Federal Employees: OPM Data Do Not Identify if Temporary	 
Employees Work for Extended Periods (01-MAR-02, GAO-02-296).	 
								 
In the early 1990s, concerns arose that federal agencies were	 
retaining employees in an ongoing series of temporary		 
appointments without benefits or tenure. For fiscal years 1991	 
through 2000, 10 agencies accounted for 90 percent of all	 
temporary limited employees hired governmentwide. During this	 
period, the number of temporary limited employees hired 	 
governmentwide declined by about 47 percent--from 282,135 in	 
fiscal year 1991 to 150,395 in fiscal year 2000. Most temporary  
limited employees were full-time hires in white-collar jobs who  
received some benefits, including annual pay adjustments and	 
premium pay. A survey done at the 10 agencies indicated that	 
seasonal work was the primary reason for using such employees,	 
followed by peak workloads. The office automation clerical and	 
assistance series was the most often reported occupational series
for fiscal year 2000. Recent studies indicate that federal	 
agencies and private sector firms generally use temporary	 
employees for similar reasons--often staffing flexibility.	 
Because temporary limited employees were serving for years under 
a series of temporary appointments without the benefits afforded 
other long-term employees, the Office of Personnel Management	 
(OPM) revised its regulations in 1994 to ensure that temporary	 
employees were "used to meet truly short-term needs." The revised
regulations created a two-year limit for individual temporary	 
appointments in both the competitive and excepted service. OPM	 
officials said that the Office of Merit Systems Oversight and	 
Effectiveness (OMSOE), when assessing agencies' compliance with  
personnel laws and regulations, routinely included some 	 
individual temporary appointments in its periodic oversight	 
reviews, but generally did not look at the work history of	 
temporary limited employees in those appointments. Data in OPM's 
central personal data file show that many temporary limited	 
employees hired in fiscal year 2000 had already worked for the	 
federal government for at least five years.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-296 					        
    ACCNO:   A02816						        
  TITLE:     Federal Employees: OPM Data Do Not Identify if Temporary 
Employees Work for Extended Periods				 
     DATE:   03/01/2002 
  SUBJECT:   Civilian employees 				 
	     Temporary employment				 
	     Fringe benefits					 
	     Labor force					 
	     Private sector practices				 
	     Personnel management				 
	     Federal employees					 
	     Thrift Savings Plan				 
	     OPM Central Personnel Data File			 

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GAO-02-296
     
A

Report to Congressional Requesters

March 2002 FEDERAL EMPLOYEES OPM Data Do Not Identify if Temporary Employees
Work for Extended Periods

GAO- 02- 296

Letter 1 Results in Brief 3 Background 6 Ten Agencies Were Predominant Users
of Temporary Limited

Employees 8 Temporary Limited Employees Were Mainly Full- Time 9 Agency
Officials? Responses Indicate Seasonal Work Was the

Primary Reason for Using Temporary Limited Employees 14 Studies Indicate
Reasons Public and Private Sectors Use Temporary

Employees Are Generally Similar 17 OPM Revised Its Regulations to Ensure the
Appropriate Use of Temporary Limited Appointments, but Long- Term Use May
Still Exist 19

Conclusions 26 Recommendations 27 Agency Comments 28

Appendixes

Appendix I: Agency Questionnaire on Temporary Limited Employees 30

Appendix II: Objectives, Scope, and Methodology 35

Appendix III: Comments From the Office of Personnel Management 41

Appendix IV: GAO Contact and Staff Acknowledgments 42 Tables Table 1: Number
and Percentage of Temporary Limited Employees

Hired by the 10 Agencies for Fiscal Years 1991 Through 2000 9 Table 2:
Number of White- Collar GS Temporary Limited Employees

by Grade Level for Fiscal Years 1991 Through 2000 12 Table 3: Temporary
Limited Hires Governmentwide That Were Conversions From One Temporary
Appointment to

Another Temporary Appointment in the Same Agency, Fiscal Years 1991 through
2000 23 Table 4: Temporary Limited Employees Hired in Fiscal Year 2000 Who
Had 5 or More Years of Federal Service 25

Table 5: Agencies and Agency Components Selected for Survey 38 Figures
Figure 1: Agencies? Hiring of Temporary Limited Employees in Fiscal Year
2000 8

Figure 2: Temporary Limited Employees Hired Governmentwide by Work Schedule
for Fiscal Years 1991 Through 2000 10 Figure 3: Occupation Categories for
Temporary Limited

Employees Hired Governmentwide for Fiscal Years 1991 Through 2000 11 Figure
4: Percentage of Temporary Limited Employees Hired as Identified by the 10
Agencies in Fiscal Year 2000 by

Specific Reason 15 Figure 5: Most Prevalent Occupations by Reason for Fiscal
Year

2000 as Identified by Our Survey of 10 Agencies 16

Lett er

March 1, 2002 The Honorable Barbara A. Mikulski The Honorable Paul S.
Sarbanes United States Senate

This report responds to your request for information on federal civilian
temporary employees. 1 Temporary employees provide federal agencies with
flexibility in handling temporary increases in workload and short- term
projects, such as working at military bases that will soon close. Temporary

employees also fill recurring summer and seasonal positions, including jobs
in national parks and forests.

Temporary employees generally assist agencies in fulfilling short- term
needs. However, in the early 1990s, there were concerns that agencies were
retaining employees in an ongoing series of temporary appointments for long
periods (8 to 10 years) without benefits or tenure, making nonpermanent
employment quasipermanent for many. In fact, in 1993 a temporary employee
who had worked in an ongoing series of temporary appointments for 8 years
died after suffering a fatal heart attack and his survivors were not
entitled to a pension or government- subsidized health or life insurance
benefits. In 1994, the Office of Personnel Management (OPM) revised its
regulations governing the use of temporary appointments to ensure that
temporary employees were used by agencies to meet truly

short- term needs and were not serving for years without many of the
benefits afforded other long- term employees. 1 Our review of temporary
employees in the executive branch excluded primarily the Postal Service,
Tennessee Valley Authority, and the intelligence agencies.

In the competitive service, temporary employees are referred to as temporary
limited employees. 2 Generally, the appointments of these employees cannot
exceed 1 year but can be extended for an additional year (for a total of 24
months). 3 Temporary employees also serve in executive branch positions that
have been excepted from the competitive hiring requirements by law,
regulation, or administrative determination for 1 year

with the possibility of an extension for another year. 4 For this report, we
use the phrase temporary limited employees to refer to appointments of
temporary employees for both the competitive and excepted services. As
agreed, our objectives were to (1) identify the federal agencies that are
the predominant users of temporary limited employees and the number and job
characteristics of such employees (including work schedules, occupations,
grade levels, and benefits); (2) discuss the primary reasons agencies give
for using temporary limited employees; and (3) compare the

federal government?s use of temporary limited employees with that of the
private sector. In addition, we agreed to identify steps OPM has taken to
ensure the appropriate use of temporary limited employees and to

determine whether long- term use of temporary limited employees still
exists.

2 The competitive service consists of those positions that are subject to
competitive civil service hiring procedures and requires fair and open
competition to ensure equal opportunity for all applicants. 3 The government
also hires employees under other nonpermanent authorities that are within
OPM?s oversight and that exceed 1 year initially. In fiscal year 2000, these
included 9,083 term appointments, which can last from 1 to 4 years, and
1,213 temporary appointments pending the establishment of a register
(TAPER). A register is a list of qualified applicants compiled in order of
relative standing for certification, from which permanent employees can be
selected. Individuals hired under term and TAPER appointments are entitled
to the same benefits as permanent employees.

4 Whole agencies are excepted by law, including the Postal Service, the
Central Intelligence Agency, and the Federal Bureau of Investigation, as are
some occupations, such as attorneys, throughout the federal government.
Federal agencies also can have a completely excepted employment system, such
as the system that the Department of Veterans Affairs has for health care
professionals, that is in addition to the department?s competitive service
system.

