Highlights of a GAO and National Commission on the Public Service
Implementation Initiative Forum on Human Capital: Principles,	 
Criteria, and Processes for Governmentwide Federal Human Capital 
Reform (01-DEC-04, GAO-05-69SP).				 
                                                                 
There is widespread agreement that the federal government faces a
range of challenges in the 21st century that it must confront to 
enhance performance, ensure accountability, and position the	 
nation for the future. Federal agencies will need the most	 
effective human capital systems to address these challenges and  
succeed in their transformation efforts during a period of likely
sustained budget constraints. More progress in addressing human  
capital challenges was made in the last 3 years than in the last 
20, and significant changes in how the federal workforce is	 
managed are underway. On April 14, 2004, GAO and the National	 
Commission on the Public Service Implementation Initiative hosted
a forum with selected executive branch officials, key		 
stakeholders, and other experts to help advance the discussion	 
concerning how governmentwide human capital reform should	 
proceed.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-69SP					        
    ACCNO:   A13876						        
  TITLE:     Highlights of a GAO and National Commission on the Public
Service Implementation Initiative Forum on Human Capital:	 
Principles, Criteria, and Processes for Governmentwide Federal	 
Human Capital Reform						 
     DATE:   12/01/2004 
  SUBJECT:   Civil service					 
	     Federal agency reorganization			 
	     Federal employees					 
	     Human resources utilization			 
	     Labor force					 
	     Personnel evaluation systems			 
	     Personnel management				 
	     Strategic planning 				 
	     Productivity in government 			 
	     Conferences					 
	     Human capital					 

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GAO-05-69SP

     

     * d0569SP.pdf
          * Human Capital Reform: Highlights of Forum Discussion
               * Should There Be a Governmentwide Framework for Human Capital
                 Reform?
               * What Should a Governmentwide Framework for Human Capital
                 Reform Include?
                    * Modern Principles that Should Be Prescribed
                      Governmentwide
                    * Criteria That Should Be Required for Agencies To Use
                      New Human Capital Authorities
                    * Processes That Should Be Prescribed Governmentwide for
                      Agencies to Implement New Authorities
                    * Next Steps in Human Capital Reform
          * Forum Attendees
               * Moderators
               * Participants
               * Congressional Observers
               * Other Observers
     * d0569SP.pdf
          * Human Capital Reform: Highlights of Forum Discussion
               * Should There Be a Governmentwide Framework for Human Capital
                 Reform?
               * What Should a Governmentwide Framework for Human Capital
                 Reform Include?
                    * Modern Principles that Should Be Prescribed
                      Governmentwide
                    * Criteria That Should Be Required for Agencies To Use
                      New Human Capital Authorities
                    * Processes That Should Be Prescribed Governmentwide for
                      Agencies to Implement New Authorities
                    * Next Steps in Human Capital Reform
          * Forum Attendees
               * Moderators
               * Participants
               * Congressional Observers
               * Other Observers

                             HIGHLIGHTS OF A FORUM

Human Capital: Principles, Criteria, and Processes for Governmentwide
Federal Human Capital Reform

What Participants Said

Forum participants discussed (1) Should there be a governmentwide
framework for human capital reform? and (2) If yes, what should a
governmentwide framework include?

There was widespread recognition that a "one size fits all" approach to
human capital management is not appropriate for the challenges and demands
government faces. However, there was equally broad agreement that there
should be a governmentwide framework to guide human capital reform built
on a set of beliefs that entail fundamental principles and boundaries that
include criteria and processes that establish the checks and limitations
when agencies seek and implement their authorities. While there were
divergent views among the participants, there was general agreement that
the following served as a starting point for further discussion in
developing a governmentwide framework to advance needed human capital
reform.

  Principles

     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 Certain prohibited personnel practices
     o Guaranteed due process that is fair, fast, and final

  Criteria

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

  Processes

     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
     o Assuring adequate training

                 United States Government Accountability Office

A

United States Government Accountability Office Washington, D.C. 20548

December 1, 2004

Subject: Highlights of a GAO and National Commission on the Public Service
Implementation Initiative Forum on Human Capital: Principles, Criteria,
and Processes for Governmentwide Federal Human Capital Reform

There is widespread agreement that the federal government faces a range of
challenges in the 21st century that it must confront to enhance
performance, ensure accountability, and position the nation for the
future. Federal agencies will need the most effective human capital
systems to address these challenges and succeed in their transformation
efforts during a period of likely sustained budget constraints.

The National Commission on the Public Service has reported that the
federal government is neither organized nor staffed nor adequately
prepared to meet the challenges of the 21st century.1 To address these
challenges, the National Commission made recommendations in three key
areas. They are: (1) Organization: reorganize the federal government by
mission to improve its capacity for coherent design and efficient
implementation of public policy and reauthorize presidential
reorganization authority to get this process started; (2) Leadership:
reform the entry process for top leaders and undertake the long-term
development of a highly skilled federal management corps; and (3)
Operations: improve federal workforce recruitment and retention and adopt
new personnel management principles to ensure much higher levels of
government performance.

Strategic human capital management must be the centerpiece of the federal
government's overall transformation effort. To that end, more progress in
addressing human capital challenges was made in the last 3 years than in
the last 20, and significant changes in how the federal workforce is
managed are underway. For example, Congress provided agencies specific
hiring authorities so that they can better compete for talented people in
a highly competitive job market. In addition, the U.S. Government
Accountability Office (GAO), National Aeronautics and Space
Administration, the Department of Defense, and the Department of

1The National Commission on the Public Service, Urgent Business for
America: Revitalizing the Federal Government for the 21st Century
(Washington, D.C.: January 2003).

Homeland Security recently received authorities intended to help them
manage their human capital strategically to achieve results. These recent
actions have significant, precedent-setting implications for the rest of
government. They represent both progress and opportunities, but also raise
legitimate concerns. We are fast approaching the point where "standard
governmentwide" human capital policies and processes are neither standard
nor governmentwide. Human capital reform should avoid further
fragmentation within the civil service, ensure reasonable consistency
within the overall civilian workforce, and help maintain a reasonably
level playing field among federal agencies when competing for talent.
Further, human capital reform should maintain key merit principles and
appropriate safeguards against discrimination and other prohibited
personnel practices.

