performance measures to track the implementation
of the strategy and its success in meeting human capital objectives. EPA's
fiscal year 2002 annual performance plan and budget justification identifies
a number of performance measures for its workforce improvement activities
under the "Effective Management" strategic goal. These measures include,
among others, the number of (1) interns hired, (2) candidates in the Senior
Executive Service (SES) Candidate Program, and (3) competencies addressed
through training and development activities. While these measures are useful
for tracking EPA's progress, they do not reflect the programmatic outcomes
that the agency would like to achieve as a result of investing in human
capital improvements for the strategic goal. As we, the Office of Personnel
Management, and others have found, federal agencies in general have
experienced difficulties in defining practical, meaningful measures that
assess the effectiveness of human capital management. Yet, such measures are
crucial to effectively managing for results and holding managers
accountable. EPA officials told us that they plan to develop specific
outcome measures, although they have yet to establish time frames for doing
so.

EPA has begun to recognize the importance of strategic human capital
management to mission accomplishment and has taken steps to align the
agency?s human capital with its mission. However, EPA, like many other
agencies, still faces serious challenges that will require the sustained
attention and commitment of its leaders. As EPA takes steps to implement its
human capital strategy, it will face a number of challenges throughout the
agency with regard to assessing workforce requirements, ensuring continuity
of leadership, and hiring and training skilled staff. Specifically, EPA has
not determined the number of employees it needs to accomplish its strategic
goals, the competencies and technical skills they should possess, and the
deployment of its current and future workforce among strategic goals, across
program areas, and in various areas of the country. In addition, EPA has not
prepared for the anticipated losses in leadership, institutional knowledge,
and expertise that will likely occur as potentially large numbers of its
senior executives retire in the near future. Nor has the agency fully
addressed the need to maintain and develop mission- critical skills in areas
such as environmental protection, environmental engineering, toxicology, and
ecology. EPA Faces

Agencywide Human Capital Challenges That, if Not Addressed, Will Limit Its
Ability to Achieve Its Mission

Page 11 GAO- 01- 812 EPA's Human Capital

High- performing organizations identify their current and future human
capital needs- including the appropriate number of employees, the key
competencies for mission accomplishment, and the appropriate deployment of
staff across the organization- and then create strategies for identifying
and filling the gaps. To better plan for meeting the agency's future human
capital needs, in June 1998, EPA initiated a study to identify the
competencies needed to meet the agency's current and future missions. While
a positive step, the study (completed in May 1999) identified only general
competencies for all EPA employees, such as effective communication and
collaboration. However, the study did not determine the number of employees
with the identified competencies needed either agencywide or in individual
organizational or geographical units.

Since completing its study, EPA has made little progress in determining the
right size, skills needs, or deployment of its workforce to achieve its
strategic goals. As a result, it lacks the detailed information needed to
make informed workforce deployment decisions, including information on (1)
the relationship between its budget requests for full- time- equivalents
(FTEs) and its ability to meet individual strategic goals and (2) any
excesses or gaps in needed competencies within the agency's various
headquarters and field components.

As part of EPA's recent human capital strategy, the agency plans to develop
and to implement a workforce planning system. The strategy calls for (1)
linking workforce planning to the agency's strategic planning efforts, (2)
securing essential competencies by recruiting and developing staff and
providing incentives to retain highly competent employees, (3) continually
monitoring and assessing the workforce, and (4) evaluating the effectiveness
of actions taken. EPA officials told us that the agency received 20 percent
less funding than requested for workforce planning in fiscal year 2001. With
these funds, EPA has benchmarked other federal agencies' workforce planning
activities and is investigating the possibility of partnering with another
agency to develop a model for workforce planning.

The importance of taking such actions is emphasized in the Office of
Management and Budget's (OMB) May 8, 2001, bulletin on "Workforce Planning &
Restructuring." 7 As a first step toward restructuring federal

7 Workforce Planning and Restructuring, Bulletin No. 01- 07, Office of
Management and Budget, May 8, 2001. EPA Has No Systematic

Means for Assessing Workforce Needs

Page 12 GAO- 01- 812 EPA's Human Capital

workforces to streamline federal organizations, OMB asked agencies to
identify, by June 29, 2001, supervisors and managers by occupational title,
grade level, location, and the number of people that they oversee; evaluate
the skills of the workforce; and provide demographics of the workforce by
age, grade, retirement eligibility, and expected retirements over the next 5
years. However, because EPA has not yet performed a comprehensive workforce
assessment, EPA human resource managers told us that they relied on past
work, such as its workforce assessment project completed in 1999, and
information provided by its headquarters and regional offices to meet OMB's
June 2001 deadline. According to these managers, while this analysis
provides a valuable "snapshot" of EPA's workforce and serves as a starting
point for a detailed workforce assessment, it is not as comprehensive as the
workforce planning effort the agency plans to conduct under its human
capital strategy. Because EPA submitted its analysis to OMB as this report
was being processed, we were unable to obtain and review it in time to
include our evaluation of it in this report.

While such information provides a general overview of the structure of EPA's
workforce, EPA cannot ensure the accuracy of this information or the
reliability of the information systems it uses for its human capital
management. The agency has no reliable means to determine how its employees
spend their time- information that is critical to assessing an agency's
workforce requirements. In March 2000, we reported that EPA needs to more
accurately determine how employees spend their time in order to ensure that
they are being used for designated purposes. We pointed out that EPA
officials had yet to assess the accuracy of the data collected under its
cost accounting system, which it used to determine the number of FTEs that
the agency devotes to each of its strategic goals and objectives.
Furthermore, in November 2000, EPA's Inspector General noted that EPA needed
to follow through on improving its cost accounting systems and that
resources that EPA headquarters budgeted for environmental programs should
be controlled and accounted for- including better tracking of how employees
spend their time- to ensure that they are being used for designated
purposes. Without accurate workforce data, EPA cannot determine (1) the
appropriate number of people and competencies needed to effectively
accomplish its mission or (2) the costs of carrying out its strategic goals
and objectives.

Page 13 GAO- 01- 812 EPA's Human Capital

Agencies need to aggressively pursue comprehensive succession planning and
executive development actions to address the potential loss of leadership
continuity, institutional knowledge, and expertise in the Senior Executive
Service (SES) ranks. These actions include (1) developing a formal
succession plan based on a review of the agency's current and emerging
leadership needs in light of its strategic and program planning, and (2)
identifying sources of executive talent both within and outside the agency.
However, EPA does not currently have in place a succession plan to ensure
continuity in the agency's leadership and to prepare for the management
losses that will likely occur as potentially large numbers of its senior
executives retire in the near future.

Fiscal year 2000 data on EPA?s workforce indicate that 57 percent of the
agency's 255 senior executives are eligible to retire before fiscal year
2006. As shown in figure 3, potential retirements may create particularly
severe shortages in some EPA units and regions, such as Region 8 (Denver) in
which up to 83 percent of executives are eligible to retire over the next 5
years.

Figure 3: Percentage of Total Senior Executive Service Staff Eligible to
Retire By 2006, By EPA Unit/ Region

Source: GAO?s analysis of OPM data.

EPA human resource managers believe that the agency is adequately prepared
for a potentially large number of retirements in the near future. EPA Is Not
Prepared for

the Potential Loss of Leadership and Institutional Knowledge

Page 14 GAO- 01- 812 EPA's Human Capital

These managers told us that, in general, EPA has 7 to 10 qualified and
experienced candidates within the agency for each SES position advertised,
as well as a pool of qualified external candidates. Historically, according
to these managers, SES recruitment efforts draw from 30 to 50 applicants for
each vacancy, many of whom are internal candidates. Nevertheless, EPA
currently has no formal succession plan based on a comprehensive workforce
assessment, which could provide it greater assurance of leadership
continuity.

EPA has initiated a number of activities aimed at ensuring the continuity of
its leadership, such as establishing an SES mentoring program and beginning
a review of executive succession needs. In addition, under its human capital
strategy, EPA plans to reinstitute an SES candidate program and develop a
leadership succession- planning program. In these endeavors, as in many of
the other positive efforts under EPA's human capital strategy, the agency
has made limited progress and it is too early to determine whether its
initiatives will be successful.

While EPA acknowledges that it faces significant challenges in maintaining a
workforce with the highly specialized skills and knowledge required to
accomplish the agency's work, it has yet to fully address the need to hire
and develop staff with mission- critical skills in key technical areas. In
order to function as a high- performing organization, an agency needs to
hire and retain a dynamic, results- oriented workforce with the talents,
multidisciplinary knowledge, and up- to- date skills to ensure that it is
equipped to achieve its mission. Similarly, it is crucial that agencies
invest in training and developing staff to develop mission- critical skills.
However, EPA currently has neither a recruiting and hiring strategy that is
targeted to fill identified gaps in skills, nor a training and employee
development strategy that explicitly links the agency's curricula with the
specific technical skills needed to achieve the agency's mission.

Moreover, as discussed above, EPA has not yet completed the crucial first
step in developing these strategies: identifying the agencywide critical
skills needed for mission accomplishment, the number of needed staff with
these skills, and their appropriate geographical and organizational
locations. According to EPA officials, once this effort is completed it will
serve as the basis for targeted recruitment and training strategies to fill
the identified gaps. However, EPA's human resource managers do not know when
the workforce assessment will be completed. EPA's Recruiting and

Training Policies Do Not Fully Address Potential Shortages in
MissionCritical Skills

Page 15 GAO- 01- 812 EPA's Human Capital

Although the agency has not completed its assessment of skills, it has
identified a number of "critical occupations" that are needed to achieve its
mission. These include, among others, environmental protection specialists,
general biological scientists, ecologists, toxicologists, environmental
engineers, general physical scientists, and health physicists. The
scientists in these seven job categories accounted for 45 percent of EPA's
total staff of almost 18,000 employees at the end of fiscal year 2000. About
20 percent of these scientists will be eligible for retirement before fiscal
year 2006.

