Human Capital: Preliminary Observations on Proposed Department of
Defense National Security Personnel System Regulations		 
(12-APR-05, GAO-05-517T).					 
                                                                 
The Department of Defense's (DOD) new human resources management 
system--the National Security Personnel System (NSPS)--will have 
far-reaching implications for civil service reform across the	 
federal government. The 2004 National Defense Authorization Act  
gave DOD significant flexibilities for managing more than 700,000
defense civilian employees. Given DOD's massive size, NSPS	 
represents a huge undertaking for DOD. DOD's initial process to  
design NSPS was problematic; however, DOD adjusted its approach  
to a more deliberative process that involved more stakeholders.  
NSPS could, if designed and implemented properly, serve as a	 
model for governmentwide transformation in human capital	 
management. However, if not properly designed and implemented, it
could severely impede progress toward a more performance- and	 
results-based system for the federal government as a whole. On	 
February 14, 2005, DOD and the Office of Personnel Management	 
(OPM) released for public comment the proposed NSPS regulations. 
This testimony (1) provides GAO's preliminary observations on	 
selected provisions of the proposed regulations, (2) discusses	 
the challenges DOD faces in implementing the new system, and (3) 
suggests a governmentwide framework to advance human capital	 
reform. 							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-517T					        
    ACCNO:   A21417						        
  TITLE:     Human Capital: Preliminary Observations on Proposed      
Department of Defense National Security Personnel System	 
Regulations							 
     DATE:   04/12/2005 
  SUBJECT:   Accountability					 
	     Civil service					 
	     Civilian employees 				 
	     Federal agencies					 
	     Human capital					 
	     Strategic planning 				 
	     Federal employees					 
	     Federal agency reorganization			 
	     Human capital management				 
	     Federal regulations				 
	     Policy evaluation					 
	     Policies and procedures				 
	     Stakeholder consultations				 
	     Performance-based pay				 
	     DOD National Security Personnel System		 

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GAO-05-517T

United States Government Accountability Office

GAO Testimony

Before the Subcommittee on the Federal Workforce and Agency Organization,
Committee on Government Reform, House of Representatives

For Release on Delivery Expected at 2:00 p.m., EDT Tuesday, April 12, 2005

HUMAN CAPITAL

  Preliminary Observations on Proposed Department of Defense National Security
                          Personnel System Regulations

Statement of David M. Walker Comptroller General of the United States

                                       a

GAO-05-517T

What GAO Recommends

[IMG]

April 12, 2005

HUMAN CAPITAL

Preliminary Observations on Proposed Department of Defense National Security
Personnel System Regulations

  What GAO Found

Many of the principles underlying the proposed NSPS regulations are
generally consistent with proven approaches to strategic human capital
management. For instance, the proposed regulations provide for (1)
elements of a flexible and contemporary human resources management
system-such as pay bands and pay for performance; (2) DOD to rightsize its
workforce when implementing reduction-in-force orders by giving greater
priority to employee performance in its retention decisions; and (3)
continuing collaboration with employee representatives. The 30-day public
comment period on the proposed regulations ended March 16, 2005. DOD and
OPM have notified the Congress that they are preparing to begin the meet
and confer process with employee representatives who provided comments on
the proposed regulations. The meet and confer process is critically
important because there are many details of the proposed regulations that
have not been defined. (It should be noted that 10 federal labor unions
have filed suit alleging that DOD failed to abide by the statutory
requirements to include employee representatives in the development of
DOD's new labor relations system authorized as part of NSPS.)

GAO has three primary areas of concern: the proposed regulations do not
(1) define the details of the implementation of the system, including such
issues as adequate safeguards to help ensure fairness and guard against
abuse; (2) require, as GAO believes they should, the use of core
competencies to communicate to employees what is expected of them on the
job; and (3) identify a process for the continuing involvement of
employees in the planning, development, and implementation of NSPS.

Going forward, GAO believes that (1) the development of the position of
Deputy Secretary of Defense for Management, who would act as DOD's Chief
Management Officer, is essential to elevate, integrate, and
institutionalize responsibility for the success of DOD's overall business
transformation efforts, including its new human resources management
system; (2) DOD would benefit if it develops a comprehensive
communications strategy that provides for ongoing, meaningful two-way
communication that creates shared expectations among employees, employee
representatives, and stakeholders; and (3) DOD must ensure that it has the
institutional infrastructure in place, including a modern performance
management system and an independent, efficient, effective, and credible
external appeals process, to make effective use of its new authorities
before they are operationalized.

GAO strongly supports the concept of modernizing federal human capital
policies, including providing reasonable flexibility. The federal
government needs a framework to guide human capital reform. Such a
framework would consist of a set of values, principles, processes, and
safeguards that would provide consistency across the federal government
but be adaptable to agencies' diverse missions, cultures, and workforces.

                 United States Government Accountability Office

Chairman Porter and Members of the Subcommittee:

I appreciate the opportunity to be here today to provide our preliminary
observations on the Department of Defense's (DOD) proposed National
Security Personnel System (NSPS) regulations, which the Secretary of
Defense and the Acting Director of the Office of Personnel Management
(OPM) jointly released for public comment on February 14, 2005.1 The
National Defense Authorization Act for Fiscal Year 20042 gave DOD
significant authorities to redesign the rules, regulations, and processes
that govern the way that defense civilian employees are hired,
compensated, promoted, and disciplined. The proposed regulations, which
according to DOD will ultimately affect more than 700,000 defense civilian
employees, are especially critical because of their implications for
governmentwide reform. In March 2005, I testified on the NSPS proposed
regulations before the Senate Committee on Homeland Security and
Governmental Affairs, Subcommittee on Oversight of Government Management,
the Federal Workforce, and the District of Columbia.3 Also, during my
recent speech before the Merit Systems Protection Board (MSPB) on the
challenges that the federal government faces in the 21st century, I
highlighted a range of trends and challenges, including DOD's human
capital reform effort and a governmentwide framework to advance human
capital reform.4

As suggested by the title of this hearing-"NSPS: The New Department of
Defense Civilian Personnel System Reaching Readiness," NSPS represents a
huge undertaking for DOD, given its massive size and geographically and
culturally diverse workforce. In addition, DOD's new human resources
management system will have far-reaching implications for the management
of the department and for civil service reform across the federal
government. NSPS could, if designed and implemented properly, serve as a
model for governmentwide transformation in human capital management.
However, if not properly designed and implemented, NSPS

1 National Security Personnel System, 70 Fed. Reg. 7552 (Feb. 14, 2005).

2 Pub. L. No. 108-136 S: 1101 (Nov. 24, 2003).

3 GAO, Human Capital: Preliminary Observations on Proposed DOD National
Security Personnel System Regulations, GAO-05-432T (Washington, D.C.: Mar.
15, 2005).

