PricewaterhouseCoopers' Review of the Office of National Drug Control
Policy (Correspondence, 06/26/2000, GAO/GGD-00-170R).

Pursuant to a legislative requirement, GAO reviewed
PricewaterhouseCoopers' (PwC) assessment of the performance, efficiency,
and effectiveness of the Office of National Drug Control Policy's
(ONDCP) operations, focusing on whether: (1) ONDCP performs its
statutory and regulatory responsibilities in an efficient, effective,
and results-oriented manner; (2) ONDCP optimizes human resources in
fulfilling its primary objectives of policy, anti-drug program
coordination, and compliance; and (3) ONDCP's internal control systems
are strategically deployed to enhance business processes throughout the
organization.

GAO noted that: (1) with regard to whether ONDCP performs its statutory
and regulatory responsibilities in an efficient, effective, and
results-oriented manner, it is PwC's opinion that ONDCP is
results-oriented and effective in performing its responsibilities
externally, but inefficient with regard to internal operations; (2) with
regard to whether ONDCP optimizes human resources in fulfilling its
primary objectives of policy, anti-drug coordination, and compliance, it
is PwC's opinion that human resources are not being optimized toward
accomplishing those objectives; (3) PwC determined, however, that
ONDCP's inability to sustain support for the primary objectives is a
result of increases in the workload associated with new program
requirements, the Director's priorities, and ONDCP's inability to
maintain its knowledge base by retaining staff; (4) the organization
could make progress toward optimizing human resources by addressing the
following issues: (a) address the human resource and retention issues
previously discussed; and (b) evaluate the pace of the Director's
Schedule in consideration of its impact on the operational tempo of
ONDCP, the retention of employees and the organization's capability to
support its primary objectives of policy, coordination, and compliance;
(5) with regard to whether ONDCP's internal control systems are
strategically deployed to enhance business processes throughout the
organization it is PwC's opinion that there is an overall low to medium
risk that the organization is not adhering to sound and prudent internal
financial controls; (6) there is, however, an area that should warrant
further attention; (7) there is a potential internal control risk
arising from inadequate matching of increased responsibilities and
workload with the required investment in the financial management
infrastructure; and (8) the significant implications of not mitigating
the risk of a breakdown in the management, supervisory, and personnel
internal controls are: (a) a lack of quality assurance over work
products due to time pressures; (b) inappropriate levels of authority,
delegation, and decision-making, given underlying roles,
responsibilities, and competencies; and (c) a decline in customer
service from the Financial Management Office.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-00-170R
     TITLE:  PricewaterhouseCoopers' Review of the Office of National
	     Drug Control Policy
      DATE:  06/26/2000
   SUBJECT:  Performance measures
	     Agency missions
	     Personnel management
	     Internal controls
	     Financial management systems
	     Strategic planning
	     Human resources utilization
	     Internal audits

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GAO/GGD-00-170R

GAO/ GGD- 00- 170R PricewaterhouseCoopers' Management Review of ONDCP

United States General Accounting Office Washington, DC 20548

General Government Division

June 26, 2000 The Honorable Ben Nighthorse Campbell Chairman The Honorable
Bryon L. Dorgan Ranking Minority Member Subcommittee on Treasury and General
Government Committee on Appropriations United States Senate

The Honorable Jim Kolbe Chairman The Honorable Steny H. Hoyer Ranking
Minority Member Subcommittee on Treasury, Postal Service,

and General Government Committee on Appropriations House of Representatives

Subject: PricewaterhouseCoopers' Review of the Office of National Drug
Control Policy

Enclosed is the final report by PricewaterhouseCoopers LLP on the
performance, efficiency, and effectiveness of the Office of National Drug
Control Policy's (ONDCP) operations. Senate Conference Report 106- 87
directed GAO to contract with an independent entity for the purpose of
conducting a management review of ONDCP's operations. In this regard, we
developed a scope of work that addressed the management concerns raised by
the conferees and identified in the conference report; specifically:

“The review should include, but not be limited to, a review of the
agency's (1) execution of its statutory responsibilities; (2) organizational
planning, management, budgeting, accounting and financial reporting systems;
and (3) human resource management to include a review of staff hiring and
retention.”

We performed the administrative duties necessary to award and monitor the
contract, and ensured that the contractor deliverables were responsive to
the scope of the contract. As directed by the conferees, we also consulted
with the Committees on Appropriations on the parameters of this review.

GAO/ GGD- 00- 170R PricewaterhouseCoopers' Management Review of ONDCP Page 2
PricewaterhouseCoopers was selected in a competitive process to perform this

review, and they met the terms contained in the contract statement of work.
The findings and conclusions expressed in their report are solely those of
PricewaterhouseCoopers. Please contact me or Weldon McPhail on (202) 512-
8777 if you or your staff have any questions about the management of this
effort. Questions regarding the findings or conclusions of the report should
be directed to PricewaterhouseCoopers' Michael Cosgrove on (703) 633- 4000.

Richard M. Stana Associate Director, Administration

of Justice Issues Enclosure

Management Review Office of National Drug Control Policy

i

TABLE OF CONTENTS EXECUTIVE SUMMARY............. 1 OUR
FINDINGS..................................................................................................................................................
1

1.0 OUR APPROACH................. 5

2.0 WHAT WE HAVE OBSERVED.............. 6 2. 1 IN GENERAL, ONDCP IS A
SOPHISTICATED ORGANIZATION OPERATING FROM A PROCESS
PERSPECTIVE.....................................................................................................................................................
6

2. 2 BUT THE INCREASING WORKLOAD AND INABILITY TO RETAIN PERSONNEL IS
SIGNIFICANTLY HINDERING
PERFORMANCE...........................................................................................
9

3.0 THE INSTITUTIONALIZATION OF ONDCP............ 13 3.1 AUTHORITY IS
CENTRALIZED AND THE LINES OF AUTHORITY ARE UNCLEAR.........................
13

3.1.1( a) Authority has been centralized in the Office of the
Director.......................................................... 13 3.1.1(
b) The chain of command can be
confusing.......................................................................................
15 3.1.1( c) The managerial role of the Deputy Director of ONDCP is
unclear............................................... 18 3.1.1( d) ONDCP
has had difficulty recruiting and retaining component Deputy
Directors....................... 19 3.1.1( e) What are other explanations
for the difficulty in recruiting and retaining component Deputy
Directors?.................................................................................................................................................
19

3.1.1( f) How would the presence of component Deputy Directors affect
ONDCP?................................... 21 3.1.1( g) Other Relevant
Business Practices – Senior Advisory Steering
Group......................................... 21 3.2 ONDCP'S TURNOVER HAS
BEEN VERY
HIGH........................................................................................
23 3.2.1 Turnover
Rates............................................................................................................................................
23

3.2.1( a) ONDCP Calendar Year 1998
Turnover.........................................................................................
24 3.2.1( b) ONDCP Calendar Year 1999
Turnover.........................................................................................
24 3. 2. 1( c) ONDCP Calendar Year 2000 Actual Turnover and Potential
Turnover Associated with the year 2000
Election...............................................................................................................................................
24

3.2.1( d) Reasons for
Turnover.....................................................................................................................
30 3.2.1( e) Human Resource Business
Practices..............................................................................................
34 3.2.1( f) Other Relevant Business Practices – Leadership
Style................................................................... 36

Management Review Office of National Drug Control Policy

ii 3.2.1( g) The Director's
Schedule.................................................................................................................
37

3. 3 FORMAL GUIDANCE TO GOVERN THE COMPONENTS AND OFFICES BEYOND THE CURRENT
DIRECTORSHIP WAS NOT
AVAILABLE..........................................................................................................
40

3.3.1 ONDCP- Specific written policies and procedures were not
available........................................................ 41 3.3.2
The Organization Charts provided are temporary and in conflict with each
other..................................... 41 3.3.3 Other Relevant Business
Practices – Policies and
Procedures....................................................................
42 3.4 SUMMARY OF HR AND ORGANIZATIONAL
ANALYSIS.......................................................................
42

4.0 BUDGETING, ACCOUNTING, AND FINANCIAL REPORTING SYSTEMS AND INTERNAL
CONTROLS..........................................................................................................
43

4.1 INTERNAL CONTROL
RISK..........................................................................................................................
43 4. 2 DISCRETIONARY AND NON- DISCRETIONARY FUNDING AVAILABLE TO THE
DIRECTOR AND ONDCP SENIOR
MANAGEMENT.......................................................................................................................
45

4. 3 THE IMPACT OF THE PROGRESSIVE INCREASE IN WORKLOAD AND OPERATIONAL
TEMPO WITHIN THE FINANCIAL MANAGEMENT
OFFICE........................................................................................
46

4. 4 POTENTIAL FOR IMPROVEMENT BY REENGINEERING WORKING PRACTICES AND
INTRODUCING NEW
TECHNOLOGY...............................................................................................................
47

4.4.1 Reengineering ways of
working....................................................................................................................
47 4.4.2 Investing in
technology.................................................................................................................................
47

APPENDICES.......... 49 Appendix A: ONDCP Employees
Interviewed...........................................................................................................
49 Appendix B: The External Organizations Researched and/ or Interviewed in
the Public and Private Sector............. 50 Appendix C: Three Original
Versions of ONDCP Organization
Charts................................................................. 51
Appendix D: Summary Analysis of ONDCP Internal Financial Control
Risk........................................................... 52 Appendix
E: U. S. Department of Justice Office of Legal Counsel – Memorandum
for Agency Counsels; General Guidance on the Federal Vacancies Reform Act of
1998...........................................................................................
55