The National Research Council recently reported on EPA's difficulty in
managing its scientific workforce. The Council pointed out that EPA's
scientific performance has been criticized many times in reports released by
the Council, EPA's Science Advisory Board, GAO, and other organizations and
"in countless criticisms and lawsuits from stakeholders with interests in
particular EPA regulatory decisions." While noting EPA's significant
improvements during the past decade in some of its scientific practices, the
Council expressed concerns about EPA's science capabilities, including its
ability to attract first- rate talent. For example, it concluded that hiring
freezes within the agency and intense job market competition from the
private sector and academic institutions have made it "extremely difficult"
to recruit or even retain the talent needed to sustain and enhance its
research workforce.

The shortage in mission- critical staff could worsen as scientists reach
retirement age and consider leaving the agency. Over the next 5 years, for
example, EPA faces the potential loss of much of the technical expertise,
which it needs to achieve its strategic goals, as potentially large numbers
of the agency's scientists in some key technical areas become eligible to
retire. Figure 4 shows the percentage of EPA staff in each critical
occupation who will be eligible to retire by fiscal year 2006.

Page 16 GAO- 01- 812 EPA's Human Capital

Figure 4: Percentage of EPA Staff in Selected Scientific/ Technical
"Critical Occupations" Eligible To Retire By 2006

Source: GAO?s analysis of OPM data.

Furthermore, some EPA organizational units may be more severely affected
than others by the impending retirements of staff with critical scientific
and technical skills. For example, figure 5 shows the effects of potential
retirements of biological scientists on EPA's organizational units.

Page 17 GAO- 01- 812 EPA's Human Capital

Figure 5: Percentage of Biological Scientists Eligible to Retire by Fiscal
Year 2006, By EPA Unit/ Region

Source: GAO?s analysis of OPM data.

EPA can fill the gaps in scientific and technical skills that may arise from
these pending retirements through (1) targeted recruiting efforts to hire
outside expertise and (2) training to ensure that current staff develop the
needed technical skills. EPA has continued its recruitment efforts in recent
years, placing emphasis on achieving diversity goals. Furthermore, while EPA
acknowledges the need to invest in EPA employees through training, it has
yet to develop an employee development strategy to meet specific scientific
and technical skill gaps. EPA's Office of Inspector General emphasized the
need for such a strategy in November 2000, when it identified EPA's training
and employee development as a fiscal year 2000 management control weakness.

To address these concerns, EPA proposes to directly link employee
development to mission needs by, among other actions, developing and testing
a rotational assignment program and implementing a workforce development
strategy. However, EPA received no funding in fiscal year 2001 for the
rotational assignment program and its workforce development strategy aims to
enhance general competencies, such as communication and collaboration,
rather than specific mission- critical technical skills.

Page 18 GAO- 01- 812 EPA's Human Capital

Managing EPA's enforcement workforce is particularly challenging because
enforcement activities pervade the agency's programs and regions.
Enforcement responsibilities are centralized within OECA, which is
responsible for monitoring the compliance of facilities regulated by federal
environmental laws and ensuring that violations are reported and that
actions are taken against violators when necessary. OECA provides overall
direction on enforcement policies to the regions, which carry out
enforcement actions and oversee the enforcement activities of states that
EPA has authorized to enforce federal environmental regulations. While OECA
recognizes that the regions need to maintain an appropriate level of
consistency in enforcing requirements and overseeing state enforcement
programs, it acknowledges that some regional variation in environmental
enforcement activities is to be expected for a number of reasons. For
example, differences exist in (1) the opinions of enforcement staff about
the best way to achieve compliance with environmental regulations and (2)
state laws and enforcement authorities and the manner in which individual
regions respond to such differences. In addition, OECA's decisions on how to
deploy its enforcement staff to the regions can affect its ability to ensure
the consistent enforcement of federal environmental requirements throughout
the country. In this regard, we found that OECA's deployment decisions are
hampered by two interrelated problems:

 Workforce deployment decisions do not fully consider workload changes that
are known to have occurred over the past decade, such as the number of
regulated facilities in individual regions that are subject to environmental
inspections.

 Information is not collected and analyzed for key regional workload
factors, such as the extent to which specific enforcement- related functions
are performed and the time required to perform them.

Without such information, OECA cannot determine the appropriate size,
skills- mix, and location of the regional enforcement staff needed to ensure
that regulated industries receive consistent, fair, and equitable treatment
throughout the nation. OECA also cannot ensure effective oversight of state
programs, which share with EPA responsibility for enforcing federal
environmental requirements. Furthermore, without this information, OECA has
no basis for systematically determining where staffing increases or
reductions- such as the 8- percent reduction proposed for fiscal year 2002-
should be made. OECA's Workforce

Deployment Does Not Ensure the Consistent Enforcement of Environmental
Requirements Across Regions

Page 19 GAO- 01- 812 EPA's Human Capital

OECA deploys its enforcement workforce largely on the basis of outdated
workload models that were developed over a decade ago and not updated since
1989. In general, the workload models were based on the number of regulated
facilities in each region and the type and amount of enforcement activities
required for a particular program. While the workload models may have been
an appropriate tool for allocating enforcement personnel during the 1980s,
many critical changes affecting the enforcement workload have occurred over
the past decade. Since the workload models were developed, (1) the number of
environmental laws, regulations, and programs has increased; (2) the focus
and requirements of several environmental programs have shifted; (3) states
have assumed a greater role in environmental enforcement; and (4)
technological advances have affected the skills and expertise needed to
conduct enforcement actions. OECA officials told us that they are currently
examining how OECA?s headquarters resources can best be deployed to meet
their strategic goals and are working to develop a more comprehensive plan
for deploying enforcement resources in the regions.

EPA regions currently vary in the extent to which they enforce environmental
requirements and oversee state enforcement activities. For example, as
figure 6 indicates, the number of inspections conducted under the Clean Air
Act in fiscal year 2000 relative to the number of facilities in each region
subject to EPA's inspection under the act varied from a high of 80 percent
in Region 3 to a low of 27 percent in Regions 1 and 2. OECA's Enforcement

Workforce Deployment Is Not Based On Current Workload Information

Page 20 GAO- 01- 812 EPA's Human Capital

Figure 6: Percentage of Total Regulated Facilities Inspected Under the Clean
Air Act During Fiscal Year 2000, by EPA Region

Source: GAO?s analysis of EPA data.

Furthermore, the number of regional enforcement staff available to oversee
state programs varies significantly among the 10 regions, raising questions
about some regions' ability to provide consistent levels of oversight. As
figure 7 indicates, differences exist in the number of state inspections
performed in relation to individual OECA staff assigned to monitoring
activities, which include overseeing state activities.

Page 21 GAO- 01- 812 EPA's Human Capital

Figure 7: Number of State Inspections Under the Clean Water Act During
Fiscal Year 2000 per EPA Staff Available to Oversee Such Inspections, by EPA
Region

Source: GAO?s analysis of EPA data.

While federal and state enforcement officials agree that basic enforcement
activities should be largely consistent, some variation among regions is to
be expected and, under certain circumstances, encouraged. According to EPA,
for example, differences are appropriate in how each region targets its
resources to address the most significant compliance issues in the region.
However, OECA has not determined whether and to what extent variations in
enforcement activities across regions represent (1) an exercise of
flexibility in adapting national program goals to local circumstances or (2)
a deployment problem that needs to be analyzed and remedied.

OECA cannot fully determine the causes and appropriateness of the variations
in regional enforcement activities because it does not have complete and
reliable workforce planning information on these activities. Specifically,
OECA does not have accurate information on (1) the universe of entities
subject to regulation under federal environmental laws and (2) the time
required to perform enforcement- related activities, such as assisting
facilities to comply with environmental regulations.

Determining the size of the universes regulated under various environmental
statutes is a difficult process that relies heavily on the OECA Lacks
Sufficient

Enforcement Information

Page 22 GAO- 01- 812 EPA's Human Capital

accuracy of EPA's data systems. However, the reliability of these systems
has been challenged from sources both inside and outside of the
organization. The universes regulated under various EPA statutes are based
on state- provided information that is subject to change as companies are
created, go out of business, reach thresholds for chemical emissions that
bring them under EPA's regulatory authority, or reduce their emissions of
certain chemicals to levels that are not subject to regulation. Furthermore,
many state enforcement programs maintain their own databases to manage their
programs and do not use EPA's national databases. Consequently, keeping the
information in the EPA databases current has been a low priority for the
states in an environment of limited resources. In March 2001, OECA
recognized the seriousness of providing inconsistent information when
reporting universes and their sizes and initiated efforts to improve the
data. OECA also recognized that determining the universe of regulated
entities under individual statutes will be difficult because of the
complexities of environmental regulations and the number of entities
involved- approximately 41 million entities ranging from community drinking
water systems to pesticide users to major industrial facilities. Once it
completes its initial efforts, OECA plans to periodically review its data to
keep the universes as current as possible.

In addition, OECA headquarters and regional managers agree that to develop
an accurate workforce planning system, key fact- based information is
essential to enable managers to account for the time of their enforcement
staff. The data most needed include the amount of time spent in performing
inspections, providing oversight of state inspections, assisting states and
industrial facilities to comply with environmental requirements, and taking
various legal actions when necessary to require compliance. Such managerial
accounting information is generally not available to OECA's managers.

The lack of such workforce planning information limits OECA's ability to
determine whether regions and states are consistently meeting the
requirements of EPA's enforcement program and whether significant variations
from these requirements exist and should be corrected. Limitations in OECA's
data on its regional activities also hamper its ability to assess the number
of staff it needs; the knowledge, skills, and abilities they should possess;
and where they should be deployed. With such information OECA could ensure
that the right number and types of people are being hired during times of
growth and that they are systematically allocated among programs and
locations according to need. The information is also needed when operations
are being downsized to ensure

Page 23 GAO- 01- 812 EPA's Human Capital

that staff reductions can be absorbed with minimal impacts on the
effectiveness of operations.