4 The Honorable David M. Walker, "21st Century Challenges: Reexamining the
Base of the Federal Government" (paper presented to the Merit Systems
Protection Board, New Orleans, La., April 5, 2005).

could impede progress toward a more performance- and results-based system
for the federal government as a whole.

We raised several issues regarding DOD's civilian workforce in a recently
released report on the fiscal challenges the federal government faces in
the 21st century, including whether DOD is pursuing the design and
implementation of NSPS in a manner that maximizes the chance of success.5
In recent testimony on DOD's business transformation efforts, we indicated
that DOD is challenged in its efforts to effect fundamental business
management reform, such as NSPS, and indicated that our ongoing work
continues to raise questions about DOD's chances of success.6 There is
general recognition that the government needs a framework to guide the
kind of large-scale human capital reform occurring at DOD and the
Department of Homeland Security (DHS), a framework that Congress and the
administration can implement to enhance performance, ensure
accountability, and position the nation for the future. Implementing
large-scale change management initiatives is a complex endeavor, and
failure to address a wide variety of personnel and cultural issues, in
particular, has been at the heart of unsuccessful organizational
transformations. Strategic human capital management, which we continue to
designate as a high-risk area governmentwide,7 can help agencies marshal,
manage, and maintain the workforce they need to accomplish their missions.

Summary	Let me begin by summarizing three positive features, three areas
of concern, and three comments regarding the way forward. The first
positive feature is that the proposed regulations provide for many
elements of a flexible and contemporary human resources management
system-such as pay bands and pay for performance. The second positive
feature is that the proposed regulations will allow DOD to rightsize its
workforce when implementing reduction-in-force (RIF) orders. For example,
DOD will be able to give greater priority to employee performance in RIF
decisions and

5 GAO, 21st Century Challenges: Reexamining the Base of the Federal
Government, GAO-05-325SP (Washington, D.C.: February 2005).

6 GAO, Department of Defense: Further Actions Are Needed to Effectively
Address Business Management Problems and Overcome Key Business
Transformation Challenges, GAO-05-140T (Washington, D.C.: Nov. 18, 2004).

7 GAO, High-Risk Series: An Update, GAO-05-207 (Washington, D.C.: January
2005).

take more factors into consideration when defining the areas in which
employees will compete for retention. The third positive feature is that
DOD has pledged to engage in a continuing collaboration with employee
representatives. On March 16, 2005, the 30-day public comment period on
the proposed regulations ended. On March 28, 2005, DOD and OPM notified
the Congress that they are about to begin the meet and confer process with
employee representatives who provided comments on the proposed
regulations. (It should be noted that 10 federal labor unions have filed
suit alleging that DOD failed to abide by the statutory requirements to
include employee representatives in the development of DOD's new labor
relations system authorized as part of NSPS.)

However, in addition to the litigation referenced above, our initial work
indicates three primary areas of concern. First, DOD has considerable work
ahead to define the details of the implementation of its system, including
such issues as adequate safeguards to help ensure fairness and guard
against abuse. Second, in setting performance expectations, the proposed
regulations would allow the use of core competencies to communicate to
employees what is expected of them on the job, but the proposed
regulations do not require the use of these core competencies. Requiring
such use can help provide consistency and clarity in performance
management. Third, the proposed regulations do not identify a process for
the continuing involvement of employees in the planning, development, and
implementation of NSPS.

Regarding the way forward, development of the position of Deputy Secretary
of Defense for Management, who would act as DOD's Chief Management
Officer, will be essential to provide leadership that can elevate,
integrate, and institutionalize responsibility for the success of DOD's
overall business transformation effort, including its new human resources
management system. In fact, in my previous testimony on DOD's business
transformation efforts, we identified the lack of clear and sustained
leadership for overall business transformations as one of the underlying
causes that has impeded prior DOD reform efforts.8 Additionally, DOD would
benefit if it develops a comprehensive communications strategy that
provides for ongoing, meaningful two-way communication that creates shared
expectations among employees, employee representatives, managers,
customers, and stakeholders. Finally, DOD must ensure that it has the
institutional infrastructure in place to

8 GAO-05-140T.

make effective use of its new authorities. At a minimum, this
infrastructure includes a human capital planning process that integrates
DOD's human capital policies, strategies, and programs with its program
goals and mission, and desired outcomes; the capabilities to effectively
develop and implement a new human capital system; and, importantly, a set
of adequate safeguards, including reasonable transparency and appropriate
accountability mechanisms, to help ensure the fair, effective, and
credible implementation and application of a new system.

DOD's proposed regulations are intended to provide a broad outline of its
new human resources management system. While they are not, nor were they
intended to be, a detailed presentation of how the new system will be
implemented, the details of the proposed regulations do matter. Although
we continue to review the DOD's extensive regulations, today I will (1)
provide some preliminary observations on selected provisions, (2) discuss
the multiple challenges that DOD faces as it moves toward implementation
of its new human resources management system, and then (3) suggest a
governmentwide framework that can serve as a starting point to advance
human capital reform.

  Preliminary Observations on the Proposed DOD National Security Personnel
  System Regulations

DOD and OPM's proposed NSPS regulations would establish a new human
resources management system within DOD that governs basic pay, staffing,
classification, performance management, labor relations, adverse actions,
and employee appeals. We believe that many of the basic principles
underlying the proposed DOD regulations are generally consistent with
proven approaches to strategic human capital management. Today, I will
provide our preliminary observations on selected elements of the proposed
regulations in the areas of pay and performance management, staffing and
employment, workforce shaping, adverse actions and appeals, and
labormanagement relations.