To address our objectives, we analyzed temporary limited employee data from
OPM?s Central Personal Data File (CPDF) 5 over a 10- year period- fiscal
years 1991 through 2000; sent a questionnaire to the 10 agencies that were
the predominant users of temporary limited employees (see app. I); reviewed
studies on temporary employment, including studies by OPM, the Merit Systems
Protection Board (MSPB), and the Congressional Research Service (CRS); and
interviewed agency officials. We requested comments on a draft of this
report from the director of OPM. Appendix II contains

more information about our objectives, scope, and methodology. Results in
Brief For fiscal years 1991 through 2000, 10 agencies were the predominant
users of temporary limited employees, accounting for slightly over 90
percent of all temporary limited employees hired governmentwide. These
agencies

were the departments of Agriculture, Commerce, Defense, Health and Human
Services (HHS), the Interior, Justice, State, the Treasury, and Veterans
Affairs (VA) and the Federal Emergency Management Agency (FEMA). Over this
period, the number of temporary limited employees

hired governmentwide declined by about 47 percent from 282,135 in fiscal
year 1991 to 150, 395 in fiscal year 2000. 6 Except for small year- to- year
increases in fiscal years 1995, 1997, and 1998, the hiring of temporary
limited employees declined annually over this 10- year period. CPDF data
show that for permanent federal employees, the decline was about 19 percent
over the same 10- year period. The majority of temporary limited employees
were full- time hires in white- collar occupations who received some
benefits, including annual pay adjustments and premium pay. 5 The CPDF
contains personnel data for most of the executive branch departments and

agencies as well as a few agencies in the legislative branch. It does not
contain employee data for the Central Intelligence Agency, Defense
Intelligence Agency, the National Reconnaissance Office, the Board of
Governors of the Federal Reserve System, National Security Agency, Office of
the Vice President, Postal Rate Commission, Tennessee Valley Authority, U.
S. Postal Service, the White House Office, non- U. S. citizens working for
federal

agencies in foreign countries, most employees of activities that do not
receive congressional appropriations (e. g., the Department of Defense?s
Commissary Service); commissioned officers in the Department of Commerce,
Department of Health and Human Services, and the Environmental Protection
Agency; and all employees of the judicial branch. The CPDF also does not
contain data on temporary employees hired to assist the Department of
Commerce?s Census Bureau with the population and housing decennial census.

6 We defined hires to include appointments (when the person is not already
an employee of an agency) and conversions (appointment of a person already
employed by an agency but in a different position or under a different
hiring authority). A person may receive more than one appointment in any
given year.

However, these employees did not receive such benefits as retirement and
life insurance. After they worked for 1 year, they were eligible to buy
health insurance but had to pay the full cost of insurance.

According to the results of a survey we conducted at the 10 agencies that
were the predominant users of temporary limited employees, seasonal work was
the primary reason agency officials gave for using such employees, followed
by peak workload. The most often reported occupational series for fiscal
year 2000 was the office automation clerical and assistance series.

Reports and studies over the past 15 years that discuss temporary employment
indicate that although some differences exist between the federal
government?s use of temporary limited employees and that of the private
sector, the reasons federal agencies and private sector firms use

temporary employees are generally similar, primarily for staffing
flexibility. Differences include reasons that are acceptable uses of
temporary employees in the private sector (e. g., screening/ recruiting for
permanent positions and saving on wage and benefit costs) but not under the
regulations governing temporary employees in the federal government. Other
differences include reasons that are associated with aspects of federal
hiring (e. g., to temporarily place candidates awaiting final security

clearances and to work in continuing positions that could not be filled
permanently because of budget cuts).

Because temporary limited employees were serving for years under a series of
temporary appointments without the benefits afforded other long- term
employees, in 1994 OPM revised its regulations governing the use of
temporary appointments to help ensure that temporary employees were ?used to
meet truly short- term needs.? OPM stated that it developed ?those

regulations in response to Congressional and employee concerns and evidence
that some employees were, indeed, serving for years under a succession of
temporary appointments with no benefits and no job security.? The revised
regulations generally created a 2- year limit for individual temporary
appointments in both the competitive and excepted service. In addition, OPM
officials said that OPM?s Office of Merit Systems

Oversight and Effectiveness (OMSOE), which assesses agencies? effectiveness
in ensuring compliance with personnel laws and regulations, routinely
includes some individual temporary appointments in its periodic oversight
reviews of agencies but generally does not look at the work history of
temporary limited employees serving in those appointments. The officials
said that unless OMSOE knew in advance or saw a problem

based on prior audit reports or other sources, it would not focus on
temporary limited employees. Because of the typically limited nature of its
reviews of temporary limited appointments, OMSOE?s reviews of

agencies are unlikely to uncover instances of long- term temporary limited
employment.

CPDF data show that of those temporary limited employees hired
governmentwide in fiscal year 2000, about 16, 000, or 11 percent, had 5 or
more years in federal service. However, the CPDF data may include prior
permanent federal service for these temporary limited employees and do

not show any gaps in service that may have occurred. Therefore, OPM?s data
do not identify the number of temporary limited employees who worked for
continuous extended periods. Although the 10 agencies that were the
predominant users of temporary limited employees said they were monitoring
individual appointments of such employees to ensure that they were truly for
short- term needs, neither OPM nor the 10 agencies have been

monitoring the total years of temporary employment by these individuals. As
CPDF data show, a substantial number of temporary limited employees hired in
fiscal year 2000 have worked for the federal government for at least 5
years, and there is no way to determine from OPM?s data whether some of
these employees have worked for continuous extended periods. Therefore, we
recommend that the director of OPM direct the agency to conduct a

study to identify the number of temporary limited employees who have been
working for continuous extended periods in temporary limited appointments
and use the results of this study to modify the regulations governing
temporary limited employees to address any problem areas found. In addition,
the director should require OMSOE to include a sample of temporary limited
employees and their work histories as part of its periodic oversight reviews
of agencies. In commenting on a draft of this report, OPM agreed with our
recommendations. OPM?s written comments

are discussed near the end of this report and reproduced in appendix III.

Background Temporary limited appointments are appropriate for meeting a
range of staffing requirements when an agency expects there will be no
permanent need for an employee. Temporary employees can work on a full-
time, parttime,

seasonal, or intermittent basis. 7 Federal employers are prohibited from
using temporary employees to avoid the costs of employee benefits or
ceilings on permanent employment levels. Federal employers also cannot

use temporary employment as a ?tryout? or trial period prior to permanent
employment. In addition, federal employers cannot circumvent the competitive
examining process by appointing an individual on a temporary basis when that
individual is not among the list of qualified applicants certified for
permanent appointment. Finally, under OPM regulations,

federal employers generally cannot use a temporary appointment to refill
positions that were previously filled with such an appointment for an
aggregate of 24 months over the preceding 3 years. OPM states that although
agencies have the basic authority to make temporary limited appointments,
agencies must document the reason for each such appointment in an employee?s
official personnel folder. Agencies can use the appointing authority to: (1)
fill a short- term position

that is not expected to last longer than 1 year; (2) meet an employment need
that is scheduled to be terminated within 24 months for such reasons as
abolition, reorganization, contracting of the function, anticipated
reduction in funding, or completion of a specific project or peak workload;
or (3) fill positions temporarily when the positions are expected to be
needed for the eventual placement of permanent employees who would

otherwise be displaced from other parts of the organization. 7 Seasonal
positions involve annually recurring periods of work lasting less than 6
months or 1, 040 hours, and intermittent positions are positions in which
work recurs at sporadic or irregular intervals so that an employee?s tour of
duty cannot be scheduled in advance of the administrative work week.
Seasonal and intermittent positions are exempt from the general time limits
of temporary appointments.

Various changes in regulation have been made over the years restricting the
length of service of temporary limited employees. Beginning in 1938,
temporary employees generally could not continue past 30 days unless OPM?s
predecessor, the Civil Service Commission, approved the extension. In 1960,
the time a temporary appointment could remain in effect was extended, so
that appointments could be made for as long as 1 year. In 1984, OPM
increased the length of time an appointment could remain in effect, so that
agencies could extend a temporary employee?s service for a

total of 4 years from the date of initial appointment without OPM?s
approval. In response to this change in policy, MSPB reported in 1987 that
although the expanded authority was a positive addition to the

management tools available to federal managers, such flexibility could lead
to poor management practices that result in continuing staffing needs being
met with temporary employees because they were easier to hire
administratively. 8

Beginning in 1991, several hearings were held before subcommittees of the
House Committee on Post Office and Civil Service to receive complaints of
temporary employees. The hearings confirmed that federal agencies were
retaining employees in an ongoing series of temporary appointments for

long periods (8 to 10 years) without benefits or tenure. In a tragic
example, a National Park Service employee, James A. Hudson, who had worked
in an ongoing series of temporary limited appointments for 8 years, died on
July 5, 1993, after suffering a fatal heart attack after working three
shifts over a

2- day period during the July 4 weekend. Mr. Hudson, who was a decorated
Vietnam War veteran, was a full- time temporary worker whose survivors were
not entitled to a pension or government- subsidized health or life insurance
benefits. In response to his death, the Congress, as part of the Department
of the Interior and Related Agencies Appropriations Act of 1994, gave Mr.
Hudson?s widow a lump- sum payment of $38,400, the

amount his family would have received as life insurance benefits had he been
a permanent federal employee.

In 1994, responding to these hearings and information from other sources,
OPM revised its regulations governing agencies? use of temporary
appointments by reducing the time limit from a maximum of 4 years to 2

years and made the requirements uniform for temporary appointments in 8 U.
S. Merit Systems Protection Board, Expanded Authority for Temporary
Appointments: A Look at Merit Issues (Washington, D. C.: 1987).

both the competitive and excepted services. For an extension beyond 2 years,
agency officials must request and obtain approval from OPM.