The administration's fiscal year 2002 budget request for enforcement
activities illustrates the importance of having accurate enforcement
information that can be used to inform workforce decisions. The
administration proposes a new grant program under which it intends to
redirect $25 million of funding for enforcement activities. Rather than
using these funds to perform its enforcement activities, EPA would provide
the funds to states and tribes for their enforcement efforts. An April 2001
internal OECA memorandum indicated that EPA did not expect that all states
would receive grants. According to this memorandum, the agency believed that
grants should be awarded based on the quality of state proposals, and
estimated that approximately 15 to 25 states would receive none of this
additional funding. However, subsequently, OECA received comments on the
proposal from states and tribes and in July 2001, OECA officials told us
that they are reconsidering their initial approach for awarding the grants.
The agency is currently developing guidance that will address how the grants
will be awarded.

As part of the administration's proposal, EPA would reduce its enforcement
staff by 270 people, or about 8 percent. EPA officials told us that staffing
for OECA's headquarters and the regions will be reduced by about 51 FTEs and
219 FTEs, respectively. The staff reductions within the regions will likely
be proportional to the number of staff currently assigned to them (that is,
a region employing 10 percent of EPA's total regional enforcement staff
would absorb 10 percent of the regional reductions, or about 22 FTEs).
However, as we have noted, EPA allocates its regional enforcement staff on
the basis of outdated information. EPA contends that it can absorb the staff
reductions without jeopardizing its ability to effectively perform
enforcement activities and to oversee the state programs to ensure that they
consistently and fairly enforce environmental laws and regulations across
the nation. However, without accurate workforce planning information on
factors such as the amount of time required to perform inspections and
oversight functions, EPA cannot demonstrate that the staff reductions will
be absorbed without impairing its effectiveness. Furthermore, in some
states, particularly those states that may not receive additional grant
funds, it is possible that the level of enforcement activity may actually be
reduced as a result of the grant program.

Page 24 GAO- 01- 812 EPA's Human Capital

EPA, like most federal agencies, has not consistently made strategic human
capital management an integral part of its strategic and programmatic
approaches to accomplishing its mission. Nonetheless, to its credit, EPA
recently has recognized the importance of strategic human capital
management, and is now in a good position to move forward during the next
few years toward implementing the human capital practices that are
associated with high performing organizations. Although EPA has recently
made substantial progress in developing a strategy to more effectively
manage its workforce, substantial issues remain and must be addressed to
increase the likelihood of the strategy resulting in tangible programmatic
results. One such issue involves integrating human capital objectives with
EPA's strategic environmental goals to ensure that implementing these
objectives will bear directly on the fulfillment of the strategic goals.
Other issues that need to be addressed include determining when and at what
cost the human capital strategy will be implemented and how its success will
be measured.

EPA's human capital strategy recognizes the need to deal with the major
human capital management areas, such as workforce planning and employee
development, that pose substantial challenges to its success. Previous
initiatives to confront some of these challenges, such as obtaining accurate
workforce planning data and attracting top- level scientists for the
agency's research programs, have met with only limited success. Effectively
implementing a strategy to overcome such challenges in a large and complex
organization like EPA is not something that can be done quickly or easily.
EPA will need to formulate appropriate remedies, and senior managers will
need to provide sustained attention and commitment to providing sufficient
priority and resources needed to carry out the corrective actions.

EPA's enforcement activities, carried out by OECA, have changed greatly
during the past decade as new environmental laws were enacted; the focus of
existing environmental programs has changed; and the states have assumed a
greater role in enforcing federal environmental regulations. The impact of
these changes on the enforcement workload cannot be determined because OECA
does not have complete and reliable data on the specific enforcement
functions performed by regional staff and the time required to perform them.
Without such data, it is not possible for OECA to strategically deploy its
staff to ensure that enforcement activities are performed more consistently
throughout the nation. (Similarly, other EPA entities might benefit from
such data for their respective activities.) Conclusions

Page 25 GAO- 01- 812 EPA's Human Capital

The need for complete and reliable data on the agency's regional enforcement
workload, functions, and capabilities is highlighted by the administration's
proposal to use $25 million of EPA's fiscal year 2002 budget for a new
enforcement grant program and to eliminate 270 of EPA's enforcement staff
positions. EPA currently cannot tailor such staff reductions in a manner to
minimize potential adverse impacts on its enforcement program because it has
no basic workforce- planning information on the number of enforcement staff
it needs; the knowledge, skills, and abilities they should possess; and
where they should be deployed.

To ensure that EPA's human capital policies and practices are most
effectively directed toward achieving the agency's mission, we recommend
that the Administrator, EPA, build upon the agency's substantial progress in
more effectively managing its workforce by revising the agency's human
capital strategy to (1) link the strategy's action steps with the
fulfillment of EPA's strategic goals, (2) identify the milestones and needed
resources to implement the strategy, and (3) establish results- oriented
performance measures to determine progress toward meeting the strategy's
objectives.

Furthermore, as EPA implements its human capital strategy over the next few
years, we recommend that the Administrator better align the strategy with
those of high- performing organizations by working toward

 developing a system for workforce allocation and deployment that is
explicitly linked to the agency's strategic and program planning efforts and
that is based on systematic efforts of each major program office to
accurately identify the size of its workforce, the deployment of staff
geographically and organizationally, and the skills needed to support its
strategic goals;

 designing succession plans to maintain a sustained commitment and
continuity of leadership within the agency based on (1) a review of current
and emerging leadership needs and (2) identified sources of executive talent
within and outside the agency;

 targeting recruitment and hiring practices to fill the agency's short- and
long- term human capital needs and, specifically, to fill gaps identified
through EPA's workforce planning system; and

 implementing training practices that include (1) education, training, and
other developmental opportunities to help the agency's employees build the
competencies that are needed to achieve EPA's shared vision, and (2) an
explicit link between the training curricula and the competencies needed for
mission accomplishment. Recommendations for

Executive Action

Page 26 GAO- 01- 812 EPA's Human Capital

In addition, to ensure that OECA deploys its resources most effectively and
efficiently to achieve the agency's strategic goals for enforcement, we
recommend that the Administrator, EPA, establish, within the context of the
agency's human capital strategy, a systematic method for deploying resources
to address the agency's enforcement workload in the regions. An effective
methodology should take into account the workforceplanning information
needed to analyze the enforcement workload and the workforce capabilities of
its 10 regions. Specifically, this would include information on (1) the
level of resources (FTEs) that are currently being allocated to specific
enforcement activities; (2) the factors that determine the enforcement
workload in each region, including, among others, the size of the regulated
universe and the extent to which states conduct enforcement/ compliance
activities that would otherwise be EPA's responsibility; (3) the specific
skills that are needed to address each region's enforcement workload and the
number of employees in each region who currently possess such skills. To
develop such a methodology, OECA needs to establish mechanisms for obtaining
more complete and reliable data on these factors. Furthermore, this
methodology would be most effective if it were linked to agencywide
recruiting, hiring, and training policies and practices in order to fill
identified gaps in the skills needed to perform effective enforcement
actions.

Finally, in redirecting enforcement resources to states and tribes, we
recommend that the Administrator, EPA, before reducing the enforcement staff
by 270 positions, collect and review more complete and reliable workforce-
planning information than is currently available on the enforcement workload
and the workforce capabilities of EPA's 10 regional offices.

We provided EPA with a draft of this report for review and comment. EPA
officials, including the Acting Deputy Director, Office of Human Resources
and Organizational Services and the Director, Administration and Resources
Management Support Staff, Office of Enforcement and Compliance Assurance,
provided comments on the draft. These officials generally agreed with our
findings and recommendations and offered a number of detailed
clarifications, which we have incorporated where appropriate.

As arranged with your office, we plan no further distribution of this report
for 10 days from the date of this letter unless you publicly announce its
contents earlier. At that time, we will send copies to the Chairman,
Subcommittee on VA, HUD, and Independent Agencies, Senate Committee Agency
Comments

Page 27 GAO- 01- 812 EPA's Human Capital

on Appropriations; the Chairmen and Ranking Minority Members of the Senate
Committee on Environment and Public Works and the House Committee on Energy
and Commerce; other interested Members of Congress; the Administrator, EPA;
the Director of the Office of Management and Budget; and other interested
parties. We will make copies available to others upon request. The letter
will also be available on GAO's home page at http:// www. gao. gov.

If you have any questions about this report, please contact me at (202) 512-
3841 or Edward Kratzer at (202) 512- 6553. Key contributors to this report
were Vincent P. Price, Bernice Dawson, Alyssa Hundrup, Ken McDowell, Ellen
Rubin, and Gregory Wilmoth.

Sincerely yours, John B. Stephenson Director, Natural Resources

and Environment

Appendix I: Scope and Methodology Page 28 GAO- 01- 812 EPA's Human Capital

Our objectives for this review were to determine (1) the extent that EPA's
strategy to improve its human capital management includes the key elements
associated with successful human capital strategies, (2) the major human
capital challenges facing EPA in successfully implementing its strategy, and
(3) the extent to which EPA's deployment of its enforcement workforce
ensures that federal environmental requirements are consistently enforced
across regions. To address the first two objectives, we reviewed the EPA
publication ?Investing in Our People: EPA's Strategy for Human Capital, 2001
through 2003,? and analyzed information on the nature and status of EPA's
key human capital management initiatives. In this regard, in July and August
2000, we asked agency officials in EPA's Office of Human Resources and
Organizational Services, Office of Enforcement and Compliance Assurance, and
each of its ten regions to respond to questions based on GAO's human capital
selfassessment "checklist" and used the checklist as a structure for
organizing and evaluating their responses. 1 The checklist is an assessment
tool that identifies the key human capital elements and underlying values
that are common to high- performance organizations (see table 3). 2 We also
obtained information from EPA's Office of Human Resources and Organizational
Services on the status of the agency's efforts to implement the strategy.

1 Human Capital: A Self- Assessment Checklist for Agency Leaders (GAO/ OCG-
00- 14G; Sept. 2000). 2 See also Human Capital: Key Principles From Nine
Private Sector Organizations

(GAO/ GGD- 00- 28, Jan. 31, 2000). Appendix I: Scope and Methodology

Appendix I: Scope and Methodology Page 29 GAO- 01- 812 EPA's Human Capital

Table 3: GAO's Human Capital Framework Strategic Planning Establish the
agency's mission, vision for the future, core

values, goals and objectives, and strategies.