Pay and Performance In January 2004, we released a report on pay for
performance for selected

Management	OPM personnel demonstration projects that shows the variety of
approaches taken in these projects to design and implement
pay-forperformance systems.9 Many of these personnel demonstration
projects

9 GAO, Human Capital: Implementing Pay for Performance at Selected
Personnel Demonstration Projects, GAO-04-83 (Washington, D.C.: Jan. 23,
2004).

were conducted within DOD. The experiences of these demonstration projects
provide insights into how some organizations in the federal government are
implementing pay for performance, and thus can guide DOD as it develops
and implements its own approach. These demonstration projects illustrate
that understanding how to link pay to performance is very much a work in
progress in the federal government and that additional work is needed to
ensure that performance management systems are tools to help agencies
manage on a day-to-day basis and achieve external results.

When DOD first proposed its new civilian personnel reform, we strongly
supported the need to expand pay for performance in the federal
government.10 Establishing a clear link between individual pay and
performance is essential for maximizing performance and ensuring the
accountability of the federal government to the American people. As I have
stated before, how pay for performance is done, when it is done, and the
basis on which it is done can make all the difference in whether such
efforts are successful.11 DOD's proposed regulations reflect a growing
understanding that the federal government needs to fundamentally rethink
its current approach to pay and better link pay to individual and
organizational performance. To this end, the DOD proposal takes another
valuable step toward a modern performance management system as well as a
market-based, results-oriented compensation system. My comments on
specific provisions of pay and performance management follow.

Aligning Individual Performance Under the proposed regulations, the DOD
performance management

to Organizational Goals	system would, among other things, align individual
performance expectations with the department's overall mission and
strategic goals, organizational program and policy objectives, annual
performance plans, and other measures of performance. However, the
proposed regulations do not detail how to achieve such an alignment, which
is a vital issue that will need to be addressed as DOD's efforts in
designing and implementing a new personnel system move forward. Our work
on public sector performance management efforts in the United States and
abroad has underscored the importance of aligning daily operations and
activities with organizational

10 GAO, Defense Transformation: Preliminary Observations on DOD's Proposed
Civilian Personnel Reforms, GAO-03-717T (Washington, D.C.: Apr. 29, 2003).

11 GAO, Human Capital: Preliminary Observations on Proposed DHS Human
Capital Regulations, GAO-04-479T (Washington, D.C.: Feb. 25, 2004).

results.12 We have found that organizations often struggle with clearly
understanding how what they do on a day-to-day basis contributes to
overall organizational results, while high-performing organizations
demonstrate their understanding of how the products and services they
deliver contribute to results by aligning the performance expectations of
top leadership with the organization's goals and then cascading those
expectations to lower levels.

A performance management system is critical to successful organizational
transformation. As an organization undergoing transformation, DOD can use
its proposed performance management system as a vital tool for aligning
the organization with desired results and creating a "line of sight" to
show how team, unit, and individual performance can contribute to overall
organizational results. To help federal agencies transform their culture
to be more results oriented, customer focused, and collaborative in
nature, we have reported on how a performance management system that
defines responsibility and ensures accountability for change can be key to
a successful merger and transformation.13

Establishing Pay Bands	Under the proposed regulations, DOD would create
pay bands for most of its civilian workforce that would replace the
15-grade General Schedule (GS) system now in place for most civil service
employees. Specifically, DOD (in coordination with OPM) would establish
broad occupational career groups by grouping occupations and positions
that are similar in type of work, mission, developmental or career paths,
and competencies. Within career groups, DOD would establish pay bands. The
proposed regulations do not provide details on the number of career groups
or the number of pay bands per career group. The regulations also do not
provide details on the criteria that DOD will use to promote individuals
from one band to another. These important issues will need to be addressed
as DOD moves forward. Pay banding and movement to broader occupational
career groups can both facilitate DOD's movement to a pay-for-performance
system and help DOD better define career groups, which in turn can improve
the hiring process. In our prior work, we have reported that the current
GS system, as defined in the Classification Act of 1949,14 is a key

12 GAO-04-479T.

13 GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers
and Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2,
2003).

14 5 U.S. Code S:S: 5101-5115.

barrier to comprehensive human capital reform and that the creation of
broader occupational job clusters and pay bands would aid other agencies
as they seek to modernize their personnel systems.15 The standards and
process of the current classification system are key problems in federal
hiring efforts because they are outdated and thus not applicable to
today's occupations and work.

Under the proposed regulations, DOD could not reduce employees' basic
rates of pay when converting to pay bands. In addition, the proposed
regulations would allow DOD to establish a "control point" within a band
that limits increases in the rate of basic pay and may require certain
criteria to be met for increases above the control point.16 The use of
control points to manage employees' progression through the bands can help
to ensure that their performance coincides with their salaries and that
only the highest performers move into the upper half of the pay band,
thereby controlling salary costs. The OPM personnel demonstration projects
at China Lake and the Naval Sea Systems Command Warfare Center's Dahlgren
Division have incorporated checkpoints or "speed bumps" in their pay
bands. For example, when an employee's salary at China Lake reaches the
midpoint of the pay band, the employee must receive a performance rating
that is equivalent to exceeding expectations before he or she can receive
additional salary increases.

Setting and Communicating Under the proposed regulations, DOD's
performance management system

Employee Performance Expectations

would promote individual accountability by setting performance
expectations and communicating them to employees, holding employees
responsible for accomplishing them, and making supervisors and managers
responsible for effectively managing the performance of employees under
their supervision. While supervisors are supposed to involve employees,
insofar as practicable, in setting performance expectations, the final
decisions regarding performance expectations are within the sole and
exclusive discretion of management.

15 GAO, Human Capital: Opportunities to Improve Executive Agencies' Hiring
Processes, GAO-03-450 (Washington, D.C.: May 30, 2003).

16 Because movement through the pay band is based on performance,
employees could progress through the pay band more quickly than they could
receive similar increases under the GS system. One method of preventing
employees from eventually migrating to the top of the pay band, and thus
increasing salary costs, is to establish control points within each band.

Under the proposed regulations, performance expectations may take several
different forms. These include, among others, goals or objectives that set
general or specific performance targets at the individual, team, or
organizational level; a particular work assignment, including
characteristics such as quality, quantity, accuracy, or timeliness; core
competencies that an employee is expected to demonstrate on the job; or
the contributions that an employee is expected to make. As DOD's human
resources management system design efforts move forward, DOD will need to
define, in more detail than is currently provided, how performance
expectations will be set, including the degree to which DOD components,
managers, and supervisors will have flexibility in setting those
expectations.