To help advance the discussion concerning how human capital reform should
proceed, GAO and the National Commission on the Public Service
Implementation Initiative co-hosted a forum on April 14, 2004 to discuss:

     o Should there be a governmentwide framework for human capital reform?
     o If yes, what should a governmentwide framework include?

The forum neither sought nor achieved consensus on all of the issues
identified in the discussion. Nevertheless, there was widespread
recognition among the forum participants that a "one size fits all"
approach to human capital management is not appropriate given the range of
the challenges and demands government faces. However, there was equally
broad agreement that there should be a governmentwide framework to guide
human capital reform built on a set of beliefs and boundaries. Beliefs
entail the fundamental principles that should govern all approaches to
human capital reform and should not be altered or waived by agencies
seeking human capital authorities. Boundaries include the criteria and
processes that establish the checks and limitations when agencies seek and
implement human capital authorities. Further, a governmentwide framework
should balance the desire 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.

While there were divergent views among the participants, there was general
agreement that the following principles, criteria, and processes served as
a starting point for further discussion in developing a governmentwide
framework to advance needed 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 Certain prohibited personnel practices
     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
     o A modern, effective, credible, and integrated performance management
       system that includes adequate safeguards to help 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 (OPM)
     o Establishing appeals processes in consultation with the Merit Systems
       Protection Board (MSPB)
     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
     o Assuring adequate training

Source: GAO.

At the forum, the Director of OPM released a draft of OPM's Guiding
Principles for Civil Service Transformation that should be very helpful in
advancing and deepening the discussion of governmentwide civil service
reform.2 The Director invited forum participants and others to comment on
the draft paper.

Attendees at the forum represented a cross section of senior leaders from
the executive branch with responsibilities for human capital management,
congressional staff from committees with jurisdiction over governmentwide
human capital policy, employee representatives, and academics and other
stakeholders who are involved in or have knowledge of current federal
human capital reform efforts. As agreed with the participants, the purpose
of the discussion was to engage in an open, nonattribution-based dialogue.
Appendix I of this letter summarizes the collective discussion and does
not necessarily represent the views of any individual participant,
including GAO or the Implementation Initiative. Appendix II lists the
forum attendees and observers.

We wish to thank all of the participants in the forum for taking the time
to share their knowledge and to provide their insights and perspectives on
the important matters this document discusses. As the momentum accelerates
for human capital reform, GAO looks forward to working with others, such
as the National Academy of Public Administration and the National
Commission on the Public Service Implementation Initiative, which offered

2U.S. Office of Personnel Management, OPM's Guiding Principles for Civil
Service Transformation (Washington, D.C.: Apr. 14, 2004) can be accessed
at
http://www.opm.gov/Strategic_Management_of_Human_Capital/documents/merit/

Page 4 GAO-05-69SP Governmentwide Human Capital Reform

to serve as a convener for further discussion on this and other important
issues of mutual interest and concern.3

David M. Walker Comptroller General of the United States Paul A. Volcker
Chairman, National Commission on the Public Service

3See The National Commission on the Public Service Implementation
Initiative and The National Academy of Public Administration, A
Governmentwide Framework for Federal Personnel Reform: A Proposal
(Washington, D.C.: November 2004).

Page 5 GAO-05-69SP Governmentwide Human Capital Reform

Appendix I

              Human Capital Reform: Highlights of Forum Discussion

Should There Be a Governmentwide Framework for Human Capital Reform?

Recent actions in human capital reform have significant, precedent-setting
implications for the rest of government. They represent progress and
opportunities, but also legitimate concerns. We are fast approaching the
point where "standard governmentwide" human capital policies and processes
are neither standard nor governmentwide. The forum's overall purpose was
to discuss:

 1. Should there be a governmentwide framework for human capital reform?
 2. If yes, what should a governmentwide framework include?

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 government faces, there was
equally broad agreement that there should be a governmentwide framework to
guide human capital reform built on a set of beliefs and boundaries.
Beliefs entail the fundamental principles that should govern all
approaches to human capital reform and should not be altered or waived by
agencies seeking human capital authorities. Boundaries include the
criteria and processes that establish the checks and limitations when
agencies obtain and implement human capital authorities. Further, 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 to achieve, but is necessary to
maintain a governmentwide system that is responsive enough to adapt to
agencies' diverse missions, cultures, and work forces. The Office of
Personnel Management's (OPM) draft Guiding Principles for Civil Service
Transformation states that in modernizing the federal civil service
system, "finding the right balance between flexibility and uniformity will
be our greatest challenge."1 Recent human capital initiatives have begun
to define that balance. For example, when Congress granted human capital
authorities for the Department of Homeland Security (DHS) and the
Department of Defense (DOD), Congress required both DHS and DOD to

1U.S. Office of Personnel Management, OPM's Guiding Principles for Civil
Service Transformation (Washington, D.C.: Apr. 14, 2004).

Page 6 GAO-05-69SP Governmentwide Human Capital Reform

adhere to the merit system principles, avoid prohibited personnel
practices, and retain the right for employees to organize and bargain
collectively. On the other hand, DHS and DOD have flexibility in how they
design and implement their classification, pay, performance, appeals, and
labor-relations systems to meet their organizational priorities,
structures, and cultures.

Participants cited several reasons why having a governmentwide human
capital framework would be both desirable and appropriate. First, broad
consistency across federal agencies is critical to ensure that each
federal employee has certain safeguards and protections regardless of
where he or she works. For example, OPM's draft Guiding Principles
acknowledges that federal employees might be better served by a single set
of procedures in areas such as due process and labor relations. Further,
other participants concurred that too much variation in each agency could
be problematic for organizations that are responsible for adjudicating
appeals and grievances, such as the Merit Systems Protection Board (MSPB)
and the Equal Employment Opportunity Commission (EEOC). In formal
proceedings, it could be difficult to rule that an individual's action
would be sanctioned in one agency but not in another agency.