Ten Agencies Were In fiscal year 2000, 10 agencies- the departments of
Agriculture,

Predominant Users of Commerce, Defense, HHS, the Interior, Justice, State,
the Treasury, and VA and FEMA- were the predominant users of temporary
limited employees. Temporary Limited These agencies also employed 84 percent
of all federal employees in that Employees year. Figure 1 shows the
percentage of temporary limited employees hired in fiscal year 2000 by the
10 agencies and all other agencies.

Figure 1: Agencies? Hiring of Temporary Limited Employees in Fiscal Year
2000

92.44% 10 Agencies

7.56% Other agencies

Source: GAO analysis of CPDF data.

Over the 10- year period, these 10 agencies accounted for slightly over 90
percent of all temporary limited employees hired governmentwide. Table 1
shows the number and percentage of temporary limited hires that the 10
agencies used each year.

Table 1: Number and Percentage of Temporary Limited Employees Hired by the
10 Agencies for Fiscal Years 1991 Through 2000

Temporary limited employees hired Percentage Fiscal year Governmentwide 10
Agencies of total

1991 282, 135 246,931 87.52 1992 256, 336 221,066 86.24 1993 236, 322
205,423 86.93 1994 214, 579 184,094 85.79 1995 217, 861 192,166 88.21 1996
160, 330 144,207 89.94 1997 162, 882 148,796 91.35 1998 164, 928 153,131
92.85 1999 160, 827 149,653 93.05 2000 a 150, 395 139,021 92.44 a The CPDF
does not contain data on temporary limited employees hired for the Decennial
Census of Population and Housing conducted by the Department of Commerce?s
Census Bureau. According to Census Bureau officials, 893,278 individuals
with temporary limited appointments worked on the decennial census during
fiscal year 2000. Census Bureau officials could not readily provide us the

overall number of appointments and conversions. Source: GAO analysis of CPDF
data.

The number of temporary limited employees hired governmentwide declined by
about 47 percent from fiscal year 1991 to fiscal year 2000. By comparison,
CPDF data show that for permanent federal employees, the

decline was about 19 percent over the same 10 years. 9 Except for small
year- to- year increases in fiscal years 1995, 1997, and 1998, the hiring of
temporary limited employees declined annually over these 10 years.

Temporary Limited Over the 10- year period, the majority of temporary
limited employees were Employees Were

full- time hires in white- collar occupations. These employees received some
benefits, including annual pay adjustments, overtime pay, and Mainly Full-
Time premium pay.

9 Permanent employee numbers used to compute this percentage consist of
employees who are on- board as of September 30 of each fiscal year and do
not include Senior Executive Service employees.

Work Schedule Temporary limited employees can work a full- time, part- time,
seasonal, or intermittent work schedule. From fiscal years 1991 through
2000, the majority of temporary limited employees were full- time hires.
Figure 2 contains data on temporary limited employees hired governmentwide
for fiscal years 1991 through 2000 by work schedule.

Figure 2: Temporary Limited Employees Hired Governmentwide by Work Schedule
for Fiscal Years 1991 Through 2000

300,000 Number of temporary limited employees hired

250,000 200,000 150,000 100,000

50,000 0

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Fiscal year

Total hires Full- time Seasonal/ intermittent Part- time

Source: GAO analysis of CPDF data.

Occupations and Grade Over the 10- year period, the majority of temporary
limited employees hired

Levels were in white- collar occupations. White- collar occupations include

professional, administrative, technical, and clerical occupations. The

remaining occupations were blue collar, comprising the trades, crafts, and
manual labor. Blue- collar occupations include foreman and supervisory
positions entailing trade, craft, or laboring experience and knowledge as
the paramount requirement. For fiscal year 2000, about 65 percent of

temporary limited employees belonged to 10 occupational series: (1) the
miscellaneous clerk and assistant series; (2) fabric and leather,
instrument, machine tool, metalwork, audio visual/ television/ video, etc.
series; (3) miscellaneous administrative and program series; (4) forestry
technician series; (5) office automation clerical and assistant series; (6)
general education and training series; (7) biological science and technician
series; (8) educational and vocational training series; (9) education and
training technician series; and (10) park ranger series. Figure 3 shows the
percentage of temporary limited employees hired governmentwide by occupation
category for the 10- year period.

Figure 3: Occupation Categories for Temporary Limited Employees Hired
Governmentwide for Fiscal Years 1991 Through 2000 100

Percentage of temporary limited employees hired 90 80 70 60 50 40 30 20 10

0 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 Fiscal year

White collar Blue collar

Note: In fiscal years 1995 and 1996, there were 2 and 3 percent of temporary
limited employees hired, respectively, whose occupations were classified as
unknown, and in the other 8 years, less than 0.5 percent were so classified.
Source: GAO analysis of CPDF data.

Most of the white- collar occupations were in the general schedule (GS) pay
plan, which consists of 15 grades of annual rates of basic pay. Table 2
shows the numbers of white- collar GS temporary limited employees hired
governmentwide by grade level.

Table 2: Number of White- Collar GS Temporary Limited Employees by Grade
Level for Fiscal Years 1991 Through 2000

GS grade levels Fiscal year GS 1- 4 GS 5- 8 GS 9- 12 GS 13- 15 Total GS

1991 102, 406 43,699 18,145 7,589 171, 839

1992 93, 206 45,409 18,270 7,773 164, 658

1993 81, 062 42,638 16,927 7,688 148, 315

1994 72, 079 39,992 16,626 6,277 134, 974

1995 91, 569 35,719 11,761 5,482 144, 531

1996 68, 599 24,305 8,441 2,873 104, 218

1997 68, 718 24,370 6,705 1,898 101, 691

1998 69, 709 24,993 7,141 1,917 103, 760

1999 63, 818 24,325 6,909 1,680 96, 732

2000 61, 897 22,781 6,348 1,598 92, 624

Source: GAO analysis of CPDF data.

Benefits Temporary limited employees receive some rights and benefits but
are not entitled to many of the rights and benefits available to permanent
federal employees. 10 Temporary limited employees, like permanent employees,

receive full salary based on the grade and step of the position they occupy,
annual pay adjustments, and overtime and premium pay. They also generally
earn annual and sick leave if they work a full- time or part- time schedule.
11 Part- time employees earn annual and sick leave on a prorated basis.
Seasonal employees can work full time or part time. Because

intermittent employees have no fixed work schedule, they do not earn annual
and sick leave. Temporary limited employees are not eligible for military
leave or family and medical leave.

Retirement and life insurance benefits are not provided to temporary limited
employees. 12 These employees cannot participate in the Thrift Savings Plan.
13 To be eligible for health insurance benefits, they must complete 1 year
of current continuous employment, excluding any break in

service of 5 days or less. Once eligible, they must pay the entire cost of
the insurance premium. 14 The government does not contribute toward the cost
of health insurance for temporary limited employees as it does for

permanent federal employees. Temporary limited employees in the GS pay plan
also do not receive withingrade pay increases. However, some blue- collar
temporary limited employees are eligible for within- grade pay increases.
Temporary limited employees cannot be converted to permanent positions, and
the time

10 A more complete and detailed listing of the rights and benefits available
to temporary limited employees can be found in U. S. Office of Personnel
Management, The Rights And Benefits of Temporary Employees in the Federal
Government (Washington, D. C.: 1993). According to OPM officials, the rights
and benefits discussed in that report have not changed.

11 Temporary limited employees with appointments for 90 days or less do not
earn annual leave; however, those who work beyond the 90 days become
eligible for leave from the beginning of the appointment.

12 Temporary limited employees contribute to social security and medicare.
13 The Thrift Savings Plan is a defined contribution retirement plan to
which permanent federal employees can contribute and accumulate assets in
the form of a savings plan.

14 Data provided by an OPM official show that as of September 30, 2000,
about 16 percent of temporary limited employees were eligible for health
insurance coverage and about 51 percent of those eligible enrolled.

served in a temporary limited position is not creditable service for federal
retirement.

Agency Officials? According to the results of our survey of the 10 agencies
that were the Responses Indicate

predominant users of temporary limited employees, seasonal work was the
primary reason agency officials gave for using such employees. Agency
Seasonal Work Was the officials? responses indicate that 37 percent of the
temporary limited Primary Reason for

employees hired in fiscal year 2000 in their agencies were for seasonal
Using Temporary work. Those officials? responses indicate that 20 percent of
temporary limited employees were hired in fiscal year 2000 because of peak
workload.