The range of expectations that DOD would consider in setting individual
employee performance expectations are generally consistent with those used
by high-performing organizations. DOD appropriately recognizes that given
the vast diversity of work done in the department, managers and employees
need flexibility in crafting specific expectations. However, the
experiences of high-performing organizations suggest that DOD should
require the use of core competencies as a central feature of its
performance management effort.17 Based on our review of other agency
efforts and our own experience at GAO, we have found that core
competencies can help reinforce employee behaviors and actions that
support the department's mission, goals, and values, and can provide a
consistent message to employees about how they are expected to achieve
results. By including such competencies as change management, cultural
sensitivity, teamwork and collaboration, and information sharing, DOD
would create a shared responsibility for organizational success and help
ensure accountability for the transformation process.

Making Meaningful Distinctions High-performing organizations seek to
create pay, incentive, and reward

in Employee Performance	systems that clearly link employee knowledge,
skills, and contributions to organizational results. These organizations
make meaningful distinctions between acceptable and outstanding
performance of individuals and appropriately reward those who perform at
the highest level. DOD's proposed regulations state that supervisors and
managers would be held accountable for making meaningful distinctions
among employees based

17 GAO, Results-Oriented Cultures: Creating a Clear Linkage between
Individual Performance and Organizational Success, GAO-03-488 (Washington,
D.C.: Mar. 14, 2003).

on performance and contribution, fostering and rewarding excellent
performance, and addressing poor performance.

Under the proposed regulations, DOD is expected to have at least three
rating levels for evaluating employee performance. We urge DOD to consider
using at least four summary rating levels to allow for greater
performance-rating and pay differentiation. This approach is in the spirit
of the new governmentwide performance-based pay system for the Senior
Executive Service (SES), which requires at least four rating levels to
provide a clear and direct link between SES performance and pay as well as
to make meaningful distinctions based on relative performance. Cascading
this approach to other levels of employees can help DOD recognize and
reward employee contributions and achieve the highest levels of individual
performance.18

Providing Adequate Safeguards Although DOD's proposed regulations provide
for some safeguards to

to Ensure Fairness and Guard ensure fairness and guard against abuse,
additional safeguards should be

Against Abuse	developed. For example, as required by the authorizing
legislation, the proposed regulations indicate that DOD's performance
management system must comply with merit system principles and avoid
prohibited personnel practices; provide a means for employee involvement
in the design and implementation of the system; and, overall, be fair,
credible, and transparent. However, the proposed regulations do not offer
details on how DOD would (1) promote consistency and provide general
oversight of the performance management system to help ensure it is
administered in a fair, credible, and transparent manner, and (2)
incorporate predecisional internal safeguards that are implemented to help
achieve consistency and equity, and ensure nondiscrimination and
nonpoliticization of the performance management process. Last month,
during testimony, we stated that additional flexibility should have
adequate safeguards, including a reasonable degree of transparency with
regard to the results of key decisions, whether it be pay, promotions, or
other types of actions, while protecting personal privacy. We also
suggested that there should be both informal and formal appeal mechanisms
within and outside of the organization if individuals feel that there has
been abuse or a violation of the policies, procedures, and protected
rights of the individual. Internal mechanisms could include independent
Human Capital Office and Office of Opportunity and Inclusiveness reviews
that provide reasonable assurances

18 GAO, Human Capital: Observations on Final DHS Human Capital Regulation,
GAO-05-391T (Washington, D.C.: Mar. 2, 2005).

that there would be consistency and nondiscrimination. Furthermore, it is
of critical importance that the external appeal process be independent,
efficient, effective, and credible.

In April 2003, when commenting on DOD civilian personnel reforms, we
testified that Congress should consider establishing statutory standards
that an agency must have in place before it can implement a more
performance-based pay program, and we developed an initial list of
possible safeguards to help ensure that pay-for-performance systems in the
government are fair, effective, and credible.19 For example, we have noted
that agencies need to ensure reasonable transparency and provide
appropriate accountability mechanisms in connection with the results of
the performance management process.20 This can be done by publishing the
overall results of performance management and individual pay decisions
while protecting individual confidentiality and by reporting periodically
on internal assessments and employee survey results relating to the
performance management system. DOD needs to commit itself to publishing
the results of performance management decisions. By publishing the results
in a manner that protects individual confidentiality, DOD could provide
employees with the information they need to better understand their
performance and the performance management system. Several of the
demonstration projects have been publishing information about performance
appraisal and pay decisions, such as the average performance rating, the
average pay increase, and the average award for the organization and for
each individual unit, on internal Web sites for use by employees. As DOD's
human resources management system design efforts move forward, DOD will
need to define, in more detail than is currently provided, how it plans to
review such matters as the establishment and implementation of the
performance appraisal systemand, subsequently, performance rating
decisions, pay determinations, and promotion actionsbefore these
actions are finalized, to ensure they are merit based.

Staffing and Employment	The authorizing legislation allows DOD to
implement additional hiring flexibilities that would allow it to (1)
determine that there is a severe shortage of candidates or a critical
hiring need and (2) use direct-hire

                        19 GAO-03-717T. 20 GAO-04-479T.

procedures for these positions. Under current law, OPM, rather than the
agency, determines whether there is a severe shortage of candidates or a
critical hiring need. DOD's authorizing legislation permits that DOD
merely document the basis for the severe shortage or critical hiring need
and then notify OPM of these direct-hire determinations. Direct-hire
authority allows an agency to appoint people to positions without
adherence to certain competitive examination requirements (such as
applying veterans' preference or numerically rating and ranking candidates
based on their experience, training, and education) when there is a severe
shortage of qualified candidates or a critical hiring need. In the section
containing DOD's proposed hiring flexibilities, the proposed regulations
state that the department will adhere to veterans' preference principles
as well as comply with merit principles and the Title 5 provision dealing
with prohibited personnel practices.

While we strongly endorse providing agencies with additional tools and
flexibilities to attract and retain needed talent, additional analysis may
be needed to ensure that any new hiring authorities are consistent with a
focus on the protection of employee rights, on merit principles-and on
results. Hiring flexibilities alone will not enable federal agencies to
bring on board the personnel that are needed to accomplish their missions.
Agencies must first conduct gap analyses of the critical skills and
competencies needed in their workforces now and in the future, or they may
not be able to effectively design strategies to hire, develop, and retain
the best possible workforces.