Appendix F: ONDCP's Response Letter to a Preliminary Draft of the
Report.......................................................... 56 Appendix
G: Legislative
Citations..............................................................................................................................
57 Appendix H: ONDCP Mission Statements and Position
Descriptions.......................................................................
61 Appendix I: Excerpt from The Retired Officer Association (TROA) Magazine,
June 2000, Vol. LVI. No. 6, “Soldiering On: General Barry McCaffrey
Talks with Tom
Philpott”.......................................................................
62

Appendix J: Full Breakdown of the Director's
Schedule...........................................................................................
63

Management Review Office of National Drug Control Policy Page 1

EXECUTIVE SUMMARY

In consultation with Congress, the General Accounting Office (GAO) has
contracted with PricewaterhouseCoopers, L. L. P. to conduct a comprehensive
evaluation of the performance, efficiency, and effectiveness of the Office
of National Drug Control Policy (ONDCP). Referring to the contract Statement
of Work, GAO specifically requires an assessment of:

1. whether ONDCP performs its statutory and regulatory responsibilities in
an efficient, effective, and results- oriented manner; 2. whether ONDCP
optimizes human resources in fulfilling its primary objectives of policy,

anti- drug program coordination, and compliance; and 3. whether ONDCP's
internal control systems are strategically deployed to enhance business

processes throughout the organization. The primary outcome of this
assessment will appraise and identify opportunities for enhancing ONDCP's
effectiveness in executing its statutory responsibilities and its current
management structure's ability to achieve mission results. This will be
accomplished through improvements in human resource management,
organizational planning, management, and performance measures related to
operational planning and financial and human resource management.

OUR FINDINGS

1. With regard to whether ONDCP performs its statutory and regulatory
responsibilities in an efficient, effective, and results- oriented manner,
it is our opinion that ONDCP is results- oriented and effective in
performing its responsibilities externally, but inefficient with regard to
internal operations.

In general, the project team found that ONDCP has a clearly defined external
mission, associated goals, specific impact targets, and a performance
tracking method for Drug Control Program agency performance. In their most
recent publication of the 2000 Annual Report of the National Drug Control
Strategy, ONDCP reports that drug use in targeted impact areas has declined
and that attitudes against drug use have increased, according to Health and
Human Services (HHS) and other relevant data sources.

ONDCP lacks, however, the same set of goals, targets, and measurements
associated with its internal operations. The framework that has been
effectively used to develop goals, targets, and performance tracking for the
Drug Control Program agencies as a whole could be used to develop internal
metrics for how ONDCP achieves its unique objectives of policy,
coordination, and compliance. Documentation relevant to the internal
operations of the components and functional offices and performance of the
organization itself was not available. Recruitment and retention issues have
also been problematic for

Management Review Office of National Drug Control Policy Page 2

ONDCP, and the efficient continuity of the organization beyond the current
directorship is an issue.

The organization could become more effective and results- oriented
internally by addressing the following performance management issues:

? develop goals, objectives, and performance measures of effectiveness for
the internal processes and objectives of ONDCP. It would make good business
sense to establish internal performance measures for the organization's
primary objectives. 1

The organization could become more efficient and effective by addressing the
following human resource management issues:

? ensure that the Office of Administration is allocated sufficient Full-
Time Equivalents (FTE) commensurate with its size and workload in order to
address human resource and retention issues;

? institute a formal exit interview practice;

? take measures to address retention issues;

? target individuals with appropriate skill sets and compatible work ethics
during recruiting;

? manage the expectations of potential employees during the recruiting
process;

? institute career development practices within ONDCP for civilian
employees;

? provide training opportunities for civilians and ensure that opportunities
to apply the training are made available within the organization;

? evaluate the ONDCP- specific guideline regarding GS- 14 to GS- 15
promotion for its impact on the retention of GS- 14 career civilians; and

? evaluate the practice of filling supervisory GS- 15- equivalent positions
with military detailees for its impact on the promotion and retention of GS-
14 career civilians.

These initiatives should contribute significantly to improvements in
efficiency and effectiveness internally, with recruitment, retention, and
continuity being of primary importance.

2. With regard to whether ONDCP optimizes human resources in fulfilling its
primary objectives of policy, anti- drug program coordination, and
compliance, it is our opinion that human resources are not being optimized
toward accomplishing those objectives. We determined, however, that ONDCP's
inability to sustain support for the primary objectives is a result of
increases in the workload associated with new program requirements, the
Director's priorities, and ONDCP's inability to maintain its knowledge

1 In a response to a draft version of this report, ONDCP stated on page 9 of
its letter dated June 7, 2000 (see Appendix F) that the project team
“erred in asserting that ONDCP lacks internal targets and
measures.” ONDCP stated that it had provided a GPRA- compliant
Performance Report to OMB in calendar year 1999. The project team requested
a copy of the Performance Report but had not received it by the time this
report was released. The external Performance Measures of Effectiveness
(PME) documents are on ONDCP's website, but the above referenced Performance
Report is not available via the internet.

Management Review Office of National Drug Control Policy Page 3

base by retaining staff. The organization could make progress toward
optimizing human resources by addressing the following issues:

? address the human resource and retention issues previously discussed; and

? evaluate the pace of the Director's Schedule in consideration of its
impact on the operational tempo of ONDCP, the retention of employees and the
organization's capability to support its primary objectives of policy,
coordination, and compliance.

3. With regard to whether ONDCP's internal control systems are strategically
deployed to enhance business processes throughout the organization, it is
our opinion that there is an overall low to medium risk that the
organization is not adhering to sound and prudent internal financial
controls. There is, however, an area that should warrant further attention.
There is a potential internal control risk arising from inadequate matching
of increased responsibilities and workload with the required investment in
the financial management infrastructure. The significant implications of not
mitigating the risk of a breakdown in the management, supervisory, and
personnel internal controls are:

? a lack of quality assurance over work products due to time pressures;

? inappropriate levels of authority, delegation, and decision- making, given
underlying roles, responsibilities, and competencies; and

? a decline in customer service from the Financial Management Office (FMO).
We would classify this as a medium risk. Should the investment not be made,
however, the result would be increased exposure and a greater likelihood of
breakdown in this area of internal control.

Although it was not explicitly requested in the Statement of Work, the
project team evaluated the organization for continuity and
institutionalization beyond the tenure of the current Administration. As an
official of the United States Government, the Director of ONDCP is a steward
of the public trust. It is incumbent upon the Director, therefore, to
provide for the institutionalization and continuity of the organization
beyond his or her tenure. In the course of this evaluation, the project team
identified issues that raise concerns about the future continuity of ONDCP:
1) authority is centralized and a significant amount of institutional
knowledge resides with the current Director; 2) the knowledge base has been
eroded by recruitment and retention problems in recent years; 3) relative to
its size, an inordinate number of leadership and professional staff
positions (up to 38%) may be vulnerable in calendar year 2000; and 4) ONDCP-
specific written guidance addressing the activities within the components
and functional offices that would contribute to the continuity of the
organization appears to be largely absent.

Management Review Office of National Drug Control Policy Page 4

The organization could avoid continuity problems in the future by addressing
the following issues, in addition to those discussed previously:

? institute succession planning to ensure a smooth transition in the event
that the Director becomes incapacitated;

? clarify the authority, responsibility, and reporting structure with regard
to the Deputy Director and the Chief of Staff;

? address chain of command issues to be consistent with good organizational
management;

? fill the component Deputy Director positions; and

? develop written policy and procedures for component and functional office
activities to ensure continuity of the organization beyond the tenure of the
current Directorship.

In summary, we have observed that although the organization is generally
sophisticated, there is a shortage of investment and staff resources to
accomplish all of the activities and objectives imposed by Congress, the
Director, and the legislative charter. The shortage is equally attributable
to the increase in workload associated with new activities, supporting the
Director's priorities, and the inability of the organization to recruit and
retain qualified staff.

A draft version of this report was provided to ONDCP for comment prior to
the formal release of the document.

The ONDCP response letter is included in its entirety in Appendix F. Factual
corrections to text and clarifications were addressed in footnotes where
appropriate throughout the document.

Management Review Office of National Drug Control Policy Page 5

1.0 OUR APPROACH

The PricewaterhouseCoopers project team developed a high- level
understanding of the internal and external business processes at ONDCP. In
doing so, the team conducted approximately 25 structured interviews with key
personnel 2 and stakeholders, using a broad- based interview guide. The
guide was prepared after the team had extensively reviewed GAO reports,
Congressional hearings, ONDCP documents, and other reports. We also
conducted web- based research into departments and agencies relevant to the
drug control program processes. Based on this information, the team
developed a baseline of the existing internal and external processes and
structures within ONDCP.

Structured Interviews

Structured Interviews

Desktop- Based Research Desktop- Based

Research Business Practices

Study Business

Practices Study

Project- Based Knowledge Project- Based

Knowledge Gathered

Empirical Evidence Gathered

Empirical Evidence Created Baseline ONDCP Business

Process Chart Created Baseline

ONDCP Business Process Chart

Applied Public/ Private Sector

Practices Applied

Public/ Private Sector Practices

Identified Differences

Identified Differences

Second, we researched other business models in the private and public
sectors. Our goal was to identify organizations with similar characteristics
or business processes for comparison of practices. 3 The team researched and
benchmarked practices in both the federal, commercial, non- governmental,
and non- profit arenas. We interviewed representatives from relevant
external organizations such as America's Promise, Office of the United
States Trade Representative (USTR), the American Heart Association, and
others. With external interviews completed, we sketched and mapped other
business practices and structures based on our findings.