Second, a governmentwide framework would allow for some central
coordination that could help minimize any adverse impact that single
agencies' authorities might have on other agencies. Many agreed that a
strong role for OPM would be necessary and appropriate. For example, in
the proposed regulations for developing its human capital system, DHS is
to coordinate with OPM when DHS establishes its occupational clusters and
pay bands and their minimum and maximum rates of pay, as well as when it
sets nationwide and locality-based pay adjustments each year. The proposed
regulations also provide OPM the authority to intervene in, and if
necessary to veto, the use of an authority when the potential exists to
adversely affect others across government. For example, it was suggested
that mobility across agencies could be adversely affected by differing
agency compensation systems.

Other participants added that a governmentwide framework would help to
avoid further fragmentation and maintain a level playing field among
federal agencies in competing for talent. For example, it was suggested
that in light of current global threats, agencies with security-related
missions may have already received human capital authorities to help them
better respond to their missions, and thus a framework could help other
agencies receive similar authorities so they could better meet theirs.

Similarly, GAO has testified that it is preferable to employ a
governmentwide approach to grant certain authorities that have broadbased
application (e.g., broadbanding, pay for performance, part-time
employment, reemployment annuities) and have serious potential
implications for the civil service system.2

Finally, within a governmentwide framework, agencies collectively could
leverage their size and take advantage of certain economies of scale.
OPM's draft Guiding Principles recognizes the federal government's immense
buying power as a single employer. OPM's draft noted that the actuarial
cost of seceding from federal government programs, such as benefit
programs for health care delivery, retirement, and life insurance, would
be high. Specifically, under the Federal Employees Health Benefits
Program, the federal workforce as a whole has been able to maintain
benefits for enrollees, reduce costs to both the taxpayer and the
employee, and mitigate financial risks. According to OPM, the same large
scale may be able to benefit agencies' human resources information systems
that share a common set of functional requirements.

On the other hand, participants stressed that a governmentwide framework
should be flexible, agile, and responsive enough to adapt to any
circumstance given agencies' diverse missions. To that end, many
participants agreed that implementing a variety of human capital systems
within a framework would be acceptable and in the long term, the most
effective approach for agencies to deploy a workforce to help achieve
their intended results. In determining what a governmentwide framework
should consist of, one participant said that the approaches taken by
leading global corporations could provide some insights. These
corporations first determine if there is a strategic reason to retain a
function at the corporate level, and if not, they devolve that function to
their lower levels. In the context of the federal government, this means
determining what must be done consistently across the government and
leaving everything else to individual agencies' authorities. With any
governmentwide framework, several participants cautioned that it would be
necessary to guard against having the framework become a straight jacket
that discourages innovation rather than being an enabler for agencies to
identify and manage needed authorities.

2GAO, Human Capital: Building on DOD's Reform Effort to Foster
Governmentwide Improvements, GAO-03-851T (Washington, D.C.: June 4, 2003).

Page 8 GAO-05-69SP Governmentwide Human Capital Reform

What Should a Governmentwide Framework for Human Capital Reform Include?

Most participants agreed that a framework to guide human capital reform
efforts should consist of modern principles that should be prescribed
governmentwide, criteria that should be required for agencies to use new
human capital authorities, and processes that should be prescribed
governmentwide for agencies to implement new authorities. To start the
discussion, GAO and the Implementation Initiative suggested, in advance of
the forum, a set of principles, criteria, and processes based on
congressional and executive branch decision making and prior work. While
there were divergent views among the participants, there was general
agreement that the following principles, criteria, and processes served as
a starting point for further discussion in developing a governmentwide
framework to advance needed human capital reform.

  Modern Principles that Should Be Prescribed Governmentwide

The participants agreed that there should be principles that the
government should retain in a governmentwide framework for reform because
of their inherent, enduring qualities. Participants observed that
incorporating such principles in statute should be limited to those that
have stood the test of time.

    Merit principles that balance organizational mission, goals, and performance
    objectives with individual rights and responsibilities.

All participants agreed that a set of merit principles should be a part of
a governmentwide framework to guide human capital reform efforts.
Generally, the merit system principles assure that federal employees are
hired, promoted, paid, and discharged only on the basis of merit. Congress
has not waived or altered the current merit system in recent laws granting
federal agencies human capital authorities and both DOD and DHS are to
adhere to the merit system principles. In addition, OPM's draft Guiding
Principles states that merit principles must remain intact as the
government moves forward with modernizing the civil service system.

Nevertheless, it was observed that there remain opportunities to update
the current merit system principles to reflect the increased focus on
missions, goals, and results as envisioned under the Government
Performance and Results Act. While these updated merit principles would
still protect employee interests, they would also take into account the
organizational needs of federal agencies and the special roles and needs
of federal employees as public servants. For example, the current
principles do not address an organizational context, such as a shared
vision or cooperation, except for the public service at large. In this
regard, an updated principle would be for managers, employees, and their
representatives to work together to balance management responsibilities
and employee interests to effectively and efficiently achieve high
performance of the organization's mission and goals. Also, updated merit
principles would be designed to support and create excellence.
Specifically, recruitment would be drawn from highly qualified rather than
qualified individuals and job security would be extended to those whose
performance contributes to organizational goals rather than those whose
performance is adequate.

On the other hand, it was also observed that performance, even at the
highest level, should not be the sole basis for job security even though
additional weight should be given to performance as a factor in a
reduction in force. Concern was also expressed that the timing of any
re-examination of the merit principles is important and that such an
undertaking could possibly influence DHS's and DOD's implementation of
their human capital authorities since adherence to the principles is
mandated.

Generally participants felt that as agencies receive more authority to
establish their own human capital systems, it is especially important to
engender trust among federal employees by prescribing the adherence to
merit principles. It was suggested that governmentwide, organizations such
as OPM, MSPB, EEOC, and the Office of Special Counsel, could provide
sufficient counterweight when agencies develop and implement their own
systems to ensure that merit principles are enforced when agencies receive
new human capital authorities.