Workforce Shaping	The proposed regulations would allow DOD to reduce,
realign, and reorganize the department's workforce through revised RIF
procedures. For example, employees would be placed on a retention list in
the following order: tenure group (i.e., permanent or temporary
appointment), veterans' preference eligibility (disabled veterans will be
given additional priority), level of performance, and length of service;
under current regulations, length of service is considered ahead of
performance. I have previously testified, prior to the enactment of NSPS,
in support of revised RIF procedures that would require much greater
consideration of an

employee's performance.21 Although we support greater consideration of an
employee's performance in RIF procedures, agencies must have modern,
effective, and credible performance management systems in place to
properly implement such authorities.

An agency's approach to reductions should be oriented toward strategically
shaping the makeup of its workforce if it is to ensure the orderly
transfer of institutional knowledge and achieve mission results. DOD's
proposed regulations include some changes that would allow the department
to rightsize the workforce more carefully through greater precision in
defining competitive areas, and by reducing the disruption associated with
RIF orders as their impact ripples through an organization. For example,
under the current regulations, the minimum RIF competitive area is broadly
defined as an organization under separate administration in a local
commuting area. Under the proposed regulations, DOD would be able to
establish a minimum RIF competitive area on a more targeted basis, using
one or more of the following factors: geographical location, line of
business, product line, organizational unit, and funding line. The
proposed regulations also provide DOD with the flexibility to develop
additional competitive groupings on the basis of career group,
occupational series or specialty, and pay band. At present, DOD can use
competitive groups based on employees (1) in the excepted and competitive
service, (2) under different excepted service appointment authorities, (3)
with different work schedules,22 (4) pay schedule, or (5) trainee status.
These reforms could help DOD approach rightsizing more carefully; however,
as I have stated, agencies first need to identify the critical skills and
competencies needed in their workforce if they are to effectively
implement their new human capital flexibilities.

21 GAO-03-717T; GAO, Defense Transformation: DOD's Proposed Civilian
Personnel System and Governmentwide Human Capital Reform, GAO-03-741T
(Washington, D.C.: May 1, 2003); and Human Capital: Building on DOD's
Reform Effort to Foster Governmentwide Improvements, GAO-03-851T
(Washington, D.C.: June 4, 2003).

22 For example, employees who work full time, part time, seasonally, or
intermittently.

Adverse Actions and Appeals

As with DHS's final regulations,23 DOD's proposed regulations are intended
to streamline the rules and procedures for taking adverse actions, while
ensuring that employees receive due process and fair treatment. The
proposed regulations establish a single process for both performancebased
and conduct-based actions, and shorten the adverse action process by
removing the requirement for a performance improvement plan. In addition,
the proposed regulations streamline the appeals process at the MSPB by
shortening the time for filing and processing appeals.

Similar to DHS, DOD's proposed regulations also adopt a higher standard of
proof for adverse actions in DOD, requiring the department to meet a
"preponderance of the evidence" standard in place of the current
"substantial evidence" standard. For performance issues, while this higher
standard of evidence means that DOD would face a greater burden of proof
than most agencies to pursue these actions, DOD managers are not required
to provide employees with performance improvement periods, as is the case
for other federal employees. For conduct issues, DOD would face the same
burden of proof as most agencies.

DOD's proposed regulations generally preserve the employee's basic right
to appeal decisions to an independent body-the MSPB. However, in contrast
to DHS's final regulations, DOD's proposed regulations permit an internal
DOD review of the initial decisions issued by MSPB adjudicating officials.
Under this internal review, DOD can modify or reverse an initial decision
or remand the matter back to the adjudicating official for further
consideration. Unlike other criteria for review of initial decisions, DOD
can modify or reverse an initial MSPB adjudicating official's decision
where the department determines that the decision has a direct and
substantial adverse impact on the department's national security
mission.24 According to DOD, the department needs the authority to review
initial MSPB decisions and correct such decisions as appropriate, to
ensure that the MSPB interprets NSPS and the proposed regulations in a way
that recognizes the critical mission of the department and to ensure that
MSPB gives proper deference to such interpretation. However, the proposed

23 Department of Homeland Security Human Resources Management System, 70
Fed. Reg. 5272 (Feb. 1, 2005).

24 Any final DOD decision under this review process may be further
appealed to the full MSPB. Further, the Secretary of Defense or an
employee adversely affected by a final order or decision of the full MSPB
may seek judicial review.

regulations do not offer additional details on the department's internal
review process, such as how the review will be conducted and who will
conduct them. An internal agency review process this important should be
addressed in the regulations rather than in an implementing directive to
ensure adequate transparency and employee confidence in the process.

Similar to DHS's final regulations, DOD's proposed regulations would
shorten the notification period before an adverse action can become
effective and provide an accelerated MSPB adjudication process. In
addition, MSPB would no longer be able to modify a penalty for an adverse
action that is imposed on an employee by DOD unless such penalty is so
disproportionate to the basis of the action as to be "wholly without
justification." In other words, MSPB has less latitude to modify
agencyimposed penalties than under current practice. The DOD proposed
regulations also stipulate that MSPB could no longer require that parties
enter into settlement discussions, although either party may propose doing
so. DOD, like DHS, expressed concerns that settlement should be a
completely voluntary decision made by parties on their own initiative.
However, settling cases has been an important tool in the past at MSPB,
and promotion of settlement at this stage should be encouraged.

Similar to DHS's final regulations, DOD's proposed regulations would
permit the Secretary of Defense to identify specific offenses for which
removal is mandatory. Employees alleged to have committed these offenses
may receive a written notice only after the Secretary of Defense's review
and approval. These employees will have the same right to a review by an
MSPB adjudicating official as is provided to other employees against whom
appealable adverse actions are taken. DOD's proposed regulations only
indicate that its employees will be made aware of the mandatory removal
offenses. In contrast, the final DHS regulations explicitly provide for
publishing a list of the mandatory removal offenses in the Federal
Register. We believe that the process for determining and communicating
which types of offenses require mandatory removal should be explicit and
transparent and involve relevant congressional stakeholders, employees,
and employee representatives. Moreover, we suggest that DOD exercise
caution when identifying specific removable offenses and the specific
punishment. When developing these proposed regulations, DOD should learn
from the experience of the Internal Revenue Service's (IRS)

implementation of its mandatory removal provisions.25 (IRS employees
feared that they would be falsely accused by taxpayers and investigated,
and had little confidence that they would not be disciplined for making an
honest mistake.) We reported that IRS officials believed this provision
had a negative impact on employee morale and effectiveness and had a
"chilling" effect on IRS frontline enforcement employees, who were afraid
to take certain appropriate enforcement actions.26 Careful drafting of
each removable offense is critical to ensure that the provision does not
have unintended consequences.