Third, we evaluated the current ONDCP structure and business practices
against other structures and practices in order to identify and address
differences. Our timeline for conducting the interviews and delivering the
final report is represented graphically below:

Developed Project Work Plan

April 22 , 2000 Completed Initial

ONDCP Interviews Completed Business Practice Interviews Delivered Assessment

Results June 15, 2000 April 15, 2000 March 1, 2000 Our Timeline

2 A list of ONDCP personnel interviewed is included in Appendix A. 3 A list
of organizations interviewed and researched during the business practices
review is included in Appendix B.

Management Review Office of National Drug Control Policy Page 6

2.0 WHAT WE HAVE OBSERVED

According to the FY98 reauthorization legislation, there is established in
the Executive Office of the President (EOP) an Office of National Drug
Control Policy, which shall –

? develop national drug control policy;

? coordinate and oversee the implementation of that national drug control
policy;

? assess and certify the adequacy of national drug control programs and the
budget for those programs; and

? evaluate the effectiveness of the national drug control programs. Its
primary objectives are policy, anti- drug program coordination, and
compliance. For the most part, the project team found that ONDCP is a
sophisticated organization. It has a clearly defined external mission and
associated goals that are highly visible on walls around the office. ONDCP
operates as a sophisticated organization in that it is structured in
components according to its business processes and coordination
responsibilities, rather than according to responsibilities by function
(personnel services, financial services, etc.). It is organized as directed
by the 1998 reauthorization legislation according to the following business
processes: Demand Reduction, Supply Reduction and Domestic Law Enforcement
(Bureau of State and Local Affairs). There is also a fourth main component
that handles the coordination of Drug Control Program agency programs,
budgets, and external performance metrics. 4 In addition, all of the
activities within the components and functional offices appear to be
congruent with their respective component or office mission and there
appears to be significant commitment from the leadership for activities and
initiatives.

In order to evaluate whether ONDCP is results- oriented and effective, the
project team assessed whether the organization has a clear and targeted
mission, a strategy, objectives, requirements, performance measurements, and
a method to assess performance. In order to determine whether ONDCP is
efficient, the project team assessed whether the organization has sufficient
capacity to meet its objectives and whether the resources have been deployed
appropriately.

External Mission

In terms of its external, mission- oriented performance, ONDCP has been
successful in developing goals, objectives, and performance impact targets
and in tracking progress against them. It has developed an annual National
Drug Control Strategy that discusses

4 The Counter- Drug Technology Assessment Center operates according to a
legislative charter with its own independent budget.

2.1 IN GENERAL, ONDCP IS A SOPHISTICATED ORGANIZATION OPERATING FROM A
PROCESS PERSPECTIVE.

Management Review Office of National Drug Control Policy Page 7

the overall goals of the Drug Control Program agencies over a ten- year time
period. The goals have been translated into objectives, which can be easily
mapped onto the business processes of the ONDCP organization. Moreover, the
goals are visible on walls throughout the office and all of the above
information is available via their website. In their most recent evaluation,
5 ONDCP reports that drug use in targeted impact areas has declined and that
attitudes against drug use have increased, according to Health and Human
Services (HHS) and other relevant data sources. An example of ONDCP's
performance measurements for certain operations, such as the High Intensity
Drug Trafficking Areas (HIDTA) program, is presented below: 6

Similar targets and performance measures are set for other ONDCP operational
programs such as the Media Campaign, Drug- Free Communities, and the
Counter- Drug Technology Assessment Center (CTAC).

5 2000 Annual Report on the National Drug Control Strategy 6 Excerpt taken
from 1998 – 2007 Performance Measures of Effectiveness

GOAL 2, OBJECTIVE 2: IMPROVE THE ABILITY OF HIDTAS TO COUNTER DRUG-
TRAFFICKING

TARGETS MEASURES 1. HIDTA Development -- Each HIDTA will 1. The percentage
of HIDTAs that meet or improve the scope and efficiency of the HIDTA exceed
the established milestones for the Program by the progressive adoption of
National HIDTA Developmental Standards the National HIDTA Developmental
Standards as developed and distributed in the 1998 at the rate of at least
10 percent per annum, HIDTA Program guidance. reaching the 90 percent level
by 2007. Reporting agencies: each HIDTA, Drug

Enforcement Agency (DEA), FBI. 2. Drug trafficking organizations in HIDTAs
-- 2. Proportion of identified drug trafficking By 2002, increase the
proportion of drug trafficking organizations disrupted or dismantled by or
organizations disrupted or dismantled as identified in within HIDTAs. HIDTA
threat assessments by 15 percent above the proportion in the 1997 base year.
By 2007, increase Reporting agencies: DEA, Defense, State the proportion
disrupted or dismantled to 30 percent FBI, U. S. Customs, Treasury. above
base year ratio.

3. Drug- related violent crime in HIDTAs -- By 2002, 3. Reported rate of
homicides, robberies, reduce by 20 percent the rate of drug related
homicides, rapes, and assaults in HIDTAs that are robberies, rapes, and
assaults in HIDTAs as compared to associated with distribution, sale, or the
1996 base year. By 2007 reduce specified drug- related consumption of
illicit drugs as measured crimes in HIDTAs by 40 percent. by available crime
indicators.

Reporting agencies: each HIDTA, DEA, Justice, FBI, Treasury.

Management Review Office of National Drug Control Policy Page 8

Internal Operations and Structure

While the staff members of ONDCP have been successful in measuring the
performance of external operations, they have not been as successful in
terms of monitoring internal, process- oriented performance measurements.
Documentation relevant to the internal performance of the organization was
not available, and there are no set performance measurements for internal
primary objectives. Although ONDCP has mission statements and position
descriptions dated May 1996, few policy or procedural documents regarding
the operations of the components or functional offices were available. 7
Those that were available were created at the initiative of individual
managers. Where basic ONDCP documentation does exist, it is not current. The
mission statement and position description document for the organization has
not been updated since May 1996 when the organization had approximately 40
persons on the payroll (although abbreviated mission descriptions for each
office dated 1998 are on the website). In addition, the organizational
charts that were provided in March 2000 were still “proposed,”
were inconsistent with each other, and did not reflect the reality of
current operations.

ONDCP does, however, operate within a sophisticated structure. In evaluating
management, an organizational analyst checks to see whether the organization
is structured to achieve the desired results. Most organizations have at
least two requirements. First, an organization will have an idea generation
or consensus building requirement. This is most effectively handled with a
team- based structure. Second, an organization will have a final decision
making and arbitration requirement, which is most effectively handled by a
streamlined chain of command structure. In evaluating ONDCP specifically,
the project team found that both the command structure and the consensus
building team structure with relevant activities exists within the
organization.

The project team also found that, according to the organizational charts,
each process component has a civilian leader at its head, rather than a team
or committee of leaders. It is important that final decision- making be
consolidated into one position so that an individual can be held
appropriately accountable for results.

A graphical representation of our understanding of the structure of ONDCP is
presented in Figure 1. The shaded areas represent components that execute
the core business processes of the organization. The non- shaded areas
represent the functional offices that support the Director and the core
components as needed. The boxes below each component office show how each of
the goals as outlined in the Strategic Plan lines up with a specific
process.

7 Policy, procedure, and guidance documents exist within the Office of
Administration regarding facilities and maintenance, security, contracts,
and other areas pertinent to office and facilities administration. Policy,
procedure and guidance documents regarding organizations within the
Executive Office of the President are available through the Office of Legal
Counsel.

Management Review Office of National Drug Control Policy Page 9

Figure 1: Our Understanding of the Current ONDCP Structure

D e p D ire c to r O f fic e o f

D e m a n d R e d u c tio n

D e p D ir e c to r B u r e a u o f S ta te

a n d L o c a l A f f a ir s D e p D ir e c to r

O f f ic e o f S u p p ly R e d u c tio n

D ir e c to r P r o g r a m s ,

B u d g e t a n d E v a lu a tio n D ir e c to r

C o u n te r -D r u g T e c h n o lo g y

A s s e s s C tr D ir e c to r O N D C P

C h ie f o f S ta ff O ff ic e o f L e g a l C o u n s e l

O ff ic e o f L e g is la tiv e A ff a ir s D e p u ty D ir e c to r

O ff ic e o f A d m in is tr a tio n F in a n c ia l M g m t O ff ic e

O ff ic e o f S tra te g ic P la n n in g O ff ic e o f P u b lic A f fa irs

M e d ia C a m p a ig n T re a tm e n t

P o lic y C o o r d in a tio n P r e v e n tio n

P o lic y C o o r d in a tio n D r u g F r e e C o m m u n itie s

D o m e s tic L a w E n f o r c e m e n t P o lic y C o o rd in a tio n

H ID T A I n te r d ic tio n G e o g ra p h ic A re a

G e o g ra p h ic A re a

E v a lu a tio n B u d g e t

P r o g r a m s

? Goal 1: Reduce drug use by young people.

? Goal 2: Target domestic sources of illegal drugs and crime associated with
criminal enterprises.

? Goal 3: Make treatment available to chronic users.

? Goal 4: Interdict the flow of drugs at our borders.

? Goal 5: Target international sources of illegal drugs and crime associated
with criminal enterprises.