The National Academy of Public Administration and the National Commission
on the Public Service Implementation Initiative have offered to serve as
conveners for further discussions on this and other related issues.

Ability to organize, bargain collectively, and participate through labor
organizations. Generally, participants agreed that the ability to
organize, bargain collectively, and participate in labor organizations is
an important principle to be retained in a governmentwide framework.
Congress has already incorporated this provision in recent human capital
legislation. Both DOD and DHS are to retain the right for employees to
organize, bargain collectively, and participate through labor
organizations of their own choosing, subject to the provisions of the new
laws.

It was suggested 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 human capital
reform. One participant noted that although some people believe collective
bargaining slows down the process of reform, there are examples of
effective labor-management relationships. For example, because the
Internal Revenue Service (IRS) is exempt from certain Title 5 provisions,
Congress mandated IRS to involve employees to gain ownership for the new
policies. In response, GAO reported that IRS and the National Treasury
Employees Union entered into an agreement that was designed to ensure that
employees are adequately represented and informed of proposed new policies
and have input into the proposals.3

Nevertheless, there might be opportunities for improvement in labor
relations. OPM's draft Guiding Principles paper states that a
governmentwide framework should continue to guarantee employees' rights to
join unions and bargain collectively. However, a single set of streamlined
and simplified procedures for labor relations and collective bargaining
may be the best way to modernize labor relations, rather than by using an
agency-by-agency approach. Similarly, the National Commission on the
Public Service agrees that employees' rights to organize, bargain
collectively, and participate through labor organizations should be
retained as a principle of human capital reform.4 Nevertheless, a new
level of labormanagement discourse is necessary if the government is to
achieve real reform, and engaged and mutually respectful labor relations
should be a high federal priority.

One participant suggested it would be useful to craft guidance on how to
design and implement revised collective bargaining procedures and manage
conflicts to achieve results. Further, DOD's human capital reform
legislation may be the starting point for such guidance. DOD is to provide
employee representatives and management the opportunity to have meaningful
discussions concerning the development of the new system. In addition, DOD
is to give employee representatives at least 30 calendar days (unless
extraordinary circumstances require earlier action) to review and make
recommendations on the proposal for the system and give any
recommendations received full and fair consideration, among other

3GAO, Human Capital: Practices That Empowered and Involved Employees,
GAO-01-1070 (Washington, D.C.: Sept. 14, 2001).

4The National Commission on the Public Service, Urgent Business for
America: Revitalizing the Federal Government for the 21st Century
(Washington, D.C.: January 2003).

Page 11 GAO-05-69SP Governmentwide Human Capital Reform

criteria. The legislation also includes a 6-year time limit, after which
the labor-relations provisions in Title 5 will apply, unless the authority
is extended.

Certain prohibited personnel practices. Generally, participants agreed
that certain personnel practices, such as reprisal for whistle blowing,
and violation of veterans' preference requirements, should be explicitly
prohibited and included as a governmentwide principle. Some participants
felt that such a principle has negative overtones and implies that without
an explicit prohibition, there would be management abuse. Others
acknowledged that an explicit principle was a necessary safeguard in the
public sector where the workforce takes an oath rather than signs a
contract and expectations are greater for transparency and accountability.
However, ultimately it depends on management to enforce this principle in
the spirit that was intended.

Guaranteed due process that is fair, fast, and final. Participants also
agreed that guaranteed due process is an important principle in a
governmentwide framework. Congress required both DHS and DOD to ensure
employees are afforded the protections of due process in their proposed
human capital systems.

Nevertheless, it has been observed that as the federal human capital
system is reformed, the current approach to due process should similarly
be reexamined. For example, the National Commission on the Public Service
Implementation Initiative and the National Academy of Public
Administration recently sponsored a forum on the federal appeals system in
response to the ongoing debate about the new systems for DHS and DOD.
Forum attendees reached a consensus that any federal employee appeals
systems should be fair, fast, and final; preserve the core rights of
employees and the general public interest; and consider protecting the
agency's mission.5

In addition, OPM's draft Guiding Principles notes that due process for
federal workers for any action that threatens their employment is a
principle that may be best protected by a single set of adverse action
procedures for both misconduct and poor performance for all agencies, as

5National Commission on the Public Service Implementation Initiative and
National Academy of Public Administration, Conversations on Public
Service: Forum on the Federal Appeals System: Items of Consensus (February
2004).

Page 12 GAO-05-69SP Governmentwide Human Capital Reform

  Criteria That Should Be Required for Agencies To Use New Human Capital
  Authorities

well as a single independent adjudicating agency. Similarly, the National
Commission on the Public Service found that there are multiple agencies
involved in handling employee appeals that form a tangled scheme with
varying procedures and case law. Lastly, GAO has reported that the complex
system to protect employees' rights to due process is inefficient,
expensive, and time-consuming.6

The participants generally agreed that some criteria should be required
for agencies to use new human capital authorities. However, there was some
discussion about whether agencies should have these criteria designed or
in place before an agency could implement its authorities. Some
participants maintained that agencies should have broad human capital
authorities when there is not a compelling reason for centralization and
consistency across government. In other words, centralization or the
absence of authority should require a business case, not the other way
around. However, others felt that requiring some of these criteria to be
in place before authorities are granted, as opposed to when authorities
are implemented, could have the unintended consequence of discouraging
human capital reform.

Demonstrated business case or readiness for use of targeted authorities.
Several participants observed that requiring agencies to present a
business case for any requested authority would be a positive step towards
the integration of human capital policies and programs with strategic
planning. Other participants, however, felt that requiring a business case
could have the unintended consequence of discouraging human capital
reform. Instead, a readiness assessment could suffice to receive the
authority, with the clear understanding that certain elements would have
to be in place to go ahead with its implementation. Those who held this
view believed that the better course is to authorize broad agency
flexibilities but ensure that they are exercised responsibly.