DOD's proposed regulations also would encourage the use of alternative
dispute resolution and provide that this approach be subject to collective
bargaining to the extent permitted by the proposed labor relations
regulations. To resolve disputes in a more efficient, timely, and less
adversarial manner, federal agencies have been expanding their human
capital programs to include alternative dispute resolution approaches.
These approaches include mediation, dispute resolution boards, and
ombudsmen. Ombudsmen typically are used to provide an informal alternative
to addressing conflicts. We previously reported on common approaches used
in ombudsmen offices, including (1) broad responsibility and authority to
address almost any workplace issue, (2) their ability to bring systemic
issues to management's attention, and (3) the manner in which they work
with other agency offices in providing assistance to employees.27

Labor-Management The DOD proposed regulations recognize the right of
employees to

Relations	organize and bargain collectively.28 However, similar to DHS's
final regulations, the proposed regulations would reduce the scope of
bargaining by (1) removing the requirement to bargain on matters
traditionally referred to as "impact and implementation" (which include
the processes used to deploy personnel, assign work, and use technology)
and

25 Section 1203 of the IRS Restructuring and Reform Act of 1998 outlines
conditions for firing of IRS employees for any of 10 actions of
misconduct.

26 GAO, Tax Administration: IRS and TIGTA Should Evaluate Their Processes
of Employee Misconduct Under Section 1203, GAO-03-394 (Washington, D.C.:
Feb. 14, 2003).

27 GAO-01-479T.

28 Under current law, the rights of employees to bargain may be suspended
for reasons of national security. See Title 5 U.S. Code S:S: 7103(b) and
7112(b)(6).

(2) narrowing the scope of issues subject to collective bargaining. A
National Security Labor Relations Board would be created that would
largely replace the Federal Labor Relations Authority. The proposed board
would have at least three members selected by the Secretary of Defense,
with one member selected from a list developed in consultation with the
Director of OPM. The proposed board would be similar to the internal
Homeland Security Labor Relations Board established by the DHS final
regulations, except that the Secretary of Defense would not be required to
consult with the employee representatives in selecting its members. The
proposed board would be responsible for resolving matters related to
negotiation disputes, to include the scope of bargaining and the
obligation to bargain in good faith, resolving impasses, and questions
regarding national consultation rights.

Under the proposed regulations, the Secretary of Defense is authorized to
appoint and remove individuals who serve on the board. Similar to DHS's
final regulations establishing the Homeland Security Labor Relations
Board, DOD's proposed regulations provide for board member qualification
requirements, which emphasize integrity and impartiality. DOD's proposed
regulations, however, do not provide an avenue for any employee
representative input into the appointment of board members. DHS
regulations do so by requiring that for the appointment of two board
members, the Secretary of Homeland Security must consider candidates
submitted by labor organizations. Employee perception concerning the
independence of this board is critical to the resolution of issues raised
over labor relations policies and disputes.

Our previous work on individual agencies' human capital systems has not
directly addressed the scope of specific issues that should or should not
be subject to collective bargaining and negotiations. At a forum we
co-hosted in April 2004 exploring the concept of a governmentwide
framework for human capital reform, which I will discuss later,
participants generally agreed that the ability to organize, bargain
collectively, and participate in labor organizations is an important
principle to be retained in any framework for reform. It also was
suggested at the forum that unions must be both willing and able to
actively collaborate and coordinate with management if unions are to be
effective representatives of their members and real participants in any
human capital reform.

  DOD Faces Multiple Implementation Challenges

Once DOD issues its final regulations for its human resources management
system, the department will face multiple implementation challenges that
include ensuring sustained and committed leadership, establishing an
overall communications strategy, providing adequate resources for the
implementation of the new system, involving employees in designing the
system, and evaluating DOD's new human resources management system after
it has been implemented. For information on related human capital issues
that could potentially affect the implementation of NSPS, see the
"Highlights" pages from previous GAO products on DOD civilian personnel
issues in appendix I.

                  Ensuring Sustained and Committed Leadership

As DOD and other agencies across the federal government embark on
large-scale organizational change initiatives, such as DOD's new human
resources management system, another challenge is to elevate, integrate,
and institutionalize leadership responsibility for these key functional
management initiatives to ensure their success. A chief management officer
or similar position can effectively provide the continuing, focused
leadership essential to successfully completing these multiyear
transformations. For an endeavor as critical as DOD's new human resources
management system, such a leadership position would serve to

o 	elevate attention to overcome an organization's natural resistance to
change, marshal the resources needed to implement change, and build and
maintain the organizationwide commitment to new ways of doing business;

o 	integrate various management responsibilities into the new system so
they are no longer "stove-piped" and fit into other organizational
transformation efforts in a comprehensive, ongoing, and integrated manner;
and

o 	institutionalize accountability for the system so that the
implementation of this critical human capital initiative can be
sustained.29

In 2004, we testified that while the Secretary of Defense and other key
DOD leaders have demonstrated their commitment to the business
transformation efforts, in our view, the complexity and long-term nature
of these efforts requires the development of an executive position capable
of providing strong and sustained executive leadership-over a number of
years and various administrations.30 The day-to-day demands placed on the
Secretary, the Deputy Secretary, and others make it difficult for these
leaders to maintain the oversight, focus, and momentum needed to resolve
the weaknesses in DOD's overall business operations. While sound strategic
planning is the foundation upon which to build, sustained and focused
leadership is needed for reform to succeed. One way to ensure sustained
leadership over DOD's business transformation efforts would be to create a
full-time executive level position for a chief management official who
would serve as the Deputy Secretary of Defense for Management.31 This
position would provide the attention essential for addressing key
stewardship responsibilities, such as strategic planning, human capital
management, performance and financial management, acquisition and contract
management, and business systems modernization, while facilitating the
overall business transformation operations within DOD.