Over the last four years, ONDCP has acquired or experienced an increase in
operational program activities to include the National Youth Anti- Drug
Media Campaign, the Drug Free Communities program, and the HIDTA program.
While it is logical to place new initiatives and growing programs under the
close purview of a strong and committed leader, the addition of operational
programs without an associated FTE allowance has added a dimension of
overload and complexity to the organization. Given that ONDCP's operational
programs call for individuals with a different set of skills, mindset, and

2.2 BUT THE INCREASING WORKLOAD AND INABILITY TO RETAIN PERSONNEL IS
SIGNIFICANTLY HINDERING PERFORMANCE.

Goal 1 Goal 3 Goal 2 Goal 4

Goal 5

Management Review Office of National Drug Control Policy Page 10

competencies than those required for coordination activities, ONDCP has
attempted to balance the mix of active, operational types with more passive,
consensus builders.

The chart in Figure 2 highlights the offices or components that are
conducting operational activities and have experienced a significant
increase in the scope of their operational requirements. Those increases
have resulted either from a redirection of effort based on the priorities of
the Director when he took over in 1996 or at the direction of Congress from
1997 to the present.

Figure 2: ONDCP Offices Conducting Operational Activities

D e p D ire c to r O ffic e o f

D e m a n d R e d u c tio n

D e p D ire c to r B u re a u o f S ta te

a n d L o c a l A ffa irs D e p D ire c to r

O ffic e o f S u p p ly R e d u c tio n

D ire c to r P ro g ra m s ,

B u d g e t a n d E v a lu a tio n D ire c to r

C o u n te r-D ru g T e c h n o lo g y

A s s e s s C tr D ire c to r O N D C P

C h ie f o f S ta ff O ffic e o f L e g a l C o u n s e l

O ffic e o f L e g is la t i v e A ffa i rs D e p u ty D ire c to r

O ffic e o f A d m in is tra t i o n F in a n c ia l M gm t O ffic e

O ffic e o f S tra te g ic P la n n in g O ffic e o f P u b lic A ffa irs

M e d ia C a m p a ig n T re a tm e n t

P o lic y C o o rd in a tio n P re v e n t i o n

P o lic y C o o rd in a tio n D ru g F re e C o m m u n i t ie s

D o m e s t i c L a w E n fo rc e m e n t P o l i c y C o o rd in a tio n

H ID T A In t e rd i c t i o n G e o g ra p h ic A re a

G e o g ra p h ic A re a

? High Intensity Drug Trafficking Areas (HIDTA) Program provides additional
Federal funds to areas within the United States which exhibit serious drug
trafficking problems and harmfully impact other areas of the country. Law
enforcement organizations within these areas assess drug trafficking
problems and design specific initiatives to reduce or eliminate the
production, manufacture, transportation, distribution, and chronic use of
illegal drugs and money laundering. Since 1990, 31 areas within the United
States have been designated as HIDTAs.

? National Youth Anti- Drug Media Campaign (Media Campaign) is an initiative
to encourage kids to stay drug- free. The Campaign targets youth ages 9
to18, especially vulnerable middle- school adolescents, their parents, and
other adults who influence the choices that young people make. To get the
word out across every economic and cultural boundary, the Campaign uses a
mix of modern communications techniques -from advertising and public
relations to interactive media -- and all possible venues -from television
programs to after- school activities -- to educate and empower young people
to reject illicit drugs.

Management Review Office of National Drug Control Policy Page 11

? Drug- Free Communities Grant Program is designed to strengthen
communitybased coalition efforts to reduce youth substance abuse. The
program enables these coalitions to enhance collaboration and coordination
in an effort to target the use of illegal drugs, as well as the underage use
of alcohol and tobacco. The program is administered by the Justice
Department's Office of Juvenile Justice and Delinquency Prevention (OJJDP)
with an interagency agreement with ONDCP. Through a competitive review
process, ONDCP and OJJDP select new grantees to receive awards of up to
$100,000 for a one- year period.

? Counter- Drug Technology Assessment Center (CTAC) is the central counter-
drug enforcement research and development organization of the U. S.
Government. It develops and implements the National Counter- Drug
Enforcement Research and Development Strategy, which identifies and defines
the scientific and technological needs of Federal, state, and local drug
enforcement agencies. CTAC is also responsible for conducting research and
development activities related to drug abuse, addiction, and rehabilitation.

? The Director's Schedule (Office of Strategic Planning and Office of Public
Affairs) is the calendar of events that documents the Director's
participation at all policy- related meetings, event appearances, speeches,
print interviews, television appearances, general office responsibilities,
personal appointments, and travel. In 1996, the Director structured ONDCP to
handle its primary objectives of policy, coordination, and compliance and to
coordinate his external appearance schedule. At the behest of the
Administration, the Director created an internal apparatus so that he could
use the “bully pulpit” to raise the awareness of the American
public to the dangers of drug use. 8 The project team estimated that the
Director's schedule requires the effort of up to 17 FTE 9 and draws on the
staff resources of the policy and coordination components.

8 On page 1 of ONDCP's response to a draft version of this document, ONDCP
indicated that the project team did not recognize “a major ONDCP
responsibility” of “policy articulation” which was defined
as “the important ONDCP mission of explaining policy to other
governments, elected officials at the federal, state, and local level,
opinion leaders, the private for- profit and non- profit sectors and the
public.”

ONDCP cited legislative citation 21 USC 1703, which outlines the 15
responsibilities of the Director, ONDCP (See Appendix G for full text of
legislation). Section (a) (11) states that the Director “may serve as
a spokesman for the Administration on drug issues.” Of the 15
responsibilities outlined in that section, 13 paragraphs direct that the
Director “shall” conduct functions whereas 2 paragraphs indicate
that the Director “may” conduct functions. Consequently, the
“shall” functions are probably of higher priority than the
“may” functions on the scale of a Director's responsibilities.
ONDCP also referenced 21 USC 1705, pertaining to the development and
submission of the National Drug Control Strategy (See Appendix G). Section
(a)( 3) states that the Director shall consult with, rather than
“explain to” (from the ONDCP text), heads of Drug Control
Program agencies, Congress, state and local officials, private citizens and
organizations with expertise and experience in demand and supply reduction
and appropriate representatives of foreign governments. The legislation does
not mandate the Director to explain drug control policy to “opinion
leaders” or to “the public.” 9 The 17 FTE estimated for
the Director's Schedule include 1 FTE from the Office of the Director, 5 FTE

from the Office of Strategic Planning, 7 FTE from the Office of Public
Affairs, ï¿½ FTE handling travel from the Office of Administration, ï¿½ FTE from
the Office of Legislative Affairs, and ï¿½ FTE from each of the four main
components. Component support was based on the formula that one hour in the
Director's Schedule requires approximately 8 hours of component staff
support, as estimated by ONDCP leadership.

Management Review Office of National Drug Control Policy Page 12

Over the past three years, the program and operational workload at ONDCP has
increased substantially with Congress creating or increasing requirements
associated with mandated programs. For example, the HIDTA program has grown
from 15 to 31 areas over the past four years. These operational programs
require a substantial number of FTE, leaving fewer to handle the primary
policy, coordination, and compliance responsibilities. The project team
isolated the number of existing FTE associated with each of the operational
programs and developed the following estimates:

Media Campaign 7 FTE from Demand Reduction Drug Free Communities 2 FTE from
Demand Reduction HIDTA 5 FTE from State and Local Affairs Director's
Schedule 17 FTE from various offices

We then backed out the number of existing FTE left to support the primary
objectives based on information from ONDCP organizational charts:

Office of Demand Reduction 16 FTE Bureau of State and Local Affairs 9 FTE
Office of Supply Reduction 24 FTE Programs, Budget and Evaluation 22 FTE

ONDCP employees indicated in the interviews that although policy,
coordination, and compliance activities do occur, staff members generally do
not have an appropriate amount of time to properly plan and execute
efficient and successful meetings. 10 This is particularly apparent in the
Bureau of State and Local Affairs which has 50% of the staff resources of
other components, but has a most challenging coordination objective of
encouraging private sector and local community initiatives. Staff resources
across ONDCP have been stretched thin, and the workload and operational
tempo of the organization is exceedingly high in all areas. In our opinion,
most of the offices within ONDCP operate in the face of the following trade-
off: either the policy, coordination, and compliance activities do not get
adequately planned for or the staff is burdened by the fast pace and
exceedingly long working hours. Many times, they operate under both
conditions.

In summary, we have observed that although the organization is sophisticated
and accomplished, there is a shortage of investment and staff resources
resulting in an inability to meet all of the objectives and priorities of
the Congress, the Director, and the

On page 10 of ONDCP's response, ONDCP states that “the conclusion that
20 FTEs support the Director's schedule is wrong.” The project team
has reviewed the activities of the Office of Strategic Planning and has
revised the number of FTE dedicated from that office to supporting the
Director's Schedule from 7 to 5 FTE. Upon revision, the total number
supporting the Director's Schedule should be 17 FTE. 10 On page 4 of ONDCP's
response, ONDCP indicated that “the failure to reflect our agency's
extensive

consensus building activities creates the erroneous impression that this
essential business practice is not followed by ONDCP.” The project
team agrees that the consensus building activities are extensive and
essential and we re- iterate the need for an appropriate allocation of time
for planning and executing efficient and successful consensus building
meetings.

Management Review Office of National Drug Control Policy Page 13

legislative charter. This inability can be attributed to the increase in
workload associated with supporting the Director's priorities, new
activities, and the inability of the organization to recruit and retain
qualified staff.