High performing organizations determine agency workforce needs using
fact-based analysis. They identify their current and future human capital
needs, including the appropriate number of employees; the key competencies
for mission accomplishment; and the appropriate deployment of staff across
the organization. GAO has reported that federal

6GAO, Federal Employee Redress: A System in Need of Reform,
GAO/T-GGD-96-110 (Washington, D.C.: Apr. 23, 1996).

Page 13 GAO-05-69SP Governmentwide Human Capital Reform

agencies often have not gathered and analyzed the data required to
effectively assess how well their human capital approaches have supported
results.7

Congress has recognized the importance of granting authorities to agencies
based on demonstrated needs. The authorities given to the National
Aeronautics and Space Administration (NASA) are intended to enable NASA to
compete successfully with the private sector to attract and retain a
world-class workforce and to reshape and redeploy its workforce more
effectively to support the mission. In advance of exercising any of the
new authorities, NASA is to submit a workforce plan, approved by OPM, 90
days before NASA implements its human capital authorities. The workforce
plan is to describe the critical needs and how the new authorities would
address those needs.

Some participants suggested that a governmentwide approach, rather than
the more piecemeal approach of agencies developing unique plans, would be
more effective and efficient in the long term. OPM or the Office of
Management and Budget (OMB) could develop a business case for
governmentwide change that would be applicable to all agencies. One
participant felt that, in effect, a governmentwide business case has in
fact been made since the DOD and DHS legislations have already
demonstrated the need and recognition for change.

Some participants questioned the government's willingness and ability to
take risk as agencies' leadership implement human capital reforms in their
organizations. For example, a participant noted that he was particularly
concerned about the findings from a Brookings Institution report that
showed there is not a high willingness to accept risk and change in the
government.8 The report found that 55 percent of federal employees
surveyed reported that their organization encourages them to take risks, 9
percent lower than the private-sector employees surveyed.

GAO has found that to effectively implement human capital authorities,
managers and supervisors need to have an appropriate attitude toward risk
taking and proceed with new operations after carefully analyzing the risks

7GAO, Human Capital: Effective Use of Flexibilities Can Assist Agencies in
Managing Their Workforces, GAO-03-2 (Washington, D.C.: Dec. 6, 2002).

8The Brookings Institution, The Troubled State of the Federal Public
Service (Washington, D.C.: June 27, 2002).

Page 14 GAO-05-69SP Governmentwide Human Capital Reform

involved and determining how they may be minimized or mitigated.9 The
insufficient and ineffective use of authorities can significantly hinder
the ability of federal agencies to recruit, hire, retain, and manage their
human capital. Also, with appropriate accountability mechanisms in place,
agencies can begin to foster an organizational culture that encourages
managers to develop creative approaches and take appropriate risks.

Integrated approach to results-oriented strategic planning and human
capital planning and management. Participants generally agreed that
agencies need to link their strategic and human capital planning and
management in order to achieve the desired outcomes with the team, unit,
and individual performance management systems. It was noted that while
many agencies do not currently have the infrastructure to do this, this
infrastructure is essential to effectively address future demands.

Effective organizations integrate their strategies for accomplishing their
mission and programmatic goals with human capital approaches.10 The
effectiveness of this integration is judged by how well it helps achieve
organizational goals. To this end, Congress has already begun to require
this integrated approach in recent human capital legislation. Congress
explicitly required DOD to link its new performance management system with
the agency's strategic plan. Additionally, we reported DHS has begun
strategic human capital planning.11 For example, one of the department's
strategic goals, organizational excellence, has an objective focused on
ensuring effective recruitment, development, compensation, succession
management and leadership of a diverse workforce to provide optimal
service at a responsible cost.

GAO also stated that any additional human capital authorities should be
implemented only when an agency has the institutional infrastructure in
place. This infrastructure includes, among other things, a human capital
planning process that integrates the agency's human capital policies,
strategies, and programs with its program goals, mission and desired
outcomes. For example, GAO has reported that leading organizations use

9 GAO-03-2.

10GAO, A Model of Strategic Human Capital Management, GAO-02-373SP
(Washington, D.C.: Mar. 15, 2002).

11GAO, Human Capital: DHS Faces Challenges In Implementing Its New
Personnel System, GAO-04-790 (Washington, D.C.: June 18, 2004).

Page 15 GAO-05-69SP Governmentwide Human Capital Reform

succession planning and management as a strategic tool that focuses on
their current and future needs and identifies and develops high-potential
staff with the aim of filling leadership and other key roles in order to
meet their missions over the long term.12

Adequate resources for planning, implementation, training, and evaluation.
There was widespread agreement among the participants that making human
capital reform most effective would require that agencies have adequate
resources to ensure sufficient planning, implementation, training, and
evaluation. Experience has shown that additional resources are necessary.
OPM has reported that the increased costs of implementing alternative
personnel systems should be acknowledged and budgeted for up front.
Similarly, GAO reported that selected OPM personnel demonstration projects
experienced increased costs associated with implementing alternative
personnel systems related to salaries, training, and automation and data
systems.13

Recent human capital reforms recognize the need for adequate resources for
their implementation. Congress required DOD to ensure adequate resources
are allocated for the design, implementation, and administration of its
new performance management system. DHS also recognized that significant
resources would be needed to design and implement a new human capital
system. In its proposed regulations, DHS estimates the overall costs
associated with implementing its new human capital system will be
approximately $130 million over a 4-year period.

Many participants pointed out that while sufficient resources are the key
to effectively implementing new pay systems, budget constraints are a
given in the public service. For example, one participant noted that in
the current environment, pay for performance is more like pay by budget
because the budget drives pay, not performance. Some felt that Congress
often authorizes pay raises for federal employees but does not then
provide additional resources to agencies to make the required pay
adjustments. To make up the difference, agencies must find resources from
other areas in their budgets. On the other hand, it was observed that
Congress authorized

12GAO, Human Capital: Insights for U.S. Agencies from Other Countries'
Succession Planning and Management Initiatives, GAO-03-914 (Washington,
D.C.: Sept. 15, 2003).

13GAO, Human Capital: Implementing Pay for Performance at Selected
Personnel Demonstration Projects, GAO-04-83 (Washington, D.C.: Jan. 23,
2004).