Establishing an Overall Another significant challenge for DOD is to ensure
an effective and ongoing

Communications Strategy	two-way communications strategy, given its size,
geographically and culturally diverse audiences, and different command
structures across DOD organizations. We have reported that a
communications strategy that creates shared expectations about, and
reports related progress on, the implementation of the new system is a key
practice of a change

29 On September 9, 2002, GAO convened a roundtable of government leaders
and management experts to discuss the chief operating concept. For more
information, see GAO, Highlights of a GAO Roundtable: The Chief Operating
Officer Concept: A Potential Strategy to Address Federal Governance
Challenges, GAO-03-192SP (Washington, D.C.: Oct. 4, 2002), and The Chief
Operating Officer Concept and Its Potential Use as a Strategy to Improve
Management at the Department of Homeland Security, GAO-04-876R
(Washington, D.C.: June 28, 2004).

30 GAO-05-140T.

31 GAO-05-140T.

management initiative.32 This communications strategy must involve a
number of key players, including the Secretary of Defense, and a variety
of communication means and mediums. DOD acknowledges that a comprehensive
outreach and communications strategy is essential for designing and
implementing its new human resources management system, but the proposed
regulations do not identify a process for the continuing involvement of
employees in the planning, development, and implementation of NSPS.

Because the NSPS design process and proposed regulations have received
considerable attention,33 we believe one of the most relevant
implementation steps is for DOD to enhance two-way communication between
employees, employee representatives, and management. Communication is not
only about "pushing the message out," but also using two-way communication
to build effective internal and external partnerships that are vital to
the success of any organization. By providing employees with opportunities
to communicate concerns and experiences about any change management
initiative, management allows employees to feel that their input is
acknowledged and important. As it makes plans for implementing NSPS, DOD
should facilitate a two-way honest exchange with, and allow for feedback
from, employees and other stakeholders. Once it receives this feedback,
management needs to consider and use this solicited employee feedback to
make any appropriate changes to its implementation. In addition,
management needs to close the loop by providing employees with information
on why key recommendations were not adopted.

Providing Adequate Experience has shown that additional resources are
necessary to ensure Resources for Implementing sufficient planning,
implementation, training, and evaluation for human the New System capital
reform. According to DOD, the implementation of NSPS will result

in costs for, among other things, developing and delivering training,
modifying automated human resources information systems, and starting up
and sustaining the National Security Labor Relations Board. We have

32 GAO-03-669.

33 DOD's efforts to date to involve labor unions have not been without
controversy. Ten federal labor unions have filed suit alleging that DOD
failed to abide by the statutory requirements to include employee
representatives in the development of DOD's new labor relations system
authorized as part of NSPS. See American Federation of Government
Employees, AFL-CIO et al v. Rumsfeld et al, No. 1:05cv00367 (D.D.C. filed
Feb. 23, 2005).

found that, based on the data provided by selected OPM personnel
demonstration projects, the major cost drivers in implementing
pay-forperformance systems are the direct costs associated with salaries
and training.

DOD estimates that the overall cost associated with implementing NSPS will
be approximately $158 million through fiscal year 2008. According to DOD,
it has not completed an implementation plan for NSPS, including an
information technology plan and a training plan; thus, the full extent of
the resources needed to implement NSPS may not be well understood at this
time. According to OPM, the increased costs of implementing alternative
personnel systems should be acknowledged and budgeted up front.34 Certain
costs, such as those for initial training on the new system, are onetime
in nature and should not be built into the base of DOD's budget. Other
costs, such as employees' salaries, are recurring and thus would be built
into the base of DOD's budget for future years. Therefore, funding for
NSPS will warrant close scrutiny by Congress as DOD's implementation plan
evolves.

Involving Employees and Other Stakeholders in Implementing the System

The proposed regulations do not identify a process for the continuing
involvement of employees in the planning, development, and implementation
of NSPS. However, DOD's proposed regulations do provide for continuing
collaboration with employee representatives. According to DOD, almost
two-thirds of its 700,000 civilian employees are represented by 41
different labor unions, including over 1,500 separate bargaining units. In
contrast, according to OPM, just under one-third of DHS's 110,000 federal
employees are represented by 16 different labor unions, including 75
separate bargaining units. Similar to DHS's final regulations, DOD's
proposed regulations about the collaboration process, among other things,
would permit the Secretary of Defense to determine (1) the number of
employee representatives allowed to engage in the collaboration process,
and (2) the extent to which employee representatives are given an
opportunity to discuss their views with and submit written comments to DOD
officials. In addition, DOD's proposed regulations indicate that nothing
in the continuing collaboration process will affect the right of the
Secretary of Defense to determine the content of implementing guidance and
to make this guidance effective at any time. DOD's proposed

34 OPM, Demonstration Projects and Alternative Personnel Systems: HR
Flexibilities and Lessons Learned (Washington, D.C.: September 2001).

regulations also will give designated employee representatives an
opportunity to be briefed and to comment on the design and results of the
new system's implementation. DHS's final regulations, however, provide for
more extensive involvement of employee representatives. For example, DHS's
final regulations provide for the involvement of employee representatives
in identifying the scope, objectives, and methodology to be used in
evaluating the new DHS system.

The active involvement of employees and employee representatives will be
critical to the success of NSPS. We have reported that the involvement of
employees and employee representatives both directly and indirectly is
crucial to the success of new initiatives, including implementing a
pay-forperformance system. High-performing organizations have found that
actively involving employees and stakeholders, such as unions or other
employee associations, when developing results-oriented performance
management systems helps improve employees' confidence and belief in the
fairness of the system and increases their understanding and ownership of
organizational goals and objectives. This involvement must be early,
active, and continuing if employees are to gain a sense of understanding
and ownership of the changes that are being made. The 30-day public
comment period on the proposed regulations ended March 16, 2005. DOD and
OPM notified the Congress that they are preparing to begin the meet and
confer process with employee representatives who provided comments on the
proposed regulations. Last month, during testimony, we stated that DOD is
at the beginning of a long road, and the meet and confer process has to be
meaningful and is critically important because there are many details of
the proposed regulations that have not been defined. These details do
matter, and how they are defined can have a direct bearing on whether or
not the ultimate new human resources management system is both reasoned
and reasonable.

Evaluating DOD's New Human Resources Management System

Evaluating the impact of NSPS will be an ongoing challenge for DOD. This
is especially important because DOD's proposed regulations would give
managers more authority and responsibility for managing the new human
resources management system. High-performing organizations continually
review and revise their human capital management systems based on
datadriven lessons learned and changing needs in the work environment.
Collecting and analyzing data will be the fundamental building block for
measuring the effectiveness of these approaches in support of the mission
and goals of the department.