3.0 THE INSTITUTIONALIZATION OF ONDCP

In the course of this evaluation, the project team encountered issues that
raised concern about the future continuity of ONDCP, which will be discussed
throughout the remainder of this report. There were four main findings that
caused us to raise the issue of the adequate institutionalization of the
ONDCP organization: 1) authority is centralized and a significant amount of
institutional knowledge resides with the current Director; 2) turnover has
been high and the knowledge base has been eroded by recruitment and
retention problems in recent years; 3) relative to its size, an inordinate
number of leadership and professional staff positions, up to 38%, may be
vulnerable during calendar year 2000; 11 and 4) ONDCP- specific written
guidance regarding the operations of the components and functional offices
that would contribute to the continuity of the organization appears to be
largely absent.

3.1.1 (a) Authority has been centralized in the Office of the Director

While it is within the purview of the Director to consolidate and centralize
authority within ONDCP, it is an unusual business practice for
Presidentially- appointed and Senate- confirmed (PAS) Deputies to serve
without some measure of autonomy. In many organizations, it is common
practice that Deputy, Under, and Assistant Secretaries have some autonomous
authority and responsibility, subject to the advice and consent of the
Secretary or equivalent, for specific areas and objectives. 12

11 The 38% noted above equates to 59 FTE divided by the base number 154 FTE.
The 59 FTE include: 6 civilian employees and 6 military detailees who have
already turned over this calendar year as of April 2000, the 17 PAS and
Schedule C employees who are vulnerable in the 2000 election cycle, and the
30 military detailee positions whose retention is subject to the consent of
the next Director, ONDCP. On page 2 of the ONDCP response, ONDCP indicated
that “the report's discussion of a ‘vulnerability of leadership'
misses key aspects of the nature of federal executive leadership.” The
project team respects the breadth of expertise of the career professionals
who may continue to serve within ONDCP beyond the current Directorship. It
is our opinion, however, that the erosion of depth within the knowledge base
resulting from turnover in the past few years has placed ONDCP in a
relatively weak knowledge position. It is also our opinion that the
potential loss to the depth of the knowledge base during calendar year 2000
would not be adequately offset, from an efficiency perspective, by the
breadth of knowledge retained by the eight key professional staff employees
mentioned in the ONDCP response. 12 Source: Interview with Dr. Archie D.
Barrett, lead negotiator for the House of Representatives on the

Goldwater- Nichols Department of Defense Reorganization Act of 1986.

3.1 AUTHORITY IS CENTRALIZED AND THE LINES OF AUTHORITY ARE UNCLEAR

Management Review Office of National Drug Control Policy Page 14

PricewaterhouseCoopers requested the most recent mission and position
descriptions for each component, office, bureau and branch within ONDCP.
Careful reading of these documents indicates that the primary function of
the staff, from Deputy Director to policy analyst, is to assist and advise
the Director in carrying out the responsibilities and objectives required of
ONDCP (See Appendix H).

During the interviews with ONDCP staff, we confirmed that management
authority for all ONDCP responsibilities and objectives resides with the
Director and that he exercises direct oversight over, and decision- making
for, the vast majority of personnel actions and day- to- day activities. The
Director oversees the organization with the day- to- day assistance of the
Chief of Staff (See Figure 3). 13 The Deputy Director of ONDCP, a physician,
works primarily with the Office of Demand Reduction and conducts outreach
and coordination activities with members of the scientific and medical
communities.

Dep Director Office of

Demand Reduction

Director Programs, Budget and Evaluation Director

Counter- Drug Technology Assessment Ctr

PAS Position, Confirmed Career Civil Service Position

Figure 3: Organizational Structure Deputy Director Positions Not Confirmed
(Actual State of ONDCP 2000)

PAS Nominee, Unconfirmed Director

ONDCP PAS Position, Acting Civil Service

Dep Director Bureau of

State and Local Affairs

Dep Director Office of Supply Reduction Deputy

Director Chief of Staff Authority centralization at ONDCP is further
compounded by the fact that the Deputy Director positions have remained
largely vacant during the current Director's four- year tenure. As of May 1,
2000, the component Deputy Director positions have been vacant for 112 out
of a total of 153 months, a 73% vacancy rate. The Deputy Director for Demand
Reduction has never been filled during this Directorship and ONDCP
leadership does not expect any of the vacancies to be filled during the
remaining months of the current Administration.

13 On page 5 of the ONDCP response, ONDCP indicated that because the
Director's Schedule shows that the Director spends only 8% of his time on
internal matters, he is not the internal manager of the organization. Our
interviews indicated that according to the views of the majority of ONDCP
staff members, the Director, with assistance from the Chief of Staff, has
significant direct oversight of internal matters. It is our opinion that
internal matters as a whole are not being adequately attended to (i. e., the
hours represented by the 8% may also represent a large part of the total
time spent handling internal matters). This assertion would be supported by
the fact that many of the project team's human resource suggestions have
been endorsed by ONDCP.

Management Review Office of National Drug Control Policy Page 15

The implication associated with the above findings is that, as a result of
the consolidation of authority, a significant amount of institutional
knowledge resides with the current Director. Unless that knowledge is
transferred to documentation and managed within the organization, the
Director will take that knowledge out of the organization when he concludes
his term.

3.1.1 (b) The chain of command can be confusing 14 In reviewing the current
ONDCP organization and comparing it with the FY98 legislation, we found that
the structure that has been implemented is a modified version of the
structure as described in the FY98 legislation. 15 The implemented structure
is generally inconsistent with accepted practices of good organizational
management. Management science identifies important practices in order to
ensure clarity, consistency, and continuity of management operations
regardless of changing variables, conditions or personalities.
Organizational design emphasizes those management principles that favor
clarity with regard to authority, responsibility, accountability, and
capacity for duties and functions performed by individuals.

Other Business Practices- Roles and Lines of Authority

During the course of our research, we found that the leadership of the other
federal departments and organizations tends to operate within a structure
illustrated in the graphic image in Figure 4. The Secretary or equivalent
focuses “upwards and outwards” in line with negotiating policy,
maintaining a public image, or delivering a specific message.

Secretary Under Secretary (or equivalent)

Under Secretary (or equivalent)

Under Secretary (or equivalent)

PAS Position, Confirmed Career Civil Service Position

Figure 4: Standard Structure

Federal Business Practices Deputy Secretary (or equivalent) External

Internal 14 This heading was clarified in response to ONDCP's comment (page
4) regarding the clarity of this section. 15 The Constitution gives the
Congress the authority and responsibility to organize the Executive Branch,

including the Departments and Officers thereof. United States Constitution-
Article 1, Section 8, Clause 18.

Management Review Office of National Drug Control Policy Page 16

In order to handle the external schedule, to keep the organization operating
effectively, and to maintain an appropriate chain of command, the Secretary
or equivalent has a designated PAS position or equivalent as the
“internal manager” responsible for the dayto- day decision
making on operational issues. Several organizations such as the Department
of Health and Human Services (HHS), the Department of Agriculture, and the
Department of Defense (DoD) have this management structure in place (See
related textbox to follow). Table 1 below outlines the organizations we
spoke with, the leadership positions, and their respective roles:

Table 1: Organizations Researched for Leadership Characteristics
Organization Internal Manager External Manager

Department of Health and Human Services Deputy Secretary Secretary
Department of Agriculture Deputy Secretary Secretary Bureau of Alcohol,
Tobacco, and Firearms Deputy Director Director Department of Defense Deputy
Secretary Secretary UK Anti- Drug Coordinator Unit Director Coordinator
Office of National Drug Control Policy Director Director

Leading the Department of Health and Human Services: A Conversation with
Secretary Donna Shalala and Deputy Secretary Kevin Thurm

The Deputy Secretary of HHS, Kevin Thurm explained his roles and
responsibilities this way: “In doing the job that I have now, I had
the great advantage of having served as the chief of staff of the
department. First, the Deputy Secretary must be in line with what the
Secretary wants in that role. While there are some standard things that
Deputy Secretaries do, it becomes pretty clear that the position is to fill
the role the Secretary wants. The two of you must be able to communicate
effectively with each other about what the role is.

Second, as I think is the case in most departments, the Deputy Secretary is
the chief operating officer and is essentially in charge of day- to- day
decision making on management issues. The job is also to work closely on
policy issues through the Department and to work closely with the chief of
staff and executive secretary on these issues. My colleagues and I decide
when these policy issues need to come to the Secretary's attention.

Third, based on the priorities that have been identified by the President,
Vice President, and the Secretary, the Deputy Secretary has to make sure
these priorities are focused on and develop processes for making sure that
progress happens. I also run quarterly meetings on the Secretary's
initiatives that cross- cut the department.

Finally, I want to stress that continuity matters and Secretary's Shalala's
staying power has mattered a lot in the effective management of the
department. The Secretary has recruited excellent people and insisted that
we work together and that there would be consequences for people who didn't
play by the rules. This is really important, and I think that my colleagues
within the department have really stepped up to the tone set by the
Secretary's leadership. ”

PwC Endowment for the Business of Government Seminar, Fall 1999.