Limited Employees Overall, 18 percent of the temporary limited employees
hired in fiscal year

2000 were students, including students in associate, graduate, or
professional degree programs. Figure 4 shows the percentage of temporary
limited employees hired in fiscal year 2000 for each reason provided.

Figure 4: Percentage of Temporary Limited Employees Hired as Identified by
the 10 Agencies in Fiscal Year 2000 by Specific Reason 40

Percentage hired in fiscal year 2000 35 30 25 20 15 10

5 0

be out

Seasonal work Peak workload

Special project

to Funding reduction Abolish/

reorganize Other

Function contracted Reasons

Note: ?Other? includes students, who account for 18 percent. The remaining 6
percent include unspecified reasons.

Source: GAO survey data.

Figure 5 shows, by reason, the most prevalent occupations identified by our
survey of the 10 agencies that were the predominant users of temporary
limited employees. The most often reported occupational series for fiscal
year 2000 was the office automation clerical and assistance series.

Figure 5: Most Prevalent Occupations by Reason for Fiscal Year 2000 as
Identified by Our Survey of 10 Agencies

work be out

workload project

to Most prevalent Reasons

Seasonal Peak Special Function contracted Other

occupations Description of work

Biological science technician series Supports production, research,
operations, or program administration efforts in laboratories, field, or
other settings including greenhouses, barns, caves, or wildlife refuges.

Clerk- typist series Involves typing performed solely or in combination with
general clerical work that does not

require specialized experience or training. Computer clerk and assistant
series

Includes positions involving performance or supervision of data processing
support and services functions for users of digital computer systems.

General student trainee series Includes trainee positions in each
occupational group that involve periods of pertinent formal

education and periods of employment in a federal agency; both of which must
be part of a formal student employment program.

Laboring series Includes such jobs as mowing lawns, washing cars, digging
ditches, loading and unloading

trucks, and moving furniture; requiring mainly physical abilities and
effort. Mail and file series

Covers the administration, supervision, or performance of clerical work
related to the processing of incoming or outgoing mail and/ or the
systematic arrangement of records for storage or reference purposes and the
scheduled disposition of records.

Miscellaneous administration and Involves the performance, supervision, or
management of nonprofessional work that requires

program series analytical ability, judgment, discretion, and knowledge of a
substantial body of administrative or

program principles. Miscellaneous clerk and assistant

Involves performing or supervising clerical, assistant, or technician work.
series

Office automation clerical and Includes word processing, either solely or
combined with clerical work.

assistance series Park ranger series

Includes such work in the conservation and use of federal parks as forest
and structural fire control; dissemination to visitors of general,
historical, or scientific information; folk- art and craft demonstrations;
and search and rescue missions.

Note 1: Our criterion for identifying primary reasons was that at least four
agency components listed a reason in their survey responses.

Note 2: ?Other? includes students. Source: GAO survey data.

Studies Indicate We reviewed reports and studies published over the past 15
years that Reasons Public and discussed aspects of temporary employment in
the public and private

sectors. Although studies indicate that some differences exist between the
Private Sectors Use federal government?s use of temporary limited employees
and that of the Temporary Employees

private sector, they also indicate that the reasons federal agencies and Are
Generally Similar

private sector firms use temporary employees are generally similar. The
primary use for both sectors concern scheduling flexibility for staffing so
that employers could use temporary employees in such instances as to fill in
for absent regular employees; to fill seasonal needs; and to provide

needed assistance at times of unexpected increases in business or to meet
fluctuations in workload. Differences between the sectors include reasons
that are acceptable uses of temporary employees in the private sector (e.
g., to screen/ recruit for filling permanent positions and to save on wage
and benefit costs) but not allowed under the regulations governing temporary
employees in the federal government. Other differences include reasons that
are associated with aspects of federal hiring, such as temporarily employing
candidates awaiting final security clearances and using temporary help in
continuing positions that could not be filled permanently due to budget
cuts.

In June 1997, an employer study was published based on a survey designed to
be representative of employment in private sector establishments with five
or more employees in the United States. 15 This study directly addressed why
private sector employers used temporary employees and divided the reasons
into two categories. The first category consisted of reasons concerning
staffing levels, including

 filling vacancies until regular employees are hired;

 filling in for absent regular employees who are sick, on vacation, or on
family medical leave;

 filling seasonal needs;

 providing needed assistance during peak- time hours of the day or week;

 providing needed assistance at times of unexpected increases in business;

 staffing special projects; and 15 Susan N. Houseman, Temporary, Part-
Time, and Contract Employment in the United States: A Report on the W. E.
Upjohn Institute?s Employer Survey on Flexible Staffing Policies (Kalamazoo,
MI: W. E. Upjohn Institute for Employment Research, 1996, revised 1997).

 providing needed assistance during hours not covered by full- time shifts.
The second category consisted of varied reasons, including

 screening job candidates for regular jobs,

 saving on wage and/ or benefit costs,

 providing needed assistance during company restructuring or merger,

 filling positions with temporary workers for more than a year,

 saving on training costs,

 gaining special expertise possessed by this type of worker,

 accommodating employees? wishes for part- time hours, and

 hiring part- time workers because of an inability to find qualified
fulltime workers.

No comparable study has been done recently for the federal sector. However,
in 1987, MSPB issued a report on temporary appointments in the federal
government 16 in which MSPB included the responses of 21 departments and
independent agencies that, among other things, included a discussion of the
reasons agencies cited for using temporary appointments. According to the
MSPB report, most agencies expressed their responses in general terms
concerning

 positions not expected to last more than 1 year,

 seasonal positions,

 part- time and intermittent positions that are not clearly of a continuing
nature, and

 continuing positions when temporarily vacated for periods of less than 1
year. In addition, some agencies provided specific examples, including

 hiring postgraduate students to work on research projects that will last
several years;

 temporarily placing candidates in less sensitive positions while they wait
for final security clearances;

 placing workers in continuing positions that could not be filled
permanently due to budget cuts;

16 U. S. Merit Systems Protection Board, Expanded Authority for Temporary
Appointments: A Look at Merit Issues (Washington, D. C.: 1987).

 filling shortage category and hard- to- fill positions, pending
certification from OPM; 17 and

 preventing a loss of candidates to private industry in occupations like
computer specialist by having the ability to hire such candidates in 2 or 3
weeks with conversion to permanent employment at a later date.

According to the MSPB report, the last two reasons, in particular, indicated
possible merit system concerns.

Other studies that provide reasons agencies cited for using temporary
employees concern specific agencies or agency components. 18 These reasons
included using temporary employees

 to meet fluctuations in workload,

 to address uncertain funding, and

 to screen candidates before hiring them permanently. According to OPM, the
last two reasons are not appropriate uses of temporary limited employees in
the federal government.

OPM Revised Its As with its other regulations, OPM is responsible for
ensuring that agencies Regulations to Ensure

adhere to its regulations concerning temporary employees. In 1994, OPM
revised its regulations governing temporary appointments. OPM stated the
Appropriate Use of that its intention in revising the regulations was to
ensure that temporary Temporary Limited

limited employees were used to meet truly short- term needs and were not
Appointments, but

serving for years under a series of temporary appointments without many of
the benefits afforded other long- term employees. The 10 agencies that

Long- Term Use May are the predominant users of temporary limited employees
stated that they Still Exist

have been ensuring the need for individual temporary appointments and
monitoring the time limits imposed on such appointments. According to 17
Certification is the process by which a list of qualified applicants are
compiled in order of

relative standing and presented to an appointing official for employment
consideration. 18 U. S. General Accounting Office, Federal Workforce: Use of
Temporary Employees at Three Puget Sound Naval Installations, GAO/ GGD- 88-
76 (Washington, D. C.: 1988). U. S. Office of Personnel Management,
Personnel Systems and Oversight Group, Agency Compliance and Evaluation,
Temporary Employment Within Land Management Agencies of the Federal
Government (Washington, D. C.: 1992). U. S. Office of Personnel Management,
Office of Merit Systems Oversight and Effectiveness, Report of a Special
Joint Review With Defense Commissary Agency on Temporary/ Intermittent
Employment (Washington, D. C.: 1996).

OPM and agency officials, however, neither OPM nor any of the 10 agencies
have been monitoring the total years of continuous temporary employment by
these individuals. CPDF data, the best available information, show that of
those temporary limited employees hired governmentwide in fiscal year 2000,
about 16, 000, or about 11 percent, had 5 or more years of federal service.
However, limitations in the CPDF data prevent a determination of the number
of individuals who spend long periods of continuous federal service in
temporary limited positions without many of the benefits afforded other
long- term employees. OMSOE Reviews Not

In 1994, OPM revised its regulations governing the use of temporary limited
Normally Designed to

appointments to help ensure that such employees are used to meet truly
Assess Temporary Limited

short- term needs. Congressional hearings and information from other
Appointments in Detail sources prompted OPM to act because some temporary
limited employees were serving for years under a series of temporary limited
appointments without many of the benefits afforded other long- term
employees. For

example, a 1992 OPM study reported that many nonpermanent seasonal employees
in the land management agencies were ?making a career? out of temporary
work. 19 The revised regulations reduced the time limit for individual
temporary limited appointments from 4 to 2 continuous years of temporary
service in a position.