DOD's proposed regulations indicate that DOD will establish procedures for
evaluating the regulations and their implementation. We believe that DOD
should consider conducting evaluations that are broadly modeled on the
evaluation requirements of the OPM demonstration projects. Under the
demonstration project authority, agencies must evaluate and periodically
report on results, implementation of the demonstration project, cost and
benefits, impacts on veterans and other equal employment opportunity
groups, adherence to merit system principles, and the extent to which the
lessons from the project can be applied governmentwide. A set of balanced
measures addressing a range of results, and customer, employee, and
external partner issues may also prove beneficial. An evaluation such as
this would facilitate congressional oversight; allow for any midcourse
corrections; assist DOD in benchmarking its progress with other efforts;
and provide for documenting best practices and sharing lessons learned
with employees, stakeholders, other federal agencies, and the public.

We have work under way to assess DOD's efforts to design its new human
resources management system, including further details on some of the
significant challenges, and we expect to issue a report on the results of
our work sometime this summer.

  Framework for Governmentwide Human Capital Reform

DOD recently joined a few other federal departments and agencies, such as
DHS, the National Aeronautics and Space Administration, and the Federal
Aviation Administration, in receiving authorities intended to help them
strategically manage their human resources management system to achieve
results. In this changing environment, the federal government is quickly
approaching the point where "standard governmentwide" human capital
policies and processes are neither standard nor governmentwide.

To help advance the discussion concerning how governmentwide human capital
reform should proceed, we and the National Commission on the Public
Service Implementation Initiative hosted a forum in April 2004 on whether
there should be a governmentwide framework for human capital reform and,
if so, what this framework should include.35 To start the discussion, we
suggested, in advance of the forum, a framework of

35 GAO and the National Commission on the Public Service Implementation
Initiative, Highlights of a Forum: Human Capital: Principles, Criteria,
and Processes for Governmentwide Federal Human Capital Reform, GAO-05-69SP
(Washington, D.C.: Dec. 1, 2004).

principles, criteria, and processes based on congressional and executive
branch decision making and prior work.

While there was widespread recognition among the forum participants that a
one-size-fits-all approach to human capital management is not appropriate
for the challenges and demands faced by government, there was equally
broad agreement that there should be a governmentwide framework to guide
human capital reform. Furthermore, a governmentwide framework should
balance the need for consistency across the federal government with the
desire for flexibility, so that individual agencies can tailor human
capital systems to best meet their needs. Striking this balance would not
be easy, but such a balance is necessary to maintain a governmentwide
system that is responsive enough to adapt to agencies' diverse missions,
cultures, and workforces.

While there were divergent views among the forum participants, there was
general agreement on a set of principles, criteria, and processes that
would serve as a starting point for further discussion in developing a
governmentwide framework in advancing human capital reform, as shown in
figure 1.

                 Figure 1: Principles, Criteria, and Processes

Principles that the government should retain in a framework for reform
because of their inherent, enduring qualities:

o  merit principles that balance organizational mission, goals, and
performance objectives with individual rights and responsibilities;

o  ability to organize, bargain collectively, and participate through
labor organizations;

o  continued prohibition of certain personnel practices; and

o  guaranteed due process that is fair, fast, and final.

Criteria that agencies should have in place as they plan for and manage
their new human capital authorities:

o  demonstrated business case or readiness for use of targeted
authorities;

o  an integrated approach to results-oriented strategic planning and human
capital planning and management;

o  adequate resources for planning, implementation, training, and
evaluation; and

o  a modern, effective, credible, and integrated performance management
system that includes adequate safeguards to ensure equity and prevent
discrimination.

Processes that agencies should follow as they implement new human capital
authorities:

o  prescribing regulations in consultation or jointly with the Office of
Personnel Management;

o  establishing appeals processes in consultation with the Merit Systems
Protection Board;

o  involving employees and stakeholders in the design and implementation
of new human capital systems;

o  phasing in implementation of new human capital systems;

o  committing to transparency, reporting, and evaluation;

o  establishing a communications strategy; and

o  assuring adequate training.

                                  Source: GAO.

  Concluding Observations

As we testified previously on the DOD and DHS civilian personnel reforms,
an agency should have to demonstrate that it has a modern, effective,
credible, and, as appropriate, validated performance management system in
place with adequate safeguards, including reasonable transparency and
appropriate accountability mechanisms, to ensure fairness and prevent
politicization of the system and abuse of employees before any related
flexibilities are operationalized. DOD's proposed NSPS regulations take a
valuable step toward a modern performance management system as well as a
more market-based, results-oriented compensation system. DOD's proposed
performance management system is intended to align individual

performance and pay with the department's critical mission requirements;
hold employees responsible for accomplishing performance expectations; and
provide meaningful distinctions in performance. However, the experiences
of high-performing organizations suggest that DOD should require core
competencies in its performance management system. The core competencies
can serve to reinforce employee behaviors and actions that support the DOD
mission, goals, and values and to set expectations for individuals' roles
in DOD's transformation, creating a shared responsibility for
organizational success and ensuring accountability for change.

DOD's overall effort to design and implement a strategic human resources
management systemalong with the similar effort of DHScan
be particularly instructive for future human capital management,
reorganization, and transformation efforts in other federal agencies.

Mr. Chairman and Members of the Subcommittee, this concludes my prepared
statement. I would be pleased to respond to any questions that you may
have at this time.

  Contacts and Acknowledgments

For further information, please contact Derek B. Stewart, Director,
Defense Capabilities and Management, at (202) 512-5559 or
[email protected]. For further information on governmentwide human capital
issues, please contact Eileen R. Larence, Director, Strategic Issues, at
(202) 512-6512 or [email protected]. Major contributors to this testimony
include Sandra F. Bell, Renee S. Brown, K. Scott Derrick, William J.
Doherty, Clifton G. Douglas, Jr., Barbara L. Joyce, Julia C. Matta, Mark
A. Pross, William J. Rigazio, John S. Townes, and Susan K. Woodward.

Appendix I

"Highlights" from Selected GAO Human Capital Reports

Appendix I "Highlights" from Selected GAO Human Capital Reports Appendix I
"Highlights" from Selected GAO Human Capital Reports Appendix I
"Highlights" from Selected GAO Human Capital Reports Appendix I
"Highlights" from Selected GAO Human Capital Reports Appendix I
"Highlights" from Selected GAO Human Capital Reports Appendix I
"Highlights" from Selected GAO Human Capital Reports

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