 Shared vision

 Human capital focus

Organizational Alignment Integrate human capital strategies with the
agency's core

business practices.

 Improving workforce planning

 Integrating the human resources function

Leadership Foster a committed leadership team and provide for reasonable
continuity through succession planning.

 Defining leadership

 Building teamwork and communications

 Ensuring continuity

Talent Recruit, hire, develop, and retain employees with the skills needed
for mission accomplishment.

 Recruiting and hiring

 Training and professional development

 Workforce deployment

 Compensation

 Employee- friendly workplace

Performance Culture Empower and motivate employees while ensuring
accountability and fairness in the workplace.

 Performance management

 Performance incentives

 Continuous learning and improvement

 Managers and supervisors

 Job processes, tools, and mission support

 Information technology

 Inclusiveness

 Employee and labor relations

Finally, to determine the extent to which EPA's deployment of its
enforcement workforce ensures that federal environmental requirements are
consistently enforced across regions, we obtained and analyzed data from
EPA's 10 regions on their enforcement workforce and workload. In this
regard, from August through November 2000, we worked with enforcement
officials and staff in OECA's headquarters office and EPA's Region 4 to
develop a comprehensive instrument to obtain information by major program
on, among other factors, (1) the number and type of each region's regulated
facilities, (2) the nature and number of individual enforcement activities
(such as inspections and oversight activities) conducted in each region by
EPA and the states, and (3) the number of staff conducting these activities.
We received and began analyzing information from most regions in January and
February 2001. Our analysis showed that, overall, the data were incomplete
and inconsistent across regions and programs because of differences in
definitions, reporting

Appendix I: Scope and Methodology Page 30 GAO- 01- 812 EPA's Human Capital

requirements, and states' willingness to provide data voluntarily. For these
reasons, we were generally unable to rely on these data for drawing
conclusions relating to EPA's enforcement workforce and workload. As an
alternative, for our analysis on workload variations and imbalances, we
relied primarily on information from OECA headquarters on enforcement FTEs
in each region and standard Program Review Status reports produced annually
by OECA. Our comparative analysis of these data with the information from
the regions further confirmed the inconsistency of EPA's enforcement data.

Our work for this review was conducted between June 2000 and July 2001 in
accordance with generally accepted government auditing standards.

Appendix II: EPA's Structure and Environmental Enforcement Activities

Page 31 GAO- 01- 812 EPA's Human Capital

EPA is organized into 13 major headquarters offices (including OECA),
located in Washington, D. C. (see fig. 8). These offices receive
administrative, investigative, and laboratory support from numerous
headquarters field entities located throughout the country. EPA also
maintains 10 regional offices to implement federal environmental statutes
and to provide oversight of related state activities.

Figure 8: EPA's Organizational Structure

Source: EPA

Appendix II: EPA's Structure and Environmental Enforcement Activities

Appendix II: EPA's Structure and Environmental Enforcement Activities

Page 32 GAO- 01- 812 EPA's Human Capital

EPA has been responsible for enforcing the nation's environmental laws since
it was created in 1970. This responsibility has traditionally involved
monitoring the compliance of those in the regulated community (such as
factories or small businesses that release pollutants into the environment
or use hazardous chemicals), ensuring that violations are properly
identified and reported, and ensuring that timely and appropriate
enforcement actions are taken against violators when necessary. Under many
major federal environmental statutes, EPA gives states that meet specified
requirements the authority to implement key programs and to enforce their
requirements. In such cases, EPA establishes by regulation the minimum
components of state enforcement authority, such as the authority to seek
injunctive relief and civil and criminal penalties. EPA also outlines by
policy and guidance its views as to the elements of an acceptable state
enforcement program, such as necessary legislative authorities and the type
and timing of the action for various violations, and tracks how well states
comply. EPA may also take appropriate enforcement action against violators.

EPA administers its environmental enforcement responsibilities through its
headquarters Office of Enforcement and Compliance Assurance (OECA). While
OECA provides overall direction on enforcement policies and sometimes takes
direct enforcement action, it carries out much of its enforcement
responsibilities through its 10 regional offices. These offices are
responsible for taking direct enforcement action and for overseeing the
enforcement programs of state agencies in those instances in which EPA has
approved a state program.

Although EPA acknowledges that some variation in environmental enforcement
is necessary to take into account local conditions and local concerns, core
enforcement requirements must nonetheless be consistently implemented. EPA
also maintains that to ensure fairness and equitable treatment, like
violations in different regions of the country should be met with comparable
enforcement responses.

Many major federal environmental statutes allow EPA to authorize states to
administer environmental programs. 1 One of the key conditions for
authorizing state programs is that the state acquire and maintain adequate
authority to enforce the federal law. For example, to obtain EPA approval

1 For some programs, EPA is responsible for carrying out directly all
enforcement and compliance activities.

Appendix II: EPA's Structure and Environmental Enforcement Activities

Page 33 GAO- 01- 812 EPA's Human Capital

to administer the Clean Air Act's title V permitting program for major air
pollution sources, states must have, among other things, adequate authority
to ensure compliance with title V permitting requirements and to enforce
permits, including authority to recover civil penalties and provide
appropriate criminal penalties. Similarly, the Clean Water Act allows EPA to
approve state water pollution programs under the National Pollutant
Discharge Elimination System if the state programs contain, among other
things, adequate authority to issue permits that ensure compliance with
applicable requirements of the act, and to abate violations, using civil and
criminal penalties and other means of enforcement.

EPA develops enforcement policies for these programs. The enforcement
policies outline EPA's traditional regulatory approach to enforcement,
including what constitutes a violation, especially the significant
violations that are likely to require an enforcement action. When a
violation is discovered, the policies generally require an escalating series
of enforcement actions, depending on the seriousness of the violation and
the facility's level of cooperation in correcting it. Actions might start
with a verbal warning, or a warning letter, and escalate to administrative
orders requiring a change in the facility's practices. These enforcement
policies also define timely and appropriate enforcement actions for various
types of violations. In the most serious cases, EPA or the states can assess
penalties or refer the case to the U. S. Department of Justice or a state?s
Office of Attorney General for prosecution. The monetary penalties that EPA
assesses include two amounts: one amount based on the seriousness of the
violation and the other amount designed to remove any financial advantage
the violator obtained over its competitors through noncompliance. EPA may
also pursue criminal enforcement action if the situation warrants.

Whether EPA or state personnel take the lead in taking enforcement actions
depends on whether the state has been authorized to administer the program.
If EPA retains the program, the cognizant EPA regional office generally
takes the lead in monitoring compliance and taking enforcement actions,
often with support and/ or guidance of EPA headquarters program offices,
OECA, and the Office of General Counsel.

EPA's polices provide guidance to the states that have been authorized to
administer the enforcement program. Moreover, EPA's regions and the states
work together each year to establish enforcement expectations and lay out
their respective roles. EPA also provides grant funds to states to assist in
the implementation of the federal programs and, under certain

Appendix II: EPA's Structure and Environmental Enforcement Activities

Page 34 GAO- 01- 812 EPA's Human Capital

circumstances, conditions receipt of grant funds on compliance with EPA
guidance.

EPA oversees the states' enforcement in a variety of ways, including
reviewing inspection reports and enforcement actions and accompanying state
inspectors. EPA also requires states to report information on various
aspects of their enforcement efforts, such as the number and type of
inspections the state has taken, the results of those inspections, and any
enforcement actions resulting from discovered violations. EPA's enforcement
policy under the Clean Air Act and Clean Water Act concentrates primarily on
large facilities and large sources of pollution. States have more autonomy
in determining how they will enforce the law at smaller sources and smaller
facilities.

EPA officials use a number of methods to oversee regional and state
enforcement programs. An important first step is the biennial Memorandum of
Agreement between EPA headquarters and the regions, which contains the core
program requirements and national priorities that both headquarters and the
regions agree must be addressed. In addition to the national priorities, the
agreements with each individual region contain region- specific priorities
that OECA reviews and approves. The regions share this agreement with their
states so that all key parties understand the regions' goals and commitments
with headquarters. Senior OECA managers visit the regions during the year to
review regional progress in meeting the agreed- upon enforcement goals and
commitments in the memorandum and to make mid- year corrections. OECA also
sponsors national meetings, schedules routine conference calls between
headquarters and regional media program staff, and conducts periodic
evaluations of regional enforcement programs. EPA regional enforcement
program staff frequently communicate with state enforcement staff through
routinely scheduled telephone conferences. In addition, a number of regions
have implemented protocols for overseeing state performance.

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In July 2000, we submitted a set of questions based on our human capital
self- assessment "checklist" to officials in EPA's Office of Human Resources
and Organizational Services. We asked these officials to provide us with
information on the extent to which EPA's human capital policies and
practices exhibited the principals that we had identified as being
associated with high- performing organizations. The following table provides
a summary of their responses, organized by the key elements as defined in
our checklist. The table also provides information, as of June 2001, on the
status of EPA's efforts to implement its human capital strategy as they
relate to each checklist element.

Table 4: Status of EPA's Human Capital Management Activities, as Reported by
Agency Officials Human Capital Management Element Status of Human Capital
Management/ Activities Reported By EPA STRATEGIC PLANNING: Establish the
Agency's Mission, Vision for the Future, Core Values, Goals and Objectives,
and Strategies

High- performance organizations define what they want to accomplish and what
kind of organization they want to be. They define a "shared vision"- a
mission, a vision for the future, core values, goals and objectives, and
strategies- and communicate it clearly, constantly, and consistently. The
agency's shared vision provides the standard for assessing the
appropriateness and effectiveness of everything the agency does. In the area
of human capital, the agency should develop strategies to enhance the value
of its employees and focus their efforts on the agency's shared vision. The
effect should be in the best interests of employer and employee; the
agency's capacity to achieve its shared vision will increase, while its
employees will benefit from the incentives of working for a high-
performance organization.