OPM?s revised regulations governing temporary appointments also generally
limit agencies from refilling any position or its successor (i. e., a
position that replaces and absorbs the original position) with a temporary
appointment if that position had been filled by a temporary appointment in
either the competitive or excepted service for a total of 2 years during the

preceding 3 years. Positions involving seasonal work (i. e., work that
involves annual recurring periods of less than 6 months) or intermittent
work (i. e., work that involves sporadic or irregular intervals) are
exceptions to such limits and restrictions. Under its regulations governing
temporary limited appointments in the competitive service, OPM requires the
supervisor of each position filled by temporary limited appointment to
certify that the employment need is truly temporary and that the proposed
appointment meets the regulatory time limits. The regulations do not

19 U. S. Office of Personnel Management, Personnel Systems and Oversight
Group, Agency Compliance and Evaluation, Temporary Employment Within Land
Management Agencies of the Federal Government (Washington, D. C.: 1992).

require such certification for excepted service temporary limited
appointments.

We contacted the 10 agencies that we identified as the predominant users of
temporary limited employees to identify steps that they were taking to
ensure the appropriate use of such employees. Officials from the 10 agencies
generally stated that they monitor the time limits on individual

temporary limited appointments to ensure that such appointments adhere to
the regulatory time limits and that they rely on the supervisors of such
employees to ensure that the employment needs are truly temporary. According
to an OPM official, holding agencies accountable for compliance with OPM?s
temporary limited employment regulations is necessary for sound human
resources administration. The official stated that OPM monitors agencies?
compliance with temporary limited employment during the evaluation visits
conducted by OMSOE, which assesses agencies? effectiveness in ensuring
compliance with personnel laws and regulations.

According to OMSOE, each of the departmental agencies and independent
agencies with larger numbers of employees is subject to review every 4
years, and each of the smaller independent agencies is reviewed every 5
years. 20

An OPM official said that OMSOE routinely includes some individual temporary
appointments in its periodic oversight reviews but generally does not look
at the work history of temporary limited employees serving

in those appointments. The officials said that unless OMSOE knew in advance
or saw a problem based on prior audit reports or other sources, it would not
focus on temporary limited employees. Because of the typically limited
nature of its reviews of temporary limited appointments, OMSOE?s reviews of
agencies are unlikely to uncover instances of long- term temporary limited
employment. In reviewing authorities used by an agency, OMSOE follows a
standard audit procedure of selecting a

judgmental sample of appointments for review. OMSOE uses a ?problem

oriented? sampling to select appointments. That means that if OMSOE
officials have identified problems with a specific type of appointment
through such sources as employee complaints and periodic employee

20 However, OMSOE does not necessarily review each office within an agency
each time it conducts an agency review. Each OMSOE audit team determines
which offices within an agency will be reviewed based on a presite
assessment of prior audit reports and other sources.

attitude surveys, the audit team will include some of those appointments in
the sample of appointments it reviews. If temporary limited appointments
were suspected of being a problem area, the review might involve more work
in this area. For example, because of an indication of possible
inappropriate use of the appointing authority for temporary limited
employees at the Department of the Interior, OMSOE did an assessment of
seasonal employment at the National Park Service. In 1998, after completing
its review, OMSOE reported that a number of parks in the

Department of the Interior?s National Park Service with seasons lasting
longer than 6 months were improperly filling seasonal positions with
temporary limited appointments. However, according to an OMSOE official,
OMSOE normally looked at the appropriateness of individual appointments and
other aspects of compliance with OPM regulations.

Regulations Include There are several ways that temporary limited employees
can work for Provisions That Could

more than the 2- year limit on individual temporary appointments. In its
Result in Long- Term Use of

regulations, OPM recognizes circumstances when agencies may require the
Temporary Limited

service of temporary limited employees beyond the allowed 2 years. To extend
a temporary limited appointment in the same position beyond the Employees

maximum of 2 years, agency officials must request and obtain approval from
OPM. According to OPM, in fiscal year 1998, it approved 110 requests
covering 332 employees; in fiscal year 1999, 165 requests covering 426
employees; and in fiscal year 2000, 180 requests covering 418 employees.
Moreover, temporary limited employees can serve for continuous years under
different temporary appointments or in the same appointment without an
extension from OPM. If it involves a break in service of 3 days or less, an
agency can reappoint or convert a temporary limited employee from one
temporary appointment to another temporary appointment many

times over a period of years and not conflict with OPM?s regulations. 21 In
addition, after 3 days have elapsed after a temporary appointment ends, an
agency can rehire the employee using a new temporary limited appointment as
long as it does not involve the same basic duties, the same major
subdivision of the agency, and the same local commuting area as the

original appointment. However, the CPDF does not contain the necessary
information to identify whether new temporary appointments were formerly
temporary limited employees.

21 A conversion is an appointment made by an agency of a person already
employed by that agency but in a different position or under a different
hiring authority.

As shown in table 3, CPDF data show that from fiscal years 1991 through
2000, between 30 and 46 percent of the temporary limited employees hired
annually governmentwide were conversions within an agency.

Table 3: Temporary Limited Hires Governmentwide That Were Conversions From
One Temporary Appointment to Another Temporary Appointment in the Same
Agency, Fiscal Years 1991 through 2000

Number of temporary Percentage of temporary

limited employees limited hires that were

Fiscal year hired governmentwide Total conversions

conversions

1991 282,135 108, 457 38. 44 1992 256,336 106, 575 41. 58 1993 236,322 108,
643 45. 97 1994 214,579 93,290 43.48 1995 217,861 94,951 43.58 1996 160,330
52,808 32.94 1997 162,882 52,309 32.11 1998 164,928 54,339 32.98 1999
160,827 49,124 30.54 2000 150,395 45,117 30.00

Source: GAO analysis of CPDF data.

According to an OPM official, there is no limit on the number of times that
an agency can convert a temporary limited employee to another temporary
limited appointment within the same agency as long as two conditions are
met. First, conversions to competitive temporary appointments must be
accomplished using a competitive selection method or must be based on
noncompetitive eligibility. 22 Second, the regulatory provisions limiting
appointments to successor positions must be met.

Finally, agencies can also exceed the general time limits of some temporary
limited employees. Under OPM regulations, an agency can appoint and

22 A competitive selection method is a competitive process that consists of
open competitive examination under the civil service laws, rules, and
regulations. Noncompetitive eligibility is an individual?s ability to be
eligible for (or subject to) a personnel action based on the person's having
obtained such eligibility for (or becoming subject to) the action through a
previous open competitive process. For example, career ladder promotions,
demotions, reassignments, transfers, reinstatements, or appointments based
on prior service are

noncompetitive actions.

extend an employee in a seasonal or intermittent temporary limited position
without regard to the 2- year general time limit as long as the time the
employee worked annually was less than 6 months, or 1,040 hours. It is also
permissible for different subunits of an agency to hire the same person

for more than one seasonal appointment lasting for up to 6 months. Thus, a
seasonal temporary limited employee could work full time for two subunits in
an agency under two different 6- month temporary limited appointments in the
same year. CPDF data show that from fiscal years 1991 through 2000, between
25 and 36 percent of temporary limited employees hired had a seasonal or
intermittent work schedule.

These scenarios could, as OPM reported in 1992, result in nonpermanent
employment- which is intended for short- term staffing needs- becoming
quasipermanent. In that report, OPM focused on seasonal temporary

employment at land management agencies and stated that many nonpermanent
employees were making a career out of temporary work in these agencies. OPM
reported that thousands of park rangers on temporary seasonal appointments
work the summer season in one park and the winter season in another, 23
working virtually full time on temporary appointments. An OPM official said
that OPM?s oversight policy is to look

at each park as a separate employer. This would permit such situations to
continue today.

In addition, OPM reported that more than 20 percent of the temporary
workforce at land management agencies had held 10 or more temporary
appointments or extensions to existing appointments. According to a
September 1994 MSPB report, retaining temporary employees for extended
periods (8 or 10 years or more) through the use of temporary appointments is
directly contrary to the explicit intent of the temporary employment
authority and denies employees involved many of the benefits available to

other long- term employees. We analyzed CPDF data to estimate the extent to
which individuals may be spending long periods in federal service as
temporary limited employees without many of the benefits afforded other
long- term employees. Our analysis showed that of the temporary limited
employees hired in fiscal year 2000, 78 percent had federal service of 2
years or less. However, CPDF 23 Many national parks have both a summer and
winter season, but under the National Park Service excepted appointing
authority, park rangers are prohibited from working more than 180 working
days in the same park.

data also showed about 16,000, or about 11 percent, had 5 or more years of
federal service. Table 4 shows a breakdown by type of temporary limited
employee.