Page 16 GAO-05-69SP Governmentwide Human Capital Reform

these pay raises in response to budget proposals that did not provide
parity between civilian and uniformed services personnel.

A modern, effective, credible, and integrated performance management
system that includes adequate safeguards to help ensure equity and prevent
discrimination. Participants generally agreed that performance management
systems with some safeguards are needed. Effective performance management
systems strive to (1) provide candid and constructive feedback to help
individuals maximize their contribution and potential in understanding and
realizing the goals and objectives of the organization, (2) seek to
provide management with the objective and fact-based information it needs
to reward top performers, and (3) provide the necessary information and
documentation to deal with poor performers.

Congress and the administration have recognized the necessity of effective
performance management systems in recent human capital reform initiatives.
Congress established a new performance-based pay system for members of the
Senior Executive Service that is designed to provide a clear and direct
linkage between performance and pay. An agency can seek approval from OPM
to raise the pay for its senior executives if OPM certifies, and OMB
concurs that the agency's performance management system, as designed and
applied, makes meaningful distinctions based on relative performance.

In addition, DOD's human capital legislation requires its new human
capital system to have a fair, credible, and transparent performance
appraisal system that includes effective safeguards to ensure that the
management of the system is fair and equitable and based on employee
performance. The new system also is to have a process for ensuring ongoing
performance feedback and dialogue between supervisors, managers, and
employees throughout the appraisal period.

Under the proposed regulations, the DHS performance management system
must, among other things, align individual performance expectations with
the mission, strategic goals, or a range of other objectives of the
department or of the DHS components. Also, the DHS performance management
system is intended to promote individual accountability by communicating
performance expectations as well as holding employees responsible for
accomplishing them and holding supervisors and managers responsible for
effectively managing the performance of employees under their supervision.
GAO testified that the

  Processes That Should Be Prescribed Governmentwide for Agencies to Implement
  New Authorities

proposal takes another valuable step towards modern performance
management.14

GAO has testified that, before additional human capital authorities are
implemented, 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 politicalization and abuse of employees.15 In addition, GAO
has identified a set of practices that collectively can help agencies
develop effective performance management systems.16

There was widespread agreement that, as a starting point, the following
processes are critical to future human capital reform efforts. While some
participants questioned whether it was necessary to prescribe some of
these processes in legislation, there was recognition that addressing
these processes sets a general expectation that every step should be taken
to ensure the most efficient and effective implementation of agencies'
human capital authorities.

Prescribing regulations in consultation or jointly with OPM and
Establishing appeals processes in consultation with MSPB. The participants
generally agreed that involving OPM and MSPB was necessary for future
human capital reform efforts. However, OPM felt that agencies' jointly
prescribing regulations rather than only consulting with OPM would help to
ensure that civil service principles are preserved when broad authorities
are under consideration. Both DOD and DHS are required to develop
regulations jointly with OPM for their new human capital systems and to
consult with MSPB when developing new appellate procedures. It was
observed that involving OPM and MSPB offers opportunities to ensure that
flexibilities are used in a manner that places the public's interest
paramount.

14GAO, Human Capital: Preliminary Observations on Proposed DHS Human
Capital Regulations, GAO-04-479T (Washington, D.C.: Feb. 25, 2004).

15GAO, Defense Transformation: Preliminary Observations on DOD's Proposed
Civilian Personnel Reforms, GAO-03-717T (Washington, D.C.: Apr. 29, 2003).

16GAO, Results-Oriented Cultures: Creating a Clear Linkage between
Individual Performance and Organizational Success, GAO-03-488 (Washington,
D.C.: Mar. 14, 2003).

Page 18 GAO-05-69SP Governmentwide Human Capital Reform

In its draft Guiding Principles, OPM asserts that implementation of
modernized human capital systems must be managed by OPM to avoid any
adverse impact on other agencies. For example, OPM notes that agency
coordination with OPM is necessary in areas such as in setting minimum and
maximum rates of pay and establishing nationwide and locality-based pay
adjustments to ensure that cross-agency effects are taken into account and
if necessary, mitigated.

On the other hand, it was also observed that OPM might need the people
resources to help manage the implementation of modernized human capital
systems across government. For example, GAO reported that there are
opportunities for OPM to strengthen its current organizational
transformation efforts as it shifts its role from less of a rule maker and
enforcer to more of a strategic partner in leading and supporting
agencies' human capital management systems.17

Involving employees and stakeholders in the design and implementation of
new human capital systems. The participants agreed that actively engaging
employees and stakeholders in designing new human capital systems was an
important process. GAO has reported that a successful organizational
transformation must involve employees and their representatives from the
beginning to gain their ownership for the changes that are occurring in
the organization. Employee involvement strengthens the transformation
process by including frontline perspectives and experiences.18 To involve
employees, agencies can

     o use employee teams to assist in implementing changes;
     o involve employees in planning and sharing performance information to
       help employees understand what the organization is trying to
       accomplish and how it is progressing in that direction, facilitate the
       development of organizational goals and objectives that incorporate
       insights about operations from a front-line perspective, and increase
       employees' understanding and acceptance of organizational goals and
       objectives; and

17GAO, Major Management Challenges and Program Risks: Office of Personnel
Management, GAO-03-115 (Washington, D.C.: January 2003).

18GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers
and Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2,
2003).

Page 19 GAO-05-69SP Governmentwide Human Capital Reform

o  incorporate employee feedback into new policies and procedures.

DOD's human capital legislation requires DOD to include a means for
ensuring employee involvement in the design and implementation of its new
human capital system. Similarly, DHS's legislation requires employee
involvement in the design of its new human capital systems. GAO reported
that during the course of the design process DHS has recognized the
importance of employee involvement and has been involving multiple
organizational components and its three major employee unions in designing
the new human capital system.19

Phasing in implementation of new human capital systems. There was general
understanding among the participants on why a phased approach to
implementing major management reforms was both appropriate and judicious.
A phased implementation approach recognizes that different components of
agencies will often have different levels of readiness and different
capabilities to implement new authorities. Moreover, a phased approach
allows for learning so that appropriate adjustments and midcourse
corrections can be made before new policies and procedures are fully
implemented organizationwide.