"Shared Vision"

A clearly defined and well- communicated mission, vision for the future,
core values, goals, and objectives, and strategies by which the agency has
defined its direction and expectations for itself and its people

EPA's 1997 and 2000 Strategic Plan, its Annual Performance Plans, and Annual
Performance Reports all include discussions of EPA's mission and "shared
vision."

 In its Strategic Plans, EPA developed a series of 10 strategic, long- term
goals, which identify outcomes in the environment and within the
organization. These goals define EPA's vision for the future, directions and
expectations.

 EPA's Annual Performance Plans present the agency's goals, objectives, and
strategies for accomplishing them.

 EPA's Annual Performance Reports further discuss the agency's progress
toward its goals and objectives by providing a goal- by- goal discussion,
focusing on the agency's accomplishments with regard to its annual
performance goals.

Specifically with regard to human capital, EPA's human capital strategy
states that, to achieve the mission of protecting human health and
safeguarding the natural environment, EPA established the following vision,
values, and strategic goals:

 "EPA's people are highly skilled and motivated, creative in seeking
solutions, and committed to achieving excellence.

 EPA respects and values integrity, the trust and confidence of the public,
diversity of cultures and thinking, competence, innovation, continuous
learning, and sound science. We treat our people fairly and with respect,
and encourage a spirit of teamwork and the consistent practice of these
values."

Human Capital Focus

A framework of human capital policies, EPA has made investing in human
resources a high priority because it recognizes that

such investments are fundamental to achieving the agency's strategic goals
and objectives. EPA's Strategy for Human Capital, completed in November
2000,

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programs, and practices specifically designed to steer the agency toward
achieving its shared vision, integrated with the agency's overall strategic
planning

addresses the following issues:

Strategic Planning: The strategy describes EPA's human capital vision,
values, goals, and strategies and its plans to use human capital to
accomplish the agency's mission.

Organizational Alignment: Goal 1 of the strategy- to attract and retain a
diverse and highly skilled workforce- calls for an agencywide workforce
planning system to identify the skills offices and regions will need,
inventory the skills of the current workforce, identify existing gaps,
forecast staffing needs, and develop strategies for recruitment, retention,
and employee development.

Leadership: EPA's strategy includes plans for ensuring continuity of
leadership through succession planning, reinstating a Senior Executive
Service candidate program, and improving efforts to develop EPA's leaders
under Goal 2- ensuring that EPA's people perform to their highest potential.
EPA's strategy also aims to create "a sense of community, where differences
are recognized as contributing to the whole, all employees' contributions
are appreciated, and all views are solicited and welcomed" (Goal 4) and
ensuring that "teamwork and collaboration are routinely practiced with
internal and external partners" (Goal 5).

Talent: EPA's strategy includes plans for recruiting and developing
employees that are linked to the mission under Goals 1 and 2.

Performance Culture: Goals 2 and 4 of the strategy include plans to (1)
strengthen EPA's performance management systems to recognize good
performance and better hold employees accountable, (2) assess the impact of
EPA's existing system, (3) provide more and better tools to managers for
dealing with poor performers, and (4) reemphasize the Merit Principles and
establish two- way communication mechanisms to increase mutual understanding
and a sense of fairness in EPA's workplaces.

Although the agency's various operating human resources offices are expected
to measure the effectiveness of human resources practices established under
the strategy, the strategy does not yet include measures for assessing the
effectiveness of EPA's plans in achieving the strategy's goals. The strategy
also calls for future benchmarking of other organizations in several areas,
such as establishing guidelines for span of control and encouraging
innovation.

ORGANIZATIONAL ALIGNMENT: Integrate Human Capital Strategies With the
Agency's Core Business Practices High- performance organizations choose the
best strategies for integrating their organizational components, activities,
core processes, and resources to support mission accomplishment. High-
performance agencies also align their human capital management systems- from
the organizational level down to individual employees- with their strategic
and program planning. The goal is to maximize value while managing risk. In
the human capital area, this requires workforce planning that is explicitly
linked to the agency's shared vision. It also requires that the "personnel"
or "human resources (HR)" function undergo a fundamental reorientation, from
being a strictly support function involved in managing personnel processes
and ensuring compliance with rules and regulations, to taking a "place at
the table" with the agency's top management team. Effective human capital
professionals must have the appropriate preparation and experience to
provide effective mission support and to participate as partners in
developing, implementing, and assessing the agency's human capital
approaches.

Workforce Planning

A strategy, linked to the agency's strategic EPA currently has no integrated
workforce planning strategy. Nevertheless, EPA

human resource managers believe that the agency has made significant
progress towards linking its workforce planning strategy and its overall
strategic and planning

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and program planning efforts, to identify its current and future human
capital needs, including the size of the workforce, its deployment across
the organization, and the knowledge, skills and abilities needed for the
agency to pursue its shared vision

efforts and, in particular, in planning for its current and future workforce
needs. According to these managers, in 1998, EPA set the foundation for a
comprehensive workforce planning system with its Workforce Assessment
Project. In this project, EPA assessed the skills and expertise of the
agency's workforce, reviewed the internal and external environments driving
change that would affect EPA in the future, and identified competencies
likely to be critical to the successful accomplishment of EPA's future
mission.

Human Capital Strategy:

Strategy 1. 1: Develop and Implement an Agency Workforce Planning System

Develop standardized workforce planning requirements and methodology to be
used agencywide, including: (1) Identify technical and other knowledge,
skills and competencies needed for the future, and types and numbers of
positions needed by series and grade; (2) inventory skills/ competencies in
the current EPA workforce; (3) examine statistical data on expected
attrition by occupational category/ grade; (4) compare future needs (both
skills/ competencies and numbers, by occupation/ grade) to existing
workforce and identify the gaps; (5) forecast the potential number of new
hires by Region/ Office taking into account budget projections, and funds
needed for training and development; (6) prepare multiyear Workforce Plans
to guide decisions on workforce composition, hiring, and employee
development efforts at the local and national level.

Fiscal year 2001 plans:

Develop standardized workforce planning requirements/ methodology. Status:
EPA has formed a project team to develop agencywide standardized workforce
planning requirements and methodology and funding has been allocated to let
a contract that will support this initiative during the fourth quarter of
fiscal year 2001. EPA has benchmarked other federal agencies' planning
activities and is looking for a federal partner to jointly develop a
workforce planning system. Future implementation plans will depend on the
results of work completed in 2001.

Strategy 6. 2: Align administrative and support plans and resources with the
Agency's mission priorities.

 Designate Human Resources and other resources management representatives
as members of senior planning teams.

 Allocate Human Resources functional resources to reflect the support to be
provided for major program priorities and initiatives.

 Provide the full range of human resources and organizational services to
EPA employees.

Fiscal year 2001 plans:

1. Provide the full range of human resources and organizational services to
EPA employees.

Status: The primary activity under this strategy will be to use the
workforce assessment and planning process being developed to assess what is
needed to provide EPA's human resources specialists with consultation skills
to complement

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their technical skills and fashion developmental responses. EPA has not yet
established milestones for this effort.

Integrating the Human Resource Function According to EPA human resource
managers, human capital professionals have been

integrally involved in developing the agency's human capital strategy and
integrating it into EPA's strategic plan. Similarly, human resources
management professionals are involved in developing and implementing EPA's
human resources management program and services including, among others,
recruitment, staffing, employee development, and labor relations. However,
EPA's human resources staff levels have declined in recent years, resulting
in skill gaps in the human resource workforce.

Human Capital Strategy:

Strategy 6. 1: Institute mechanisms to ensure workforce impact and support
needs are identified and planned for early in the strategic planning,
preparations for new initiatives, and other planning processes.

 Develop and institute the "fully funded FTE" model to ensure sufficient
funding for human resources initiatives.

 Require a workforce impact analysis to be included in planning for new
programs and initiatives.

 Design and use a facilitated, structured process to do workforce impact
analyses and analyses of support needs when conducting strategic planning
and planning for new initiatives.

 Capture what is spent on human resources and use in budget decisions and
in planning for new initiatives.

Fiscal year 2001 plans:

1. Develop the "fully funded FTE" model. Status: EPA is defining the
elements of the ?Fully Funded FTE? and developing associated cost factors.
EPA will incorporate the final cost factors into the budget formulation
process for fiscal year 2002 (Spring 2001) if the senior leadership agrees
to this approach.

LEADERSHIP: Foster a Committed Leadership Team and Provide Reasonable
Continuity Through Succession Planning A committed senior leadership team is
essential to fostering an agency's shared vision, aligning organizational
components to best pursue this vision, and building a commitment to the
vision at all levels of the organization. To become a high- performance
organization, an agency needs senior leaders who are drivers of continuous
improvement and whose styles and substance are in accord with the way the
agency sees its mission and its own character. To create a workforce that
shares this vision and is aware of the contribution that each employee can
and must make toward achieving it, the agency's senior leaders must work as
a team to convey a clear and consistent portrayal of this vision throughout
the organization by their words and deeds and the example they set.
Political appointees and career managers may bring differing values to the
team, but they must work at building mutual understanding and trust and at
committing themselves to a shared set of goals for their agency. Because
these goals can take years to achieve, the agency must have a succession
planning strategy that ensures a sustained commitment and continuity of
leadership.

Defining Leadership EPA human resource managers stated that the agency
expects its leaders to (1) successfully reflect the five Mandatory Executive
Core Qualifications outlined by the Office of Personnel Management (OPM)-
leading change, leading people, results driven, business acumen, and
building coalitions/ communication; (2) focus on specific management areas
defined by EPA, (for example, human and other resource

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management); and (3) produce results relating to their assigned functional/
programmatic responsibilities. EPA's expectations for its leaders are not
explicitly aligned with the agency's mission and strategic goals, but are
broader and outlined in more general terms. EPA human resource managers
believe that this allows ratings to consider performance in all aspects of
the leaders' responsibilities.