Management Review Office of National Drug Control Policy Page 17

Based on our interviews at ONDCP, we determined that the current
implementation is inconsistent with other federal business practices. The
Chief of Staff, rather than the Deputy Director of ONDCP, serves as the
chief operating officer of ONDCP (See Figure 6). The Chief of Staff has been
inserted into the chain of command as a conduit between the Director and the
component Deputy Directors and has oversight responsibility for the

Director ONDCP

DepDirector Office of

Demand Reduction

Dep Director Bureau of State

and Local Affairs

DepDirector Office of

Supply Reduction

Director Programs,

Budget and Evaluation Director

Counter- Drug Technology

AssessCtr PAS Position, Confirmed Career Civil Service Position

Figure 5: Standard Organizational Structure

Deputy Director

DepDirector Office of

Demand Reduction

Dep Director Bureau of State

and Local Affairs

Dep Director Office of

Supply Reduction

Director Programs,

Budget and Evaluation Director

Counter- Drug Technology

AssessCtr PAS Position, Confirmed Career Civil Service Position

Figure 6: Current Implementation of the ONDCP Structure

Director ONDCP

Chief of Staff Deputy

Director rest of the staff members. The Chief of Staff is operating in that
position at the behest of the Director and serves as the day- to- day
internal officer of the organization. During interviews, several ONDCP staff
members responded affirmatively to a direct inquiry regarding whether they
perceived that the Chief of Staff exercised significant influence over the
confirmed Deputy Directors.

With the existing ONDCP structure, as in Figure 6, the chain of command down
from the Director is divided and, as a result, can become complicated and
confusing. In 1998, for example, ONDCP had two confirmed component Deputy
Directors reporting through the Chief of Staff, an SES position, to the
Director (see Figure 7). The organization also had

Dep Director Office of

Demand Reduction

Dep Director Bureau of State & Local Affairs

Dep Director Office of Supply Reduction

Director Programs, Budget and Evaluation Deputy

Director Director

Counter- Drug Technology Assessment Ctr

PAS Position, Confirmed Career Civil Service Position

Figure 7: Organizational Structure

with Two PAS Positions Confirmed (Actual State of ONDCP 1998)

PAS Nominee, Unconfirmed Chief

of Staff Director

ONDCP PAS Position, Acting Civil Service

Management Review Office of National Drug Control Policy Page 18

an unconfirmed Deputy Director of ONDCP. Under this scenario, it was
confusing to other agency counterparts, and to ONDCP employees, as to who
officially could represent and negotiate on behalf of the organization: the
unconfirmed Deputy Director, the confirmed component Deputy Directors, or
the Chief of Staff.

3. 1. 1 (c) The managerial role of the Deputy Director of ONDCP is unclear

We were unable to clearly determine the managerial role of the Deputy
Director of ONDCP. 16 The ONDCP mission and position descriptions have not
been updated since May 1996 and do not address the PAS Deputy Director of
ONDCP position. It has been an evolving role for the current acting
occupant, a physician, as his management skills and knowledge base have
developed. 17 We understand that the Deputy Director serves as the external
intermediary with the medical community on demand reduction- related issues
and has been assigned special projects where his medical expertise and skill
set are required. We also understand that lately he has taken on more of an
intermediary role between the Office of Demand Reduction and the Director.
18 (The Deputy Director has significantly fewer interactions with the Bureau
of State and Local Affairs and the Office of Supply Reduction.) ONDCP has
compensated for the absence of a Deputy Director for Demand Reduction by
having the Deputy Director of ONDCP take on some of the demand reduction-
related activities.

The absence of a clearly defined managerial role and area of responsibility
for the Deputy Director of ONDCP has contributed to the confusing chain of
command that exists today. Because the Acting Deputy Director of ONDCP is on
detail from the National Institute of Health and not confirmed, it is
unclear who would take over the current Director's authority were he to
become incapacitated. Succession is not clear, which does not bode well for
the institutionalization or continuity of the organization.

16 On page 6 of the ONDCP response, ONDCP indicates that the statement
“that the Deputy Director position lacks ‘a clearly defined role
and area of responsibility' is not borne out.” In the response,
however, ONDCP does not clearly define a managerial role or area of
responsibility for the Deputy Director of ONDCP. ONDCP states that the
Deputy Director's role is to fill the role the Director wants and to work
closely on issues with the Chief of Staff, executive secretary and with
others throughout ONDCP (consistent with the text box description of the
Deputy Secretary's role at HHS). The HHS text box goes on in the following
paragraph, however, to quote the Deputy Secretary of HHS explaining his role
more explicitly as the chief operating officer of the organization: “
as I think is the case in most departments, the Deputy Secretary is the
chief operating officer and is essentially in charge of day- to- day
decision making on management issues.” 17 On page 5 of the ONDCP
response, ONDCP states that “this statement does not accurately
reflect the

history and role of the Deputy Director.” The original text is based
on information gathered in interviews conducted during the course of the
review. 18 On page 6 of the ONDCP response, ONDCP indicated that the Deputy
Director of ONDCP has not been

delegated an intermediary oversight role between the Office of Demand
Reduction and the Director. The project team acknowledges the contradiction.
The project team has rephrased this sentence to more accurately reflect what
was conveyed to us during our interviews.

Management Review Office of National Drug Control Policy Page 19

The organization could avoid continuity problems in the future by addressing
the following issues:

? institute succession planning to ensure a smooth transition in the event
that the Director becomes incapacitated;

? clarify the authority, responsibility and reporting structure with regard
to the Deputy Director and the Chief of Staff;

? address chain of command issues so as to be consistent with good
organizational management; and

? fill the component Deputy Director positions.

3. 1. 1 (d) ONDCP has had difficulty recruiting and retaining component
Deputy Directors

ONDCP has been less than effective at recruiting and retaining individuals
in the component Deputy Directorships. In order to understand why, the
project team attempted to identify possible disincentives for individuals in
those positions.

3.1.1 (e) What are the explanations for the difficulty in recruiting and
retaining component Deputy Directors?

During interviews, ONDCP leadership suggested that there were two reasons
why the PAS positions remained vacant for extended periods. First, Congress
had not acted to confirm the PAS position nominees that had been put forth.
Second, physicians were unlikely to serve in policy- making positions, as
suggested in the FY98 legislation for the Deputy Director for Demand
Reduction, for compensation reasons.

We gathered information on confirmation statistics from other relevant
sources in an effort to verify these reasons. We researched previous ONDCP
Directorships to see if it had been particularly difficult as a rule to
recruit and retain within ONDCP. If previous Directors had had difficulty
filling positions, then we could establish that there may be something
inherent in the nature of the mission or the organization that tends to
affect recruitment and retention of Deputy Directors.

Management Review Office of National Drug Control Policy Page 20

Table 2: ONDCP History of Filled Deputy Director Positions Director Number
of component Deputy PAS

positions Number of filled PAS positions Time Frame Filled at End of

Term

Bennett Three Three 2 years Three Martinez Three Two 2 years Two Brown Three
Two 2 years Two McCaffrey Three Two 4 years Zero* * Projected

Since previous Directors were able to recruit and retain component Deputy
Directors and since the mission and fundamental structure of the
organization has remained constant, we concluded that it is improbable that
there is something inherent in the nature of ONDCP that is causing problems
in this area.

We also researched the current Office of the United States Trade
Representative (USTR) to see if an EOP agency of similar size has had
trouble getting PAS positions confirmed with the current political
constitution of the Executive and Legislative branches. If the USTR was also
found to have had difficulty confirming PAS nominees, we could establish
that the inherently political nature of the confirmation process, with the
Executive and Legislative branches headed by different political parties,
could have contributed to the inability of ONDCP to confirm PAS nominees.
Our interviews with USTR indicated that they have not had the same
difficulty confirming PAS nominees. USTR has all three of their PAS deputy
positions confirmed and currently filled.

Table 3: USTR Filled PAS Positions Organization Number of component

Deputy PAS positions Number of filled PAS positions Currently Filled

Office of U. S. Trade Representative (USTR) Three Three Three Finally, we
researched other health- related organizations to see if it has been
difficult to attract and retain physicians in policy- oriented positions. If
other health- related organizations have had difficulty recruiting
physicians for PAS and/ or policy- making positions, then we could establish
that physicians as a whole are unlikely to be attracted to policy- oriented
positions.

Table 4: Health Organizations with PAS Positions Organization Number of
component

Deputy PAS positions Number of filled PAS positions Currently Filled

Food and Drug Administration (FDA) Four Three Three US Surgeon General At
Least Two At Least Two At Least Two

Our research indicated that physicians have been confirmed in the Office of
the U. S. Surgeon General and the Food and Drug Administration. These
medical physicians provide scientific and medically- based health policy
analysis. Many of the other organizations we researched and interviewed,
such as the American Heart Association,

Management Review Office of National Drug Control Policy Page 21

rely on medical and scientific experts when making policy decisions. The
following chart presents a list of policy organizations and how they employ
medical physicians.

Table 5: Health and Policy Organizations with Medical Physicians
Organization Medical Physicians

U. S. Surgeon General Employs medical physicians throughout the organization

Department of Health and Human Services 33% (20,345 medical physicians in a
61, 654 employee organization)

Food and Drug Administration Agency 3.3% (300 medical physicians in a 9,000
employee organization)

American Heart Association The majority of the organization consists of
medical physicians in policy and upper level positions

Office of National Drug Control Policy Employs one medical physician In sum,
we were unable to verify ONDCP's explanations for the absence of confirmed
Deputy Directors. Information gathered from interviews indicated that the
lack of autonomy and confusing chain of command issues may have contributed.

3.1.1 (f) How would the presence of component Deputy Directors affect ONDCP?