Congress has also recognized the need for phasing in new human capital
systems. DOD is to implement its new system for up to 300,000 employees
and cannot expand it until the Secretary determines that the department
has in place a performance management system that meets the criteria
specified in the law. Similarly, according to its proposed regulations,
DHS plans to implement its job evaluation, pay, and performance management
system in phases to allow time for final design, training, and careful
implementation.

Committing to transparency, reporting, and evaluation. The participants
agreed that transparency, reporting, and evaluation are critical processes
in ongoing human capital reform efforts. High-performing organizations
continually review and revise their human capital management systems based
on data-driven lessons learned and changing needs in the environment. It
was observed that the public deserves to be told how well the government
is doing to improve the quality of its civil service as measured against
objective standards linked to promised results.

19GAO, Human Capital: DHS Personnel System Design Effort Provides for
Collaboration and Employee Participation, GAO-03-1099 (Washington, D.C.:
Sept. 30, 2003).

Page 20 GAO-05-69SP Governmentwide Human Capital Reform

The benefits of ongoing evaluation and knowledge sharing are gaining wider
acceptance. Congress required the interagency Chief Human Capital Officers
Council to include an evaluation of the formulation and implementation of
agency performance management systems in its annual report to Congress. In
addition, DHS's proposed regulations indicate that it is committed to an
ongoing comprehensive evaluation of the effectiveness of the human capital
system, including the establishment of human capital metrics and the use
of employee surveys.

One participant observed that there has not been enough evaluation and
sharing of lessons learned from existing alternative human capital
systems. For example, the participant noted that lessons learned from the
Federal Aviation Administration (FAA) could be shared more broadly across
the government. In 1996, the FAA received broad exemptions from Title 5
laws governing federal civilian personnel management, which at the time
was regarded as one of the most flexible human capital efforts in the
federal government. While GAO reported that FAA had not fully incorporated
elements that are important to effective human capital management, FAA's
experiences are valuable nonetheless.20

Along these lines, GAO has reported that agencies seeking human capital
reform should consider doing evaluations that are broadly modeled on the
evaluation requirements of the OPM demonstration projects.21 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, customer, employee, and external
partner issues may also prove beneficial. Such an evaluation could
facilitate congressional oversight; allow for any midcourse corrections;
assist the agencies 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.

20GAO, Human Capital Management: FAA's Reform Effort Requires a More
Strategic Approach, GAO-03-156 (Washington, D.C.: Feb. 3, 2003).

21 GAO-03-717T and GAO-04-479T.

Page 21 GAO-05-69SP Governmentwide Human Capital Reform

Establishing a communications strategy. While the participants agreed that
a communications strategy is an important process in the implementation of
any major change management initiative, such as new human capital
authorities, some questioned whether it is necessary to write it into
legislation for human capital reform. Other participants observed that it
should not be taken for granted that such a strategy would necessarily
happen, and for that reason, making a communication strategy an explicit
requirement in legislation would make it more likely to occur.

GAO has found that creating an effective, on-going communications strategy
is essential to implementing a transformation.22 The organization
undergoing a transformation must develop a comprehensive communications
strategy that reaches out to employees, customers, and stakeholders and
seeks to genuinely engage them in the transformation process.

Assuring adequate training. The participants agreed that training for
employees at all levels was critical to the success of any human capital
reform. High performing organizations understand the value of training.
Several participants suggested that the success of DHS's and DOD's human
capital reform efforts hinged on the type and quality of the training
managers and employees received. However, although training was recognized
as important, some participants questioned whether it is necessary to
prescribe training in legislation.

While DHS's human capital legislation does not require it to provide
training on its new human capital system, DHS recognizes in its proposed
regulations that a substantial investment in training is a key aspect of
implementing a performance management system. DOD's human capital
legislation requires the department to provide adequate training and
retraining for supervisors, managers, and employees in the implementation
and operation of the performance management system.

To ensure that adequate funding is set aside for training for human
capital reform efforts, one participant suggested developing a formula to
designate a fixed amount of training dollars for federal employees so that
training is not cut when agency budgets are constrained. Along these
lines, under the Human Capital Performance Fund that Congress established,
agencies are to use up to 10 percent of their appropriations to train
supervisors,

22GAO-03-669.

  Next Steps in Human Capital Reform

managers, and others on using performance management systems to make
meaningful distinctions in performance. However, Congress has not fully
funded the Performance Fund.

GAO found that organizations implementing personnel demonstration projects
provided extensive training before and during implementation of their new
human capital systems as well as throughout the first 5 or more years of
the project.23 GAO has reported that training and developing new and
current staff to fill new roles and work in different ways will play a
crucial part in the federal government's endeavors to meet its
transformation challenges.24 Ways that employees learn and achieve results
will also continue to transform how agencies do business and engage
employees in further innovation and improvements.

Among the next steps in human capital reform, there was general
recognition for a need to continue to develop a governmentwide framework
for human capital reform that Congress and the administration can
implement to enhance performance, ensure accountability, and position the
nation for the future. The momentum is accelerating to make strategic
human capital management the centerpiece of the federal government's
overall management transformation effort. Agencies such as DOD and DHS
have received broad human capital authorities. It is likely that other
departments and agencies will soon seek their own human capital authority.
There is a need to guide these future reform efforts constructively and
determine if there should be governmentwide change or continue to change
human capital policies agency by agency. Further, if there is
governmentwide change, the amount of authority afforded to agencies must
be determined.

Also, the anticipated future roles of Congress, OPM, and other
stakeholders should be articulated as human capital reforms proceed.
Congress could provide continued oversight of governmentwide human capital
reform. It was generally recognized that such oversight is critical in
ensuring that OPM has a role in the design and implementation of new human
capital systems. OPM could provide a governmentwide perspective to human

23GAO-04-83.

24GAO, Human Capital: A Guide for Assessing Strategic Training and
Development Efforts in the Federal Government, GAO-04-546G (Washington,
D.C.: March 2004).