EPA officials consider executive core competencies, specific management
areas, and technical requirements when staffing management positions and
making executive development decisions. EPA is reviewing its executive
performance management system based on proposed regulations issued by OPM
using the balanced- measures concept. As part of this effort, EPA has
gathered benchmarking information and will develop additional information
with OPM and other federal agencies.

Human Capital Strategy:

Strategy 2. 3: Build effective leadership at all levels within the agency.

 Articulate and disseminate the Agency's leadership philosophy.

 Select leadership assessment instruments to be used consistently
agencywide.

 Convene the EPA SES management team on a regular basis.

 Maintain a centralized pool of dollars and staff resources to support
local organizational improvement efforts. Convene forums to facilitate the
exchange of ideas and networking. Foster improvement of core processes and
better environmental results.

Fiscal year 2001 Plans:

1. Convene the SES management team on a regular basis. Status: EPA held an
SES management team meeting in 2000 and has scheduled another meeting of the
entire EPA SES corps for May 31 and June 1, 2001. Potential topics of
discussion include:

 the Administrator's and senior management's priorities and leadership
philosophy;

 management challenges facing the agency;

 future labor/ management relationships;

 a new SES performance management system;

 integrating human capital considerations into the strategic planning
process; and

 future EPA strategic plans. 2. Establish and communicate leadership
expectations to supervisors and managers.

Status: EPA plans to communicate expectations for all supervisors, managers,
and executives through its Leadership Development program.

Teamwork and Communications

Strategy to build teamwork, communicate the agency's shared vision in clear
and consistent terms to all levels of the organization, and receive feedback
from employees

EPA has no explicit communication strategy. However, according to EPA human
resource managers, all Assistant and Regional Administrators meet weekly
with the Administrator, and a Senior Management Council meets periodically
to address the agency's priorities and other significant business in a
comprehensive manner. The Assistant and Regional Administrators are expected
to communicate back to their respective organizations. In addition, the
Administrator and Deputy Administrator communicate directly with all EPA
employees using email regarding important agency

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matters, such as reorganizations, changes in programmatic directions, major
accomplishments, important decisions, and new initiatives.

Similarly, EPA has no explicit strategy to build teamwork or to receive
feedback from employees on an agencywide basis. However, according to human
resource managers, individual EPA program and regional offices have efforts
underway to build teamwork and obtain feedback from employees, including
plans and efforts to improve team development and activities, training on
teams and high performance organizations, employee satisfaction surveys,
management assessment surveys, and customer satisfaction surveys.

Human Capital Strategy:

Strategy 5. 2: Improve and support teamwork within organizations and across
organizational boundaries.

 For organizations that utilize teams, institute a team support program,
including internal consultants to advise managers and teams on the benefits
of a team- based organization, how to implement teams, and related subjects;
training in such team skills as group dynamics, group facilitation, and
conflict resolution; and tools to support teams throughout the
implementation.

Fiscal year 2001 Plans:

[None reported]

Ensuring Continuity: Executive Succession Planning

Ensure continuity of leadership through executive succession planning;
includes a review of its current and emerging leadership needs in light of
its strategic and program planning and identified sources of executive
talent both within and outside the agency.

EPA does not have an executive succession planning system in place. However,
according to EPA human resource managers, all of the agency's organizations
are developing potential candidates for executive positions. Typically, in
each organization, there are multiple candidates who have experiences and
training directly related to the organization's executive positions. When
selecting executives, EPA uses merit staffing procedures, including applying
rating factors that are directly related to the executive position. EPA is
reviewing executive position needs based on projected turnover information,
plans to review succession vulnerability organization by organization, and
plans to analyze the availability of talent at lower management levels.

Human Capital Strategy:

Strategy 2. 3: Build effective leadership at all levels within the agency.

Fiscal year 2001 Plans:

1. Develop a leadership succession planning program, including
identification of potential leaders and mentoring programs.

Status: EPA issued a human resources guide for supervisors and training
curriculum guidance in May 1999; a management development resources guide in
July 2000; and has completed draft guidance for coaching and mentoring. EPA
plans to initiate a course for new supervisors in 2001.

Ensuring Continuity: Executive Development Program According to EPA human
resource managers, the agency plans to establish a structure

to develop managers and executives based on future skill and programmatic
needs. The first step towards this end will be to reestablish an SES
Candidate Development

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Program. In addition, EPA (1) has initiated a mentoring program for grade 15
employees; (2) hires Presidential Management Interns; (3) has implemented an
intern program that focuses on minority populations; and (4) invests in FEI
with 40- 50 participants each year.

As part of EPA's Workforce Development Strategy, the senior leadership teams
of seven EPA organizations were trained in the key functions of
organizational leadership; the linkage of vision and values; the alignment
of mission, environment, results, and outcomes with operational performance
plans; and guidelines for ensuring that this alignment continues.

Human Capital Strategy:

Strategy 2. 3: Build effective leadership at all levels within the Agency.

Fiscal year 2001 Plans:

1. Reinstate the SES Candidate Program. Status: EPA's new SES Candidate
Development Program has been approved by OPM. The first two classes of this
new program will be selected by January 2002.

2. Develop a core curriculum for all supervisors/ managers, with 80 hours of
training for new supervisors, including training in the merit principles,
labor- management relations, equal employment opportunity, performance
management, and other key human resources management responsibilities, and
80 hours annually of training for experienced managers.

Status: EPA's human resources guide for supervisors, distributed to all EPA
executives, managers, and supervisors in 1999, details all supervisory
responsibilities. It is available on EPA's intranet for continuous updates.
Information and training for employees interested in moving into supervisory
positions will be available by the end of fiscal year 2001.

TALENT: Recruit, Hire, Develop, and Retain Employees with the Skills for
Mission Accomplishment A high- performance organization demands a dynamic,
results- oriented workforce with the talents, multidisciplinary knowledge,
and up- to- date skills to enhance the agency's value to its clients and
ensure that it is equipped to achieve its mission. Because mission
requirements, client demands, technologies, and other environmental
influences change rapidly, a performance- based agency must continually
monitor its talent needs and be alert to the changing characteristics of the
labor market. It must identify the best strategies for filling its talent
needs through recruiting and hiring and invest in developing and retaining
the best possible workforce. Its compensation and benefits programs,
flexibilities, facilities, services, and work/ life arrangements should be
viewed from the perspective of how well they help the agency compete for and
retain the best talent available and elicit the best performance from that
talent. In addition, this talent must be continuously developed through
education, training, and opportunities for continued growth. The agency must
match the right people to the right jobs and be prepared to employ matrix
management principles, maintaining the flexibility to redeploy its human
capital and realigning structures and work processes to maximize economy,
efficiency, and effectiveness. Structures and work arrangements must be
fashioned to avoid stovepiping (or "siloing") and draw on the strengths of
the organizational components. Cross- functional teams can be used as a
flexible means of focusing talent on specific tasks.

Recruiting and Hiring

A strategy that is targeted to fill short- term and long- term human capital
needs, and

EPA has no formal agencywide recruitment or hiring plan that is linked to
its short and long- term strategic direction. Nevertheless, EPA human
resource managers told us that EPA has an active recruitment program,
including attending hundreds of recruitment events each year throughout the
country. EPA contracted for a state- of- the- art

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specifically, to fill gaps identified through workforce planning efforts
recruitment display and new recruitment materials and has a centralized
system to

track upcoming recruitment events.

Human Capital Strategy

Strategy 1. 2: Develop/ implement recruitment strategies based on workforce
plans.

 Develop and implement coordinated national and local recruitment
strategies.

 Expand the EPA Intern Program for recruiting a diverse and talented
workforce.

 Establish long- term partnerships with educational institutions to aid
future recruiting efforts.

 Utilize compensation options and flexibilities.

Fiscal year 2001 plans:

1. Expand the EPA Intern Program. Status: According to EPA, the intern
program has brought 79 interns- including minorities and people with
disabilities- into the agency. The first class entered the workforce and the
1999 class completes its 2- year program in September 2001. EPA plans to
select its next class in July 2001, and to evaluate the program after the
2002 class is completed.

2. Develop/ implement coordinated recruitment strategies. Status: In October
2000, EPA hosted the 2nd Hispanic Stakeholders Consultation bringing
together stakeholders to discuss implementing EPA's National Hispanic
Outreach Strategy. This strategy is intended to promote economic and
employment opportunities for Hispanics with the agency. EPA plans to develop
recruitment strategies that demonstrate EPA's commitment to fair and equal
employment opportunity, including a similar outreach strategy for Asian
Americans and Pacific Islanders. Also, in September 2000, EPA developed a
plan to increase employment opportunities for individuals with disabilities,
which describes how EPA's recruitment, career development and other programs
and strategies support its commitment to provide opportunities for
individuals with disabilities. EPA's Office of Human Resources and
Organizational Services, the Office of Civil Rights, and the Headquarters
program offices initiated a diversity outreach partnership to ensure that
the goals of affirmative action, diversity, and equity are addressed in the
recruitment process. Furthermore, EPA will make recruitment tools available
on its Intranet. New state- of- the- art recruitment booths were designed
and new recruitment brochures are currently under review.

Strategy 1. 3: Develop strategic approaches to retaining employees with
critical expertise and competencies.

 Conduct exit interviews throughout the agency to establish baseline data
on retention factors.

 Develop retention strategies aimed at retaining employees with essential
skills.

Fiscal year 2001 plans:

1. Develop a questionnaire and database for, and conduct, exit interviews.

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Status: Funding was not provided for these activities. 2. Develop retention
strategies.

Status: This will be addressed as part of EPA's workforce planning effort.

Training and Professional Development

Training and professional development strategy including education,
training, and other developmental opportunities to help its employees build
the competencies needed to achieve the agency's shared vision; explicit link
between the agency's training offerings and curricula and the competencies
identified by the agency for mission accomplishment

EPA's Fiscal Year 1999 Annual Performance Report, among other documents,
states that EPA's human capital strategy aims to attract, recruit, and
develop employees who can address the critical environmental issues of today
and the future. This report also states that increasing employee
competencies is an integral element of a comprehensive, inclusive strategy
designed to produce an EPA workforce that is prepared for the future.