Table 4: Temporary Limited Employees Hired in Fiscal Year 2000 Who Had 5 or
More Years of Federal Service

Types of temporary limited employees 5 to 10 years 10 or more years Total

Full- time 2, 869 2,560 5,429

Part- time 231 251 482

Seasonal/ intermittent 3,746 5, 988 9,734

Student 513 74 587 Total 7, 359 8, 873 16,232

Note 1: A type of temporary limited employee that is included but not broken
out separately are reemployed civil service annuitants. Unlike other
temporary limited employees, reemployed annuitants generally are entitled to
health and other benefits as a result of their retirement from prior federal
service. It is not possible to determine from CPDF data exactly how many of
the total number of temporary limited employees hired in fiscal year 2000,
or the 16,232 individuals who may have worked

more than 5 years, are reemployed annuitants. However, CPDF data show that
1,754 of the 16,232 had 25 or more years of federal service.

Note 2: These data exclude military service. Source: GAO analysis of CPDF
data.

The information in table 4, however, is imprecise because of limitations in
the data available in the CPDF, specifically in service computation dates. A
service computation date allows OPM and agencies to track an employee?s
creditable years of federal service (civilian and military) toward
retirement and other benefits. For each federal employee, this date is
adjusted with every transfer, separation, or reinstatement experience over
the course of the employee?s career. The purpose of having a service
computation date is so that at any point in time there is a reasonably
accurate measure of an

employee?s length of service. The service computation date includes
permanent federal employment as well as temporary service without regard to
when such service was performed. For example, a current temporary limited
employee?s service computation date indicating 10 years

of service could include years of prior military service, 24 permanent
federal civilian service, and temporary limited employment over an extended
24 Our analysis excluded military service.

period with substantial gaps between appointments. Although CPDF data are
the best available information and show that some temporary limited
employees had been working for long periods in federal service, it is not
possible to determine how many temporary limited employees actually worked
for continuous extended periods in temporary limited

appointments. Most of the 16,232 temporary limited employees hired in fiscal
year 2000 who had 5 or more years in federal service were hired under
seasonal appointments. As mentioned earlier, as long as employees hired
under seasonal appointments work less than 1, 040 hours per appointment,
OPM?s

regulations allow agencies to hire and extend such employees for years.
Because agencies reported to us that they were monitoring only individual
appointments, they would not necessarily know whether seasonal or other
temporary limited employees might have been working for 5 or more years.

They also might not know whether employees serving in seasonal appointments
could have been hired for more than one seasonal appointment in any given
year. As was the case with the park ranger example cited earlier, such
employees could be working on two separate 6month seasonal appointments-
virtually full time on temporary appointments- without an agency or OPM
being aware of it and without many of the benefits afforded other long- term
employees.

According to officials from OPM and the 10 agencies that we identified as
the predominant users of temporary limited employees, neither OPM nor the
agencies monitor the total length of service for temporary limited
employees. According to OPM officials, identifying the total length of
continuous service of temporary limited employees would require doing a

?longitudinal,? or historical study tracing the service of individual
employees back in time. Conclusions From fiscal years 1991 through 2000, the
majority of temporary limited

employees were full- time hires in white- collar occupations, eligible to
receive annual pay adjustments, overtime, and premium pay and generally
earning annual and sick leave. These employees did not receive retirement
and life insurance benefits but could buy health insurance after they worked
for more than 1 continuous year if they were willing to pay the full cost of
the insurance. In 1994, OPM revised its regulations governing temporary
limited employees, generally creating a 2- year limit for each temporary

appointment. OPM stated that its intention in revising the regulations was
to help ensure that temporary limited employees would be used to meet truly
short- term needs and not serve for years without many of the benefits
afforded other long- term employees. However, the regulations do not
preclude agencies from hiring temporary limited employees to work in a

series of extensions, reappointments, and appointments. Thus, there seems to
be an inconsistency between OPM?s stated intent and what is permissible
under the provisions of its regulations. The regulations allow

agencies to continue a pattern of repetitive temporary appointments that
result in long- term temporary limited employees not receiving many of the
benefits available to other long- term employees. CPDF data on the total
years of service of temporary limited employees show that of such employees
hired governmentwide in fiscal year 2000, about 16, 000, or 11 percent, had
5 or more years of federal service. However, the limitations of these data
combined with the fact that neither OPM nor agencies monitor the total years
of temporary employment by

temporary limited employees raise a concern that temporary limited employees
could be serving for many years under a series of appointments. In addition,
OMSOE reviews of agencies are unlikely to uncover incidents of long- term
temporary limited employment because they typically look only at individual
appointments but not the work history of temporary limited employees serving
in those appointments.

The CPDF data available to OPM and agencies for determining the time federal
employees spend in federal service include all federal service, both
temporary and permanent federal employment, without regard to the total
length of time over which such service was performed. Neither OPM nor
agencies collect the necessary information that would identify whether, in

fact, temporary limited employees were working continuously for years. There
is no way to tell from the CPDF whether employees might be serving in
temporary limited appointments for continuous extended periods or how many
may be receiving benefits, for example, as a result of retiring from prior
federal service. Identifying the total length of continuous service of
temporary limited employees would require doing a ?longitudinal,? or
historical study tracing the service of individual employees back in time.

Recommendations We recommend that the director of OPM direct OMSOE to
conduct a study to identify the number of temporary limited employees who
have been

working for continuous extended periods in temporary limited

appointments and the reasons and conditions that permitted such cases to
occur. The director should use the results of this study to modify the
regulations governing temporary limited employees to address any problem
areas found. In addition, the director should require OMSOE to include a
sample of temporary limited employees and their work histories

as part of its periodic oversight reviews of agencies. Agency Comments We
sent a draft report to OPM in which we proposed that the director of OPM
clarify regulations on temporary limited employees so that they address the
amount of time such employees may serve in a series of temporary
appointments and better track compliance with the revised

regulations. We discussed this draft with OPM officials, who did not believe
that enough information was available to determine the nature of any
problems related to temporary limited employees working for extended periods
and how to revise the regulations. Therefore, we revised the draft report to
recommend that the director of OPM direct the agency to conduct a study to
identify the number of temporary limited employees who have been working for
continuous extended periods in temporary limited appointments and the
reasons and conditions that permitted such cases to occur. We also
recommended that the director require OMSOE to include a sample of temporary
limited employees and their work histories

as part of its periodic oversight reviews of agencies. In a letter dated
February 19, 2002, (see app. III) the director of OPM provided comments on
the revised draft of this report. OPM agreed with both of these

recommendations and said that they would be implemented. Our other
recommendation was that the director should use the results of the
recommended study to modify the regulations governing temporary limited
employees to address any problem areas found. OPM did not specify precisely
what it would do in response to this recommendation but

said that any problems identified would be addressed through recommended or
required corrective actions. As agreed with your offices, unless you
publicly announce the contents of this report earlier, we plan no further
distribution until 30 days from the date of this letter. At that time, we
will send copies of this report to the chairman and ranking member, Senate
Committee on Governmental

Affairs; the chairman and ranking member, House Committee on Government
Reform; and the director of the Office of Personnel

Management. We will also send copies of this report to the heads of the 10
agencies that participated in our survey and other interested parties. We
will also make copies available to others on request. Please contact me on
(202) 512- 6806 if you or your staff have questions. Key contributors to
this report are listed in appendix IV.

Victor S. Rezendes Managing Director, Strategic Issues

Appendi xes Agency Questionnaire on Temporary Limited

Appendi x I

Employees Agency Questionnaire on Temporary Limited Employees

    

Temporary Limited Employees Agency Questionnaire

 

The General Accounting Office has been asked by Senators Barbara Mikulski
and Paul Sarbanes to obtain information on the federal government?s use of
temporary employees. Specifically, the requestors are interested in the use
of temporary limited employees, as defined in the Code of Federal
Regulations (5 C. F. R. 316.401), excluding those with provisional
appointments (5 C. F. R. 316.403). Federal agencies may also hire temporary
limited employees under agency- specific hiring authority. Temporary limited
employees are used to fill short- term needs (that is, the initial
appointment may not exceed 1 year and generally may be extended up to a
maximum of 1 additional year), although temporary limited appointments that
involve intermittent and seasonal work may exceed the 2- year limit. We are
sending this questionnaire to 10 federal agencies whose selected components
are the major users of temporary limited employees. The information that we
are requesting is not available from either the Office of Personnel
Management (OPM) or its Central Personnel Data File (CPDF).