The project team considered how the presence of Deputy Directors would
impact ONDCP. Acting Deputy Directors serve at the pleasure of the Director,
but confirmed Deputy Directors can only be dismissed by the President or
impeached by Congress. Consequently, the authorities of confirmed Deputy
Directors would serve as “checks and balances” with regard to
the authority of the Director. With official representatives acting on
behalf of the organization and accountable to Congress and to the President,
the Director would probably have to engage in more consensus building
activities and more debate in order to get “buy- in” for his or
her objectives. This would also help to ensure that the message being
delivered by ONDCP was the fully discussed message representing the fully
vetted opinion of the Drug Control Program community.

The existence of confirmed Deputy Directors would also offset the
centralization of the knowledge base. With several confirmed Deputies
working toward the objectives of the organization, the
“portfolio” of procedural and historical knowledge of the
organization would be diversified among several individuals and there would
be less risk to the overall continuity and long- term benefit of the
organization.

3.1.1 (g) Other Relevant Business Practices – Senior Advisory Steering
Group

We researched and interviewed individuals at other organizations that are
involved in a social mission in order to gain insights as to how they
conduct their operations. Most had some type of established senior advisory
steering group to assist in policy formulation

Management Review Office of National Drug Control Policy Page 22

and implementation. 19 This type of forum provides for teaming and consensus
building, which is important when developing policy so that all areas of
expertise and knowledge are considered. Although ONDCP relies heavily on
advisory groups for policy development at the senior management level, the
project team did not find evidence of a senior advisory steering group that
regularly meets with the Director. Examples of this senior advisory steering
group function exist in the American Heart Association, American Medical
Association, Food and Drug Administration, America's Promise, and the United
Kingdom Anti- Drug Coordinator Unit. These groups generally consist of a
committee of CEO/ Director level peers from other government agencies, area
experts and professionals, process managers, and other interested
stakeholders. The senior advisory steering group meets according to a set
schedule in order to conduct professional debate on issues. Once a consensus
is developed, the designated Director or CEO makes a final decision. The
diagram in Figure 8 illustrates the characteristics of the senior advisory
steering group and the persons involved in the process.

Figure 8: Typical Advisory Steering Group

CEO/ Director Vice President/ Deputy Director

Process Manager/ Vice

President Process

Manager/ Vice President

Process Manager/ Vice

President Advisory Steering

Group

Government agency reps Area experts and professionals Process managers/ Vice
Presidents

Other interested stakeholders Meeting regularly

One specific example of this advisory group function is implemented at the
United Kingdom Anti- Drug Coordinator Unit, where a Strategic Steering Group
meets regularly to help the Coordinator assess overall progress in
implementing the strategy. This group includes senior officials from within
the government, individuals from independent bodies, professional drug
agencies, local governments, businesses, and Drug Action Teams. By working
through policy issues with an advisory group, the organization maximizes its
chances of obtaining a fully vetted and consensus- based policy.

19 In a response to a draft version of this report, ONDCP indicated that
“the report does not reflect ONDCP's reliance on policy advisory
groups.” The project team acknowledges that ONDCP has several advisory
groups with which it consults on various issues. The example discussed in
this section pertains to an established senior policy advisory group or
steering committee that would meet regularly to consult with and to advise
the Director, ONDCP on the overall priorities and strategies committed to by
ONDCP.

Management Review Office of National Drug Control Policy Page 23

ONDCP has experienced high turnover during the current directorship. Our
review has revealed several situations that have characterized the current
Director's tenure. First, ONDCP has not been able to meet its 154 FTE
ceiling (124 FTE + 30 military detailee positions). 20 Second, the agency
has been unsuccessful in hiring and retaining staff resources. And third,
Congress has not supported requests for additional FTE funding. As a result,
ONDCP has performed its duties with a number of unfilled positions,
vacancies, and high turnover. In our opinion, the Director's leadership
style, the heavy workload associated with increasing program area
responsibilities, the lack of an adequate number of personnel to handle
ONDCP's responsibilities, and the lack of attention to human resource
practices has resulted in personnel turnover. ONDCP's aggregate and yearly
turnover statistics are presented in the sections that follow.

3.2.1 Turnover Rates

Table 6: ONDCP Civilian Turnover Aggregate Statistics ONDCP Civilian
Turnover Statistics Aggregate Results

104 of 154 positions 68% turnover 2 of 5 authorized PAS positions, 40%
turnover 11 of 15 authorized Career SES and Non- Career SES positions 73%
turnover 61 of 104 authorized Career Status, Schedule A's and Schedule C's
59% turnover

Table 7: ONDCP Military Turnover Aggregate Statistics ONDCP Military
Turnover Statistics Aggregate Results

30 of 30 authorized military detailee positions (as per DoD arrangement)
100% turnover Using ONDCP personnel data and internal organizational charts,
our project team determined the effects on the agency of the actual turnover
from calendar year 1998 to the present and of the potential calendar year
2000 turnover. The turnover has occurred in both civilian and military
detailee positions of significant influence. As a result, the actual
turnover that ONDCP has experienced from 1998 to 1999 combined with this
year's potential turnover from the 2000 election raises the issue of the
knowledge base and knowledge retention in light of the coming period of
transition.

20 The project team included the 30 military detailees in our analysis
because these individuals are in positions of significant influence and
authority and their recruitment and retention has a direct impact on the
knowledge base and continuity of the organization. They perform duties and
functions essential to the operations of ONDCP. Most of the military
detailees are colonel and lieutenant colonel level and are nestled within
the leadership of many of the components and offices.

3. 2 ONDCP'S TURNOVER HAS BEEN VERY HIGH

Management Review Office of National Drug Control Policy Page 24

3. 2. 1 (a) ONDCP Calendar Year 1998 Turnover 22 civilian and 10 military
detailee positions turned over in calendar year 1998. Based on the number of
authorized 154 positions, ONDCP experienced a turnover rate of 21%. ONDCP
did not meet its authorized FTE ceiling in 1998.

Table 8: 1998 Turnover Positions Component Office Turnover Positions Total
Office Positions 21 Turnover Rate

Public Affairs Office 5 7 71% Office of Legislative Affairs 4 6 67% Office
of Programs, Budget, Research & Evaluation 7 23 30%

3. 2. 1 (b) ONDCP Calendar Year 1999 Turnover 31 civilian and 10 military
detailee positions turned over in calendar year 1999. Based on the number of
authorized 154 positions, ONDCP experienced a turnover rate of 27%. Still,
ONDCP did not meet its authorized FTE ceiling in 1999. The areas of overall
high impact in 1999 included the following:

Table 9: 1999 Turnover Positions Component Office Turnover Positions Total
Office Positions 22 Turnover Rate

Director's Office 5 7 71%

Office of Legislative Affairs 4 6 67%

Public Affairs Office 4 7 57%

Office of Legal Counsel 4 7 57%

Office of Programs, Budget, Research & Evaluation 9 23 39%

Office of Supply Reduction 9 23 36% 3. 2. 1 (c) ONDCP Calendar Year 2000
Actual Turnover and Potential Turnover Associated with the 2000 Election

As of April 20, 2000, 6 civilian and 6 military detailee positions turned
over in this calendar year. In addition, 17 filled political positions are
vulnerable in this year's election. Political positions that are vulnerable
in a change of administration include all Presidential Appointee Schedules
(PAS), Non- Career Senior Executive Service (NC SES), and Schedule C's (SC).

21 The total number of component office positions was determined from
ONDCP's organizational chart dated 3/ 3/ 2000. If the number of component
office positions changed in this year, the overall turnover rates could be
adjusted. 22 Ibid.

Management Review Office of National Drug Control Policy Page 25

With a change of administration, ONDCP's next director could decide to
eliminate the 30 authorized military detailee positions. Thus, 30 filled
military detailee positions 23 may be vulnerable in the coming election year
as well. Because the military detailees are in positions of significant
influence, their loss would be detrimental to the organization's knowledge
base. Based on the ceiling of 154 authorized FTE, ONDCP could potentially
experience a combined (actual and potential) turnover rate of 38% in this
calendar year. As of April 20, 2000, ONDCP had not met its authorized FTE
ceiling.

The areas of potentially high impact (combined actual and potential turnover
based on 154 FTE capacity) are graphically presented below:

Figure 9: ONDCP Actual and Potential Turnover for Calendar Year 2000
Percentage Impact on Component Offices, 24 Based on 154 FTE Full Capacity

21- 100% Potential Component/ Office Turnover

0- 20% Potential Component/ Office Turnover On the next several pages, we
have provided charts that show which positions turned over in calendar years
1998 and 1999, and the actual and potential turnover for calendar year 2000.
The summary chart of the 1999 and 2000 data demonstrates that the knowledge
bases for most of the offices within ONDCP have been seriously weakened or
are vulnerable with the coming election.

23 The total number of component office positions was based on ONDCP's
organizational chart dated 3/ 3/ 2000. If the number of component office
positions changed in this year, the overall turnover rates could be
adjusted. 24 Ibid.