According to EPA's human resource managers, the agency is implementing
developmental programs to build the competencies identified in its 1999
workforce assessment project, beginning with leadership development. The
goal of the leadership development program is to develop managerial
competencies among mid- level management, focusing on the importance of
supervisors fostering leadership skills in their staffs. EPA also plans to
begin development programs aimed at administrative support staff and SES
candidates.

Human Capital Strategy: Strategy 2. 1: Link employee development to mission
needs.

 Fully fund and implement the Workforce Development Strategy. Ensure that
leadership development is a key element of the strategy for all employees at
all levels of the organization.

 Utilize Phase II of the Strategy for Mid- Level Development to create a
comprehensive career management system linking development of mid- level
employees to the mission.

 Develop an agency employee retraining plan to ensure the current workforce
possesses the necessary skills to meet current and future work challenges.

 Apply OPM's guide to strategically planning for training to tailor
development to organizations' strategic needs.

 Explore and pilot rotational assignment programs, such as assignments to
Community- based Environmental Protection (CBEP), to broaden individual
employees' range of skills and experience. Rotational assignments will
include assignments within organizations, assignments to different
organizations (such as cross- media assignments), and assignments in
different geographic areas (such as Headquarters to Regions, Region to
Region, etc.).

 Use Individual Development Plans (IDP) to link training to the
organization's mission.

 Institute local mentoring programs.

 Utilize new systems for training, including technological approaches.

Fiscal year 2001 plans:

1. Fully fund and implement the Workforce Development Strategy. Status:
According to human resource managers, EPA's Workforce Development Strategy
continues to be a major priority and is funded to carry out the individual
project initiatives approved by the EPA Human Resources Council.

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2. Explore and pilot rotational assignment programs. Status: This project
was not funded and is now on hold.

Workforce Deployment

Workforce deployment, with decisions based on ensuring that the workforce is
deployed appropriately- both geographically and organizationally- to support
organizational mission, goals, and strategies

EPA does not have a workforce deployment strategy or plan in place. Instead,
each fiscal year, EPA develops its Enacted Operating Plan, based on
congressional action on its appropriations bill. While developing the annual
budget, EPA determines its workforce levels according to agency priorities.
The workforce levels within a given EPA office or region may shift from year
to year to address the most critical environmental needs and to compensate
for areas where work is complete or nearing completion.

Human Capital Strategy:

[Not directly addressed]

Employee- Friendly Workplace According to EPA human resource managers,
agency management tries to balance the needs of EPA's employees with the
requirements of individual work assignments and operational goals. Flexible
working arrangements available to EPA employees include

 A choice of regular or compressed work schedules;

 Leave arrangements, such as family- friendly leave and a leave bank for
employees with personal or family emergencies; and

 A "flexiplace" program, which permits employees to work up to 2 days every
2 weeks at home or a telecenter location, or, if recovering from an illness,
to work up to 6 months at home. EPA participated in a 1990 Office of
Personnel Management pilot study on telecommuting and, since then, has
expanded the scope of its program, issued policy guidance, and completed
related agreements with all unions.

Human Capital Strategy:

Strategy 1. 4: Maximize flexibility in using workplace programs that
contribute to EPA's attractiveness as an employer and that help employees
achieve a balance between work and non- work life.

 Assess current workplace programs to determine the level of participation
and employee satisfaction.

 Educate managers and staff on the benefits of these programs both for
employees and organizations.

 Pilot job sharing in offices not currently using this option.

 Advertise EPA's workplace programs on the EPA Web site and sites
specifically designed to reach potential job applicants.

Fiscal year 2001 plans:

[None reported]

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Activities Reported By EPA PERFORMANCE CULTURE: Empower and Motivate
Employees While Ensuring Accountability and Fairness in the Workplace

High- performance organizations foster a work environment in which people
are empowered and motivated to contribute to continuous learning and
improvement and mission accomplishment and that provides both accountability
and fairness for all employees. A highperformance agency's approach to its
workforce is inclusive and draws on the strengths of employees at all levels
and of all backgrounds. It maintains a workplace in which honest two- way
communications and fairness are a hallmark, perceptions of unfairness are
minimized, and workplace disputes are resolved by fair and efficient means.
Its line managers and supervisors, who may be given greater human capital
decisionmaking authority in a performance environment, must be sufficiently
prepared and appropriately trained to be accountable for their decisions.
High- performance organizations also recognize that all employees help
create organizational value and that job processes, tools, and mission
support arrangements must be tailored to support mission accomplishment. A
dedication to continuous learning and improvement can help an agency to
respond to and anticipate change, create new opportunities for itself, and
pursue a shared vision that is ambitious and achievable. Incentives are
important in steering the workforce; they must be results- oriented, client-
based, realistic, and subject to balanced measures that reveal the multiple
dimensions of performance. Incentives should be part of a performance
management system under which employees' performance expectations are
aligned with the agency's mission, and in which personal accountability for
performance is reinforced by both rewards and consequences. Because agencies
are increasingly technology- driven and knowledge- based, high- performing
agencies ensure that their employees have the right information technology
resources to do their work and to gather and share information.

Performance Management

Performance management system designed to steer the workforce toward
embodying and effectively pursuing the agency's shared vision

EPA initiated its current PERFORMS performance management system in 1998, in
which performance is rated as either successful or unacceptable. According
to EPA human resource managers, the supervisor and employee are responsible
for developing a performance agreement that is aligned with the agency's
strategic plan, stressing results- oriented measures. However behavioral and
activity- oriented measures are also permitted in the agreements. The
standards for supervisors, team leaders, and resource managers include
specific criteria to address their responsibilities and document their
accountability. Supervisors are responsible for improving organizational
performance and increasing employee productivity by communicating the shared
vision and managing employee expectations. Since almost all employees are
rated "successful," ratings do not differentiate among performers. Such
differentiation is built into the feedback processes throughout the year.
EPA has not yet evaluated the system's effectiveness.

EPA human resource managers told us that the agency has de- linked
performance ratings from explicit formulas for cash awards. Instead, cash
awards are based on an employee's individual group or team- based
accomplishments in relation to generic measures of quantifiable factors,
such as dollars saved, or non- quantifiable factors, such as the quality of
an analytical study. EPA has emphasized in general terms the importance of
results- oriented performance. For example, EPA stresses customer service as
a general test of performance at all levels of the agency through explicit
customer service- related awards and customer service standards.

Human Capital Strategy:

Strategy 2. 4: Strengthen performance management programs to reinforce
accountability.

 Establish a support structure for handling performance problems in which
managers can discuss problems with employees in a non- threatening
environment.

 Fully utilize all formal and informal means for recognizing and
appreciating good work.

 Assess PERFORMS' effectiveness in recognizing good performance and
improving poor performance. Compare with other systems to determine which
are most effective.

Appendix III: Information Reported by EPA on the Status of the Agency's
Human Capital Management

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 Establish clear expectations that all managers will recognize good
performance and will deal with poor performance through performance
improvement and disciplinary processes.

 Balance reviews of managerial performance during discussions between
senior managers and subordinate managers to include a review of both program
accomplishments and human resources responsibilities, including managers'
use of performance management programs and managers' ability to create a
work culture that supports, invests in, and involves people.

 Revise and reinforce model performance standards for managers.

Fiscal year 2001 plans:

1. Establish clear performance management expectations for managers. 2.
Review managers' performance for program accomplishments and human resources

responsibilities. Status: EPA's human resource office will develop guidance
for all supervisors, managers, and executives, and include it in all
Leadership Development efforts. (For both 1 and 2 above).

Strategy 4. 1: Fully apply and comply with the Merit Principles in
selection, promotion, development, recognition, and work assignment
decisions.

 Educate all employees about the Merit Principles and Prohibited Personnel
Practices.

 Institute practices to bring about transparency and open communication
with regard to organizational decisions affecting employees.

Fiscal year 2001 plans:

[None reported]

Strategy 4. 3: Institute feedback mechanisms that facilitate full and open
communication and accountability at all levels in the Agency.

 Establish and implement a 360- degree feedback process beginning with
managers; over time, expanding to include all employees.

 Periodically publish workforce profiles and data on hires, promotions,
awards, and high profile assignments to foster a climate of openness.

 Use alternative dispute resolution techniques to resolve EEO complaints,
grievances, and Unfair Labor Practices before they become formal.

 Conduct periodic surveys of employees to solicit their views on diversity
and fairness and the overall quality of work life in their organizations.

Fiscal year 2001 plans:

1. Implement a 360- degree feedback process for agency managers. Status: EPA
has been developing such a management/ leadership feedback process since the
third quarter of fiscal year 2000. All managers are strongly encouraged to
seek and follow up on feedback from peers, direct reports, supervisors, and
customers. EPA will provide guidance on the 360- degree feedback process to
all managers.

Appendix III: Information Reported by EPA on the Status of the Agency's
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Human Capital Management Element Status of Human Capital Management/
Activities Reported By EPA

2. Publish workforce profiles/ data. Status: In fiscal year 2001, EPA plans
to develop an intranet- based system for accessing workforce profile
information and employment demographics as part of the HR Pro Human
Resources Information System. When fully implemented, HRPro will be EPA's
primary source of employee, position, and organizational data.

3. Use alternative dispute resolution. Status: In 2000, EPA pilot tested a
workplace mediation program, assessing whether (1) the location of the
program is neutral and independent, (2) use of a co- mediation model and
outside mediators is effective, (3) in- house mediators would be perceived
as neutral, and (4) management participation is sufficient. EPA mediated 16
cases in 2000. Four of the 16 cases were settled. EPA extended the pilot for
another year and awarded a contract for further evaluation of the program.
The second year of the pilot will continue to use the co- mediation model,
but will allow employees to choose from in- house mediators, Federal Shared
Neutrals' mediators, or a combination of the two.