Please provide this questionnaire to the agency component indicated below on
this page and have the component complete the questionnaire. Then, return
the completed questionnaires for all of the components in a single group to
us, along with any additional requested information, within 15 working days
of receipt to the address listed below. You may fax your response to us on
(202) 512- 4516, to the attention of Kiki Theodoropoulos, and follow up with
copies of any additional information by mail or courier.

The return address is: U. S. General Accounting Office Attention: Kiki
Theodoropoulos 441 G Street, N. W., Room 2908 Washington, D. C. 20548

If you have any questions, please contact Kiki Theodoropoulos on (202) 512-
4579 or at

theodoropoulosv@ gao. gov or Molly Gleeson on (202) 512- 4940 or at
gleesonm@ gao. gov.

Thank you for your cooperation. Agency/ Component:
___________________________________

Please provide the following information:

Name of person completing questionnaire: __________________________________
Title of person completing questionnaire: __________________________________
Telephone number: (_____)_____________ Fax number: (_____)_____________ E-
mail address: ____________________________

  According to OPM?s Central Personnel Data File (CPDF), _____________
hired _________ temporary limited employees, as defined in 5 C. F. R.
316.401, during fiscal year 2000. Not included are temporary limited
employees with provisional appointments under 5 C. F. R. 316.403. For each
of the reasons listed below, please provide:

 the approximate number of temporary limited employees who were hired by
your agency component during fiscal year 2000 for each of the reasons listed
below and

 the six most prevalent (in terms of number hired) occupations of temporary
limited employees hired for each reason.

Reason Approximate Occupations

number hired

(Enter occupational series code and title.

during FY 2000

Enter a maximum of six occupations.)

Seasonal work 1. ____ ___________________

4. ____ ___________________ ________

2. ____ ___________________ 5. ____ ___________________

3. ____ ___________________ 6. ____ ___________________

Peak workload 1. ____ ___________________

4. ____ ___________________ ________

2. ____ ___________________ 5. ____ ___________________

3. ____ ___________________ 6. ____ ___________________

Completion of 1. ____ ___________________

4. ____ ___________________ special project ________

2. ____ ___________________ 5. ____ ___________________

3. ____ ___________________ 6. ____ ___________________

Anticipated 1. ____ ___________________

4. ____ ___________________ reduction in

________ 2. ____ ___________________

5. ____ ___________________ funding

3. ____ ___________________ 6. ____ ___________________

Function to be 1. ____ ___________________

4. ____ ___________________ contracted out ________

2. ____ ___________________ 5. ____ ___________________

3. ____ ___________________ 6. ____ ___________________

Abolishment or 1. ____ ___________________

4. ____ ___________________ reorganization of

________ 2. ____ ___________________

5. ____ ___________________ function

3. ____ ___________________ 6. ____ ___________________

Other - specify: 1. ____ ___________________

4. ____ ___________________ _______________ ________

2. ____ ___________________ 5. ____ ___________________

3. ____ ___________________ 6. ____ ___________________

  According to the CPDF, ______________ hired the following numbers of
temporary limited employees, as defined in 5 C. F. R. 316.401, for fiscal
years 1995 through 2000. Temporary limited employees with provisional
appointments under 5 C. F. R. 316.403 were excluded.

Fiscal year Number of temporary limited employees hired 1995 1996 1997 1998
1999 2000

Please explain the reason( s) for any increases, decreases, fluctuations, or
static situations in the above data.

  In addition to the temporary hires identified in question 1, did your
agency hire under authorities

other than 5 C. F. R. 316.401 temporary employees whose initial appointment
may not exceed 1 year and generally may be extended up to a maximum of 1
additional year (excluding provisional appointments under 5 C. F. R.
316.403)? These other authorities could include excepted service and agency
specific authorities. (Check one.)

1. Yes Continue with questions 4 through 6 . 2. No Questionnaire is now
complete.

  Please provide the following information for the temporary employees
hired in fiscal year 2000 under authorities other than 5 C. F. R. 316.401:

 the approximate number of temporary employees who were hired by your
agency during fiscal year 2000 for each of the reasons listed below and

 the six most prevalent (in terms of number hired) occupations of temporary
limited employees hired for each reason.

Reason Approximate Occupations

number hired

(Enter occupational series code and title.

during FY 2000

Enter a maximum of six occupations.)

1. ____ ___________________ 4. ____ ___________________

Seasonal work 2. ____ ___________________

5. ____ ___________________ ________

3. ____ ___________________ 6. ____ ___________________

1. ____ ___________________ 4. ____ ___________________

Peak workload 2. ____ ___________________

5. ____ ___________________ ________

3. ____ ___________________ 6. ____ ___________________

1. ____ ___________________ 4. ____ ___________________

Completion of 2. ____ ___________________

5. ____ ___________________ special project ________

3. ____ ___________________ 6. ____ ___________________

1. ____ ___________________ 4. ____ ___________________

Anticipated 2. ____ ___________________

5. ____ ___________________ reduction in

________ funding

3. ____ ___________________ 6. ____ ___________________

1. ____ ___________________ 4. ____ ___________________

Function to be 2. ____ ___________________

5. ____ ___________________ contracted out ________

3. ____ ___________________ 6. ____ ___________________

1. ____ ___________________ 4. ____ ___________________

Abolishment or 2. ____ ___________________

5. ____ ___________________ reorganization of

________ function

3. ____ ___________________ 6. ____ ___________________

Other - specify: 1. ____ ___________________

4. ____ ___________________ ________

2. ____ ___________________ 5. ____ ___________________

_______________ 3. ____ ___________________ 6. ____ ___________________

  Please provide the following information for the temporary employees
hired in fiscal year 2000 under authorities other than 5 C. F. R. 316.401:

 the nature of action code

 the legal authority code

 the title of the legal authority

 the number of employees hired under this legal authority, and

 the benefits (if any) that are available to these employees.

Nature of Legal

Legal Number of

Benefits available action

authority authority title

employees

(Check all that apply.

code code

hired

If none, check ?Other? and specify ?none?.)

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

Retirement Health Insurance

Life insurance Other - specify below: _____________________________________

  In addition to the authorities in question 5, does your agency have
additional agency- specific regulations, instructions, or guidance for
hiring and providing benefits for such temporary employees?

1. Yes Please return a copy of the instructions or guidance with the
completed questionnaire.

2. No Thank you very much for your assistance.

Appendi x II

Objectives, Scope, and Methodology Senators Barbara A. Mikulski and Paul S.
Sarbanes asked us to gather information on federal civilian temporary
employees, specifically temporary limited employees. Our objectives were to
(1) identify the federal agencies that are the predominant users of
temporary limited employees and the job characteristics of such employees
(including work schedules, occupations, grade levels, and benefits); (2)
discuss the primary reasons agencies give for using temporary limited
employees; and (3) compare the federal government?s use of temporary limited
employees with that of the private sector. In addition, we agreed to
identify steps OPM has taken to ensure the appropriate use of temporary
limited employees and whether long- term use of temporary limited employees
still exists.

To identify the federal agencies that are the predominant users of temporary
limited employees and the job characteristics of such employees, OPM
initially provided us with summary data listing temporary limited employment
by agency on a quarterly basis from March 1999 through March 2000. On the
basis of OPM?s list, we identified agencies as predominant users of
temporary limited employees if they had 1,000 or

more temporary limited employees on- board as of March 30, 2000. Ten
agencies met our criterion for being predominant users: the departments of
Agriculture, Commerce, Defense, HHS, the Interior, Justice, State, the

Treasury, and VA and FEMA. These 10 agencies accounted for 94 percent of the
executive branch?s temporary limited workforce on- board as of March 30,
2000, according to data provided by an OPM official.

We then reviewed temporary limited employment data contained in OPM?s CPDF,
a database that contains personnel data for most of the executive branch
agencies, including all of the cabinet departments, independent

agencies, commissions, and councils. 25 To analyze CPDF data, we used an
approach that an OPM official said would extract data from the CPDF on
temporary limited employees. During our analysis, we found that OPM?s
approach extracted data on other types of temporary employees (who can

25 The CPDF does not contain employee data for the Central Intelligence
Agency, Defense Intelligence Agency, National Reconnaissance Office, Board
of Governors of the Federal Reserve System, National Security Agency, Office
of the Vice President, Postal Rate Commission, Tennessee Valley Authority,
U. S. Postal Service, White House Office, non- U. S. citizens working for
federal agencies in foreign countries, most employees of activities that do
not receive congressional appropriations (e. g., the Department of Defense?s
Commissary

Service); commissioned officers in the Department of Commerce, HHS, and the
Environmental Protection Agency; and all employees of the judicial branch.
The CPDF also does not contain data on temporary employees hired to assist
the Department of

Commerce?s Census Bureau with the population and housing decennial census.

be appointed for more than 1 year and are entitled to the same benefits as
permanent employees) as well as temporary limited employees. The OPM
official later confirmed that OPM?s approach captured other types of
temporary employees.