Director 86%

Chief of Staff 100%

Office of Strategic Planning 63%

Deputy Director 100%

Public Affairs Office 43%

Office of Administration 44%

Counter- Drug Technology Assessment Center

0% Office of

Demand Reduction 23%

Bureau of State and Local Affairs

13% Office of

Supply Reduction 52%

Office of Programs, Budget, Research, &

Evaluation 30% Executive

Secretariat 0%

FInancial Management Office

0% Office of Legal Counsel

17% Office of Legislative Affairs

17% % %

Management Review Office of National Drug Control Policy Page 26

CHIEF OF STAFF OFFICE Chief of Staff, SES- 6 Exec. Assistant, GS- 12 Deputy
Chief of Staff, ES- 3

Staff Assistant, GS- 7 Staff Assistant, GS- 9

STRATEGIC PLANNING Director, SES- 1 Assistant Director, GS- 15

Secretary, GS- 9 Events Assistant, PMI GS- 9

Strategic Planner, LTC Deputy Events Manager, GS- 12

Strategic Planner, GS- 13 Research Assistant, GS- 4 LEGAL COUNSEL

General Counsel, SES- 3 Secretary, GS- 9 Deputy Counsel, GS- 15 Asst. Gen
Counsel, COL Associate Counsel, GS- 14

Attorney- Advisor, GS- 14 Attorney- Advisor, GS- 14

DIRECTOR'S OFFICE Director, PAS Personal Secretary, GS- 7 Executive
Assistant, COL Asst. Exec. Assistant, LTC

Special Assistant, GS- 12 Speech Writer, GS- 14 Staff Assistant, GS- 7

Scheduler, GS- 7 LEGISLATIVE AFFAIRS

Director, SES- 1 Director, SES- 1 Secretary, GS- 9 Assistant Director, GS-
15 Legislative Analyst - OSR, GS- 14 Legislative Analyst - ODR, GS- 14

Admin. Support Asst., GS- 8 PUBLIC AFFAIRS

Director, SES- 1 Assistant Director, COL Chief, Press Relations, GS- 15
Public Affairs Specialist, GS- 14 Public Affairs Specialist, GS- 11 Public
Affairs Specialist, GS- 9

Secretary, GS- 9 Admin. Assistant, GS- 7 Press Relations Assistant, GS- 5
DEPUTY DIRECTOR'S OFFICE Deputy Director, SES- 6

Policy Advisor, GS- 13 Confidential Secretary, GS- 10

EXECUTIVE SECRETARIAT Correspondence Manager, GS- 12 Correspondence
Specialist, GS- 10

Correspondence Assistant, GS- 6 ADMINISTRATION

Director, GS- 15 Travel Management Spec., GS- 9

Support Services Asst., GS- 7 Secretary, GS- 6

COMMUNICATIONS Asst. for Info Sys, LTC

SUPPORT SERVICES Assistant for Support, GS- 14

Support Specialist, GS- 11 PERSONNEL Assistant for Personnel, GS- 13

Special Assistant, LTC Personnel Specialist, GS- 11

TECHNOLOGY Director, SES- 5 Secretary, GS- 9 Program Analyst, GS- 15 Program
Engineer, GS- 14 FINANCIAL MANAGEMENT

Director, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 13 Budget
Analyst, GS- 13 Budget Analyst, GS- 13 Budget Analyst, GS- 11/ 12/ 13
Financial Support Spec., GS- 11

DEMAND REDUCTION Deputy Director, PAS EX- III

Secretary, GS- 9 Asst. Deputy Director, SES- 2

Staff Director, COL Grants Administrator, GS- 15 Senior Policy Analyst, GS-
15 Program Supt. Spec., GS- 12

EDUCATION Senior Advisor and Chief, SES- 3

Bus/ Med/ Ent. Analyst, GS- 14 Mgmt & Contracts Spec., GS- 14

Management Analyst, GS- 13 Special Assistant, GS- 13 Policy Analyst, PMI GS-
9 Admin Supt. Asst., GS- 8

PREVENTION Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst, PMI
GS- 9

Policy Analyst, GS- 14 TREATMENT Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, GS- 15 Cocaine Analyst, LTC

SPECIFIC DRUGS Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst,
GS- 14

Heroin Analyst, LTC STATE & LOCAL

Deputy Director, PAS EX- III Secretary, GS- 9 Asst. Deputy Director, SES- 1

Staff Director, COL JUSTICE & LAW ENFORCEMENT

Branch Chief, GS- 15 Law Enforcement Analyst, LTC

Policy Analyst, PMI GS- 9 HIDTA Director, GS- 15 Policy Analyst, GS- 14
Policy Analyst, GS- 14 Policy Analyst, GS- 13

Secretary, GS- 8 REGIONS Branch Chief, GS- 15 South West/ Border Analyst,
GS- 14

Policy Analyst - East, GS- 14 SUPPLY REDUCTION

Deputy Director, PAS EX- III Secretary, GS- 9 Asst. Deputy Director, SES- 1

Staff Director, CDR Advisor, COL Staff Assistant, GS- 7

SOURCE COUNTRY SUPPORT Branch Chief, GS- 15 Program Supt. Spec., GS- 12

Colombia Analyst, GS- 14 Mexico Analyst, GS- 13 Mexico Analyst, PMI GS- 9

Policy Analyst, GS- 9 SWA/ Africa/ Europe Analyst, GS- 14

Peru/ Bolivia Analyst, GS- 14 Burma/ Thai/ SEA Analyst, LTC

PRODUCTION & TRAFFICKING Branch Chief, GS- 15 Int'l Law Enf. Analyst, GS- 14

Policy Analyst, LTC Policy Analyst, CDR Policy Analyst, LTC Policy Analyst,
MAJ

INTELLIGENCE Director, SES- 3 Intel Research Analyst, GS- 14

Intel Sharing Analyst, LTC Intel Sharing Analyst, LTC

Researcher, CPT PROGRAMS, BUDGET,

RESEARCH, & EVALUATION Director, SES Secretary, GS- 7 Assistant Director,
SES- 1

Economist, GS- 9 Policy Analyst, GS- 9

PROGRAMS Branch Chief, GS- 15 Drug Policy Analyst, GS- 14

Demographer, GS- 14 Policy Analyst, GS- 14 Data/ Survey Analyst, GS- 15
Policy Analyst - Int'l Supply, LT Policy Analyst - Demand, CDR

BUDGET Branch Chief, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 14
Budget Analyst, GS- 14 Budget Analyst, GS- 12

Budget Analyst, LTC EVALUATION Branch Chief, GS- 15 Policy Analyst, GS- 14

Policy Analyst, LTC Policy Analyst, LTC Policy Analyst, MAJ

ONDCP CALENDAR YEAR 1998 TURNOVER

Turnover positions are presented in red text. 1998 Turnover

22 civilians 10 military detailees

21% turnover rate

Management Review Office of National Drug Control Policy Page 27

ONDCP CALENDAR YEAR 1999 TURNOVER

Turnover positions are presented in red text.

SOURCE COUNTRY SUPPORT Branch Chief, GS- 15 Program Supt. Spec., GS- 12

Colombia Analyst, GS- 14 Mexico Analyst, GS- 14

Mexico Analyst, LTC Mexico Analyst, PMI GS- 9 SWA/ Africa/ Europe Analyst,
GS- 14

Peru/ Bolivia Analyst, GS- 14 Burma/ Thai/ SEA Analyst, LTC

PRODUCTION & TRAFFICKING Branch Chief, GS- 15 Int'l Law Enf. Analyst, GS- 13

Policy Analyst, LTC Policy Analyst, CDR Policy Analyst, LTC Policy Analyst,
MAJ

INTELLIGENCE Director, SES- 3 Intel Research Analyst, GS- 14

Intel Sharing Analyst, LTC Intel Sharing Analyst, LTC

Researcher, CPT STRATEGIC PLANNING

Director, SES- 1 Assistant Director, GS- 15

Secretary, GS- 9 Events Assistant, PMI GS- 9

Strategic Planner, LT Strategic Planner, LTC Deputy Events Manager, GS- 12

Strategic Planner, GS- 13 Research Assistant, GS- 4

CHIEF OF STAFF OFFICE Chief of Staff, SES- 6

Secretary, GS- 10 Deputy Chief of Staff Staff Assistant, GS- 7 Staff
Assistant, GS- 9 LEGAL COUNSEL

General Counsel, SES- 3 Secretary, GS- 9 Dep. Gen. Counsel, GS- 15 Associate
Counsel, GS- 14

Attorney- Advisor, GS- 14 Attorney- Advisor, GS- 13

DIRECTOR'S OFFICE Director, PAS Personal Secretary, GS- 7 Executive
Assistant, COL

Strategic Planner, COL Confidential Assistant, GS- 13 Confidential
Assistant, GS- 11

Speech Writer, GS- 14 Scheduler, GS- 11 Staff Assistant, GS- 7

Scheduler, GS- 8 LEGISLATIVE AFFAIRS

Director, SES- 1 Secretary, GS- 9 Assistant Director, GS- 15 Legislative
Analyst - OSR, GS- 14 Legislative Analyst - ODR, GS- 14

Legislative Assistant, GS- 13 Legislative Specialist, GS- 9 Admin. Support
Asst., GS- 8

PUBLIC AFFAIRS Director, SES- 1 Secretary, GS- 9 Assistant Director, COL
Chief, Press Relations, GS- 15 Public Affairs Specialist, GS- 14 Public
Affairs Specialist, GS- 12 Public Affairs Specialist, GS- 12

Public Affairs Specialist, GS- 9 Press Relations Asst., GS- 5

Admin. Assistant, GS- 7 DEPUTY DIRECTOR'S OFFICE

Deputy Director, SES- 6 Policy Advisor, GS- 13 Confidential Secretary, GS-
10

EXECUTIVE SECRETARIAT Correspondence Manager, GS- 12 Correspondence
Specialist, GS- 10

Correspondence Assistant, GS- 6 ADMINISTRATION

Director, GS- 15 Travel Management Spec., GS- 9