Page 23 GAO-05-69SP Governmentwide Human Capital Reform

capital reform, for example, by collaborating in the design and
development of new human capital systems and in identifying and mitigating
any adverse impact of reform efforts on other agencies. GAO could continue
assisting Congress in analyzing and supporting efforts to improve the
human capital infrastructure key to successful transformation of the
government. The Implementation Initiative and other key stakeholders can
continue to advance human capital reform through conversations, such as
the one that took place at this forum.

                                  Appendix II

                                Forum Attendees

Moderators    David M. Walker  Comptroller General of the United States    
                                  U.S. Government Accountability Office       
                 Paul A. Volcker  Chairman                                    
                                  National Commission on the Public Service   
Participants Carol A. Bonosaro President                                   
                                  Senior Executives Association               
                  Charles Bowsher    Former Comptroller General of the United 
                                                                       States 
                                  and                                         
                                     Member of the National Commission on the 
                                                                       Public 
                                  Service                                     
                 Dr. David S. Chu Under Secretary of Defense (Personnel and   
                                  Readiness)                                  
                                  Office of the Secretary of Defense          
                                  U.S. Department of Defense                  
                 Claudia A. Cross Chief Human Capital Officer/Director        
                                  Office of Human Resources Management        
                                  U.S. Department of Energy                   
                 Brian DeWyngaert Executive Assistant to the President        
                                            American Federation of Government 
                                                                   Employees, 
                                  AFL-CIO                                     
                   Maureen Gilman Director of Legislation                     
                                  The National Treasury Employees Union       
                   Janet Hale     Under Secretary for Management              
                                  U.S. Department of Homeland Security        
                 Sallyanne Harper Chief Administrative Officer/Chief          
                                  Financial                                   
                                  Officer                                     
                                  U.S. Government Accountability Office       
                  Jesse Hoskins   Chief Human Capital Officer                 
                                  U.S. Government Accountability Office       

Patricia Ingraham   Distinguished Professor The Maxwell School of          
                       Citizenship and Public Affairs                         
                       Syracuse University                                    
Kay Coles James     Director U.S. Office of Personnel Management           
Clay Johnson III    Deputy Director for Management U.S. Office of          
                       Management and Budget                                  
C. Morgan Kinghorn  President National Academy of Public Administration    
Nancy Kingsbury     Managing Director Applied Research and Methods U.S.    
                       Government Accountability Office                       
Rosslyn Kleeman     Distinguished Executive in Residence The George        
                       Washington University                                  
Gail T. Lovelace    Chief People Officer U.S. General Services             
                       Administration                                         
Neil A. G. McPhie   Acting Chairman U.S. Merit Systems Protection Board    
J. Christopher Mihm Managing Director Strategic Issues U.S. Government     
                       Accountability Office                                  
Steve Nelson        Director                                               
                       Office of Policy and Evaluation U.S. Merit Systems     
                       Protection Board                                       
Vicki Novak         Assistant Administrator for Human Resources            
                       National Aeronautics and Space Administration          
Bernard Rosen       Emeritus Distinguished Adjunct Professor in Residence  
                       American University                                    
Ron Sanders         Associate Director                                     
                       Division for Strategic Human Resources Policy U.S.     
                       Office of Personnel Management                         

Joanne Simms           Deputy Assistant Attorney General for Human         
                          Resources and Administration / Chief Human Capital  
                          Officer Justice Management Division U.S. Department 
                          of Justice                                          
Hannah Sistare         Executive Director                                  
                          National Commission on the Public Service           
                          Implementation Initiative                           
Pete Smith             President                                           
                          Private Sector Council                              
Max Stier              President and CEO                                   
                          Partnership for Public Service                      
Michael B. Styles      National President Federal Managers Association     
Robert N. Tobias       Professor                                           
                          American University                                 
Mitchel B. Wallerstein Dean                                                
                          The Maxwell School of Citizenship and Public        
                          Affairs                                             
                          Syracuse University                                 

Mason Alinger Professional Staff Member Observers House Government Reform
Committee

U.S. House of Representatives

Nanci Langley Democratic Deputy Staff Director Subcommittee on Financial
Management, the Budget, and International Security Senate Governmental
Affairs Committee

U.S. Senate

Chris Lu Deputy Chief Counsel - Minority House Government Reform Committee

U.S. House of Representatives

Andrew Richardson         Staff Director                                   
                             Subcommittee on Oversight of Government          
                             Management, the Federal Workforce, and the       
                             District of Columbia                             
                             Senate Governmental Affairs Committee            
                             U.S. Senate                                      
Tania A. Shand            Professional Staff Member                        
                             House Government Reform Committee                
                             U.S. House of Representatives                    
Jennifer Tyree            Counsel                                          
                             Subcommittee on Financial Management, the        
                             Budget, and International Security               
                             Senate Governmental Affairs Committee            
                             U.S. Senate                                      
Marianne Clifford         Minority Staff Director and Chief Counsel        
Upton                     Subcommittee on Oversight of Government          
                             Management, the Federal Workforce, and the       
                             District of Columbia                             
                             Senate Governmental Affairs Committee            
                             U.S. Senate                                      

Other Observers William Atkinson  Former Chief of Staff                    
                                     U.S. Merit Systems Protection Board      
                      Paul Conway    Chief of Staff to the Director U.S.      
                                     Office of Personnel Management           
                   Stephanie Diamond Former Human Resources Program Manager   
                                     Office of Human Resources Management     
                                     U.S. Department of Energy                
                   Rita R. Franklin  Deputy Director, Office of Human         
                                     Resources Management U.S. Department of  
                                     Energy                                   
                    Thomas Richards  Government Affairs Representative        
                                     Federal Managers Association             

Debra Tomchek                        Director for Human Resources          
                                        Justice Management Division           
                               U.S. Department of Justice                     
Didier Trinh                Executive Director                             
                                        Federal Managers Association          
Tracey Watkins                           Senior Advisor to Acting Chairman 
                                          U.S. Merit Systems Protection Board 

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