Because OPM?s approach captured more than just temporary limited employee
data, we had to use another approach and criteria to select data from the
CPDF on competitive service temporary limited employees and excepted service
employees who meet the temporary limited criteria. As there is no code in
the CPDF to identify which current federal employees are temporary limited
employees, we reviewed temporary limited appointments and conversions, which
are identifiable. For the competitive service, we reviewed the nature of
action codes (NOAC) 26 and legal authorities 27 for temporary limited
appointments defined in OPM?s Guide to Processing Personnel Actions and were
able to clearly identify the applicable NOACs and legal authorities for
these employees. We checked

these codes and authorities in our later discussions with OPM and agency
officials and agencies? responses to our questionnaires. For the excepted
service employees who met the temporary limited criteria, we identified the
most likely NOACs and legal authorities from information we obtained from
(1) our contacts with OPM and agency officials and (2) agency responses to
our questionnaire in which we asked the agencies to provide us with NOACs
and legal authorities for excepted service temporary limited employees for
fiscal year 2000. We did not verify the reliability of the nature of action
and legal authority data in the CPDF used to identify temporary limited
employees.

For the excepted service, we used NOACs and legal authorities reported to us
in the questionnaires except where they appeared to be in error. This
occurred in a very few instances. We also reviewed OPM?s Guide to Processing
Personnel Actions to identify any additional NOACs or legal authorities to
include. We identified no other NOACs. We included only

those legal authorities with not- to- exceed (NTE) dates, and we excluded
those legal authorities where we could not determine if they were for
permanent or temporary appointments and the authorities were not listed in
the questionnaire responses.

26 A NOAC is the specific personnel action used to create or change a
civilian personnel record and includes such actions as promotion,
termination, and within- grade increase. 27 Legal authority refers to the
law, executive order, rule, regulation, or other basis that authorizes the
appointing officer to effect a personnel action concerning an employee.

We analyzed the temporary limited employment data contained in the CPDF from
fiscal year 1991 through 2000, and included those employees hired throughout
the year. We defined hires to include appointments (i. e., when the person
is not already an employee of an agency) and conversions

(i. e., appointments when a person is employed by an agency in a different
position or under a different hiring authority). We did not analyze
employees on- board as of a specific date (e. g., September 30) because such
employees may work for short periods of time, and the end of the fiscal

year would only capture a moment in time, according to agency human
resources officials we interviewed.

To identify the job characteristics of temporary limited employees
governmentwide, we reviewed data available in the CPDF on work schedules and
grade levels for fiscal years 1991 through 2000 and occupations for fiscal
year 2000. To identify the benefits available to these employees, we
interviewed OPM officials and reviewed studies from OPM and MSPB and
applicable laws and regulations.

To identify the primary reasons agencies give for using temporary limited
employees, we designed and pretested with 2 agencies a questionnaire that we
later sent to the 10 agencies that we identified as being the predominant
users of such employees based on data provided by an OPM official. (See app.
I for a copy of the questionnaire.) In designing the questionnaire, we
discussed the questionnaire contents with OPM officials and reviewed

reports and studies on temporary employees in the federal government. For 7
of the 10 agencies, we asked their five components that were the largest
users of temporary limited employees to respond to the questionnaire. For
the remaining three agencies, including the four components of Defense, the
questionnaire responses covered the entire agency. Table 5 lists the 41
agencies and components to which we sent the

questionnaire. During the pretests, agency human resource officials told us
that they could not provide the information we were requesting on an
agencywide basis. We identified the components that were the largest users
of temporary limited employees based on information provided by

OPM officials and CPDF data as of September 30, 1999. We received completed
questionnaires from all 41 agencies and components.

Table 5: Agencies and Agency Components Selected for Survey Agency Component

Department of Agriculture Agricultural Marketing Service Agricultural
Research Service Animal and Plant Health Inspection Service Forest Service
Natural Resources Conservation Service Department of Commerce Bureau of the
Census

International Trade Administration National Institute of Standards and
Technology National Oceanic and Atmospheric Administration U. S. Patent and
Trademark Office Department of Defense Air Force

Army Navy Other DOD components Department of Health and Human

Centers for Disease Control and Prevention Services Food and Drug
Administration

Health Care Financing Administration Indian Health Service National
Institutes of Health Department of the Interior Bureau of Indian Affairs

Bureau of Land Management National Park Service U. S. Fish and Wildlife
Service U. S. Geological Survey Department of Justice Drug Enforcement
Administration

Executive Office for Immigration Review Executive Office for U. S. Attorneys
Federal Bureau of Prisons Immigration and Naturalization Service Department
of State Department of the Treasury Financial Management Service

Internal Revenue Service U. S. Customs Service U. S. Mint U. S. Secret
Service

(Continued From Previous Page)

Agency Component

Department of Veterans Affairs Deputy Assistant Secretary for Human
Resources Management

General Counsel National Cemetery Administration Veterans Benefits
Administration Veterans Health Administration Federal Emergency Management
Agency

The information in this review applies only to those agencies and agency
components to which we sent questionnaires. For three agencies, the
departments of Defense and State and FEMA, the information applies to the
entire agency. For seven agencies, their five components comprised 73 to 98
percent of total temporary limited employees hired in fiscal year 2000. We
used this information to represent the 10 agencies surveyed, but the

information cannot be projected to these 7 agencies or governmentwide. We
did not report on the reasons for increases, decreases, or fluctuations in
temporary limited employees hired from fiscal years 1995 through 2000

because the reasons were so varied that an analysis would not be meaningful.
Only one agency and one agency component reported having additional agency-
specific instructions for their excepted service temporary limited
employees. We did not verify the accuracy of the data provided by the
agencies.

To compare the federal government?s use of temporary limited employees with
that of the private sector, we conducted a literature search to identify
studies on federal and private sector uses of temporary employees. To ensure
that we identified all relevant studies, we also contacted OPM, MSPB, and
CRS officials, because their agencies had previously conducted

studies concerning temporary limited employees. We analyzed the reasons
cited in the studies as to why employers use temporary employees and
compared similarities and differences for both sectors.

To identify steps OPM has taken to ensure the appropriate use of temporary
limited employees, we analyzed CPDF data, reviewed OPM and MSPB studies on
temporary employment, interviewed OPM officials, and reviewed current and
prior OPM regulations and guidance on temporary employees. We also asked the
10 agencies that we identified as being predominant users of temporary
limited employees about the steps they were taking to ensure the appropriate
use of such employees. For 8 of the

10 agencies, we asked the component that was the largest user of temporary
limited employees in fiscal year 2000 to respond to our inquiries. The eight
agencies? components were the Forest Service, Bureau of Census, Defense
components other than the military services, National Institutes of Health,
National Park Service, Executive Office for U. S.

Attorneys, Internal Revenue Service, and Veterans Health Administration. The
two agencies were the Department of State and FEMA. All responded to our
inquiries. To identify whether long- term use of temporary limited employees
still exists, we first had to determine how many employees appointed to

temporary limited positions had more than 2 years of prior creditable
service; to do so, we used the service computation dates in the CPDF. We
subtracted military service from the total creditable service. Because
creditable civilian service includes all prior civilian federal service,
including any permanent federal employment, and because there may be gaps
between federal service, creditable service as reflected in the service
computation date for temporary limited employees cannot be used by itself to
identify continuous years of service under a series of appointments.

We did our work in Washington, D. C., from October 2000 through February
2002, in accordance with generally accepted government auditing standards.

Comments From the Office of Personnel

Appendi x II I Management

Appendi x I V

GAO Contact and Staff Acknowledgments GAO Contact Victor S. Rezendes, (202)
512- 6806 Acknowledgments In addition to the individual named above, Richard
W. Caradine, Ronald J. Cormier, Thomas G. Dowdal, V. Bruce Goddard, Robert
J. Heitzman, Stuart M. Kaufman, Michael J. O?Donnell, Molly K. Gleeson,
Rebecca Shea, Kiki Theodoropoulos, and Gregory H. Wilmoth, made key
contributions to this report.

(450000)

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a

GAO United States General Accounting Office

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Appendix I

Appendix I Agency Questionnaire on Temporary Limited Employees

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Appendix I Agency Questionnaire on Temporary Limited Employees

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Appendix I Agency Questionnaire on Temporary Limited Employees

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Appendix I Agency Questionnaire on Temporary Limited Employees

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Appendix II

Appendix II Objectives, Scope, and Methodology

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Appendix III

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Appendix IV

United States General Accounting Office Washington, D. C. 20548- 0001

Official Business Penalty for Private Use $300

Address Correction Requested Presorted Standard

Postage & Fees Paid GAO Permit No. GI00
*** End of document. ***