Information Technology

Information technology plan emphasizing the alignment of the agency's
information technology programs with its mission, goals, and strategies

EPA's 1995 Information Resources Management Strategic Plan outlines how the
agency plans to manage its information resources. This plan supports EPA's
strategic goals and recognizes that effective information resources
management is essential to a more comprehensive approach to environmental
protection. Appendix B of the plan links the plan's eight information
technology vision elements with EPA's guiding principles for environmental
protection.

The Clinger- Cohen Act of 1996 requires that all EPA information technology
investment proposals be justified based on criteria that include their
contribution to the agency's mission. According to EPA human resource
managers, OMB has cited EPA's implementation of this requirement as an
effective process for assessing the value of information technology
projects. To better align its information technology program and
environmental mission, EPA has, since 1995,

 established an advisory committee to review the agency's information
program and provide recommendations on how to ensure that it supports EPA's
evolving environmental protection strategies. The committee's
recommendations supported EPA's decisions to reorganize the agency's
information program to better meet customer needs;

 developed the Reinventing Environmental Information Implementation Plan, a
strategy for improving EPA's use of information technology; and

 begun an Integrated Information Initiative to work in partnership with
states to develop a plan for a shared environmental information exchange
network.

According to EPA, the agency benchmarks its information technology programs
and services against those of similar organizations. For example,

 in 1997, EPA compared its programs with best practices identified by GAO;

 every 3 years, EPA benchmarks its data center services against government
and industry standards;

 an EPA team is assessing the agency's information technology policies and
functions, including benchmarking against federal policies and functions
best practices.

Appendix III: Information Reported by EPA on the Status of the Agency's
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EPA employees rely extensively on information technology in their jobs,
including gathering and sharing knowledge. For example, e- mail is widely
used to share documents across the agency, facilitating more efficient and
effective work performance. Furthermore, EPA's workforce uses both the
agency's Intranet and the Internet to disseminate and collect information.
Also, EPA recognizes that training is a key component in assuring that
employees can best use information technology. In this regard, EPA

 in 1998, established a training program in partnership with the Department
of Defense's National Defense University and Information Resources
Management College;

 is partnering with the General Services Administration's Federal Learning
Technologies Program to develop an EPA information technology E- Learning
Program; and

 has expanded its efforts to enable its information technology workforce to
access and utilize research services relating to information technology
issues, trends, products, and vendors.

Human Capital Strategy:

Strategy 3. 2: Institute new ways to share information on innovations and
creative approaches within EPA and across organizational boundaries.

 Identify information sharing processes in EPA and promote best practices,
such as establishing an intranet repository for information about innovative
projects around the agency and studying the feasibility of establishing a
knowledge management officer or office to share information and lessons
learned throughout the agency.

Fiscal year 2001 plans:

[None reported]

Inclusiveness: Diversity Plan/ Policy In March 1997, the Administrator, EPA,
directed EPA managers to meet with their minority employees to identify
employment issues and concerns related to affirmative employment and to
develop a plan of action focusing on such issues as hiring, awards,
training, promotions, recruitment, and assignments.

EPA human resource managers consider developing team skills to be the most
urgent and immediate focus of the Mid- Level Development program component
of the agency's Workforce Development Strategy. EPA's "team skills" course
includes a module on conflict resolution. EPA has developed 250 teams and
customer service facilitators who have been certified to help their
organizations move more to a teamsbased environment. Many program offices
across EPA have emphasized training in conflict resolution and relationship
building techniques. EPA has an alternative dispute resolution program to
help resolve workplace conflicts.

Human Capital Strategy:

Strategy 4. 2: Institute processes to recognize and embrace differences that
each employee brings to the organization; facilitate the contribution to the
work of the organization by all employees.

Appendix III: Information Reported by EPA on the Status of the Agency's
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 Continue to implement the Diversity Action Plans, annually evaluating
progress made, and revising Plans to improve effectiveness.

 Publish an annual report on Diversity/ Fairness accomplishments.

 Take steps to ensure that selection processes are transparent and broadly
understood for assignments to new programs and projects, temporary
promotions, details, assignments outside the Agency, and similar special
assignments.

 Include in the core curriculum for supervisors and managers a module on
ensuring equal opportunity and equitable treatment within their
organizations.

 Develop an Agency survey of organizational health and culture that can be
used by all Offices and Regions.

Fiscal year 2001 plans:

1. Continue to implement, evaluate, and revise Diversity Action Plans. 2.
Publish an annual report on Diversity/ Fairness accomplishments. 3. Develop
an Agency survey of organizational health and culture.

Status: EPA provided no status information for these activities.

Employee and Labor Relations EPA has collective bargaining relationships at
both the national and local levels. The American Federation of Government
Employees (AFGE) has a national consolidated bargaining unit, which covers
nonprofessional employees in nine AFGE locals, and a second, separate
consolidated unit, which covers professional employees in two locations. EPA
also has separate, individual collective bargaining relationships with three
National Treasury Employee Union locals, three National Association of
Government Employees locals, and two National Federation of Federal Employee
locals, and a local of the Engineers and Scientists of California.

According to EPA human resource managers, the relationship with AFGE at the
national level is productive and effective, according EPA human resource
managers. The parties have amicably negotiated both a master collective
bargaining agreement and memoranda of understanding on issues such as a new
two- level performance management system. They are also close to final
agreement on a flextime program. Most issues, however, are not national in
scope, but are regional or local in nature.

Given the number of separate bargaining units within EPA, the nature of the
collective bargaining relationship differs by location, according to EPA
human resource managers. In most locations, there is a cooperative
relationship, which focuses on partnership and interest- based forms of
dispute resolution. However, in a few locations, the relationship is
adversarial and characterized by a lack of trust and respect between the
parties. Most EPA regions, labs, and offices have excellent relations with
their unions and have developed a level of trust and understanding which
maintains the relationship even if they disagree on specific items. Most
locations have had no unfair labor practices and very few grievances or
other formal disputes, according to EPA's human resource managers. The
parties discharge their collective bargaining obligations effectively and
with an emphasis on the amicable resolution of disputes. They encourage
training and the development of skills, which help improve the collective
bargaining relationship. Difficult issues such as reorganizations,
relocations, compressed and flexible work arrangements, and employee
development have been successfully negotiated and/ or resolved to the
parties' mutual satisfaction.

Human Capital Strategy:

Appendix III: Information Reported by EPA on the Status of the Agency's
Human Capital Management

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Human Capital Management Element Status of Human Capital Management/
Activities Reported By EPA Strategy 5. 1: Build consensus and constructive
labor/ management relations through improved communication and information
sharing.

 Implement the Labor/ Management Strategic Plan.

 Educate Agency managers on labor/ management partnership requirements.

Fiscal year 2001 plans:

1. Implement the Labor/ Management Strategic Plan. Status: EPA is
reexamining appropriate options for continued labor- management support in
light of Executive Order 13203's impact on management/ union partnership
efforts. EPA plans to continue to foster a collaborative relationship with
union representatives.

Managers/ Supervisors One of the fundamental principles of the Workforce
Development Strategy is that every job contains a responsibility for
"leadership." This principle is based on the findings of EPA's workforce
assessment that the agency's entire workforce of the future should have
competencies and skills now required for the senior executive service. EPA
has offered four mid- level training courses based on the competencies
identified for EPA mission accomplishment. Similarly, EPA's administrative
support development program is intended to develop the competencies needed
at these levels. The goal of EPA's leadership development enterprise is to
provide an opportunity for agency leaders to develop their leadership skills
and those of their employees, and to improve managerial competencies
throughout the agency. EPA is conducting pilots to develop and test
leadership for both organizational and individual improvement. EPA has
completed seven initial pilots and is determining how to apply the results
of the pilots in individual agency organizations.

Human Capital Strategy:

Strategy 2. 3: Build effective leadership at all levels within the Agency.

[See "Leadership" above]

Continuous learning and improvement EPA emphasizes continuous learning and
improvement in its strategic plan, annual plans, performance plans, and
annual performance reports. EPA's Strategic Plan states that the agency will
invest in its employees- through training, education and other means- to
ensure that the agency's workforce is of the highest caliber and is fully
prepared to deliver national leadership and expertise in environmental
protection. In addition, EPA's Fiscal Year 2000 Annual Performance Plan
contains annual performance goals and measures for continuous learning and
improvement.

As part of its efforts, EPA has a formal suggestion program in which
employees may submit suggestions and receive cash awards if their suggestion
is adopted. Suggestions are reviewed and adopted as feasible and
appropriate, according to EPA human resource managers. More broadly, EPA
encourages suggestions, ideas, and comments from employees on programmatic
and administrative operations and proposed changes as part of the agency
culture. In addition, EPA stresses- in its formal recognition manual and
elsewhere- the importance of rewarding the contributions of employees
working in groups to accomplish innovative solutions to problems.

Appendix III: Information Reported by EPA on the Status of the Agency's
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Human Capital Strategy:

Strategy 2. 2: Instill a culture of continuous learning, ethical behavior,
and professionalism.

 Improve orientation programs for employees new to their positions or
roles.

 Develop partnerships with universities to bring academic programs into
EPA.

 Institute policies, practices, and expectations to make attendance at
training sessions the highest priority and to discourage organizations and
employees from canceling attendance.

 Increase development and use of online training and other technological
approaches to training delivery.

Fiscal year 2001 plans:

[None reported]

Strategy 3. 1: Create and set expectations that innovation, creativity, and
risktaking are demonstrated by all employees throughout the agency.

 Develop a module on innovation and creativity for inclusion in relevant
training for all employees (with the "Leading Change" module developed as
part of the Workforce Development Strategy as the first step).

 Establish incentives to recognize and reward innovation, creativity, and
risk- taking in all aspects of the agency's operations.

 Identify barriers to creativity and remove them.

Fiscal year 2001 plans:

[None reported]

Strategy 3. 2: Institute new ways to share information on innovations and
creative approaches within EPA and across organizational boundaries.

 Identify information- sharing processes in EPA and promote best practices,
such as establishing an intranet repository for information about innovative
projects around the agency and studying the feasibility of establishing a
knowledge management officer or office to share information and lessons
learned throughout the agency.

Fiscal year 2001 plans:

[None reported]

(160534)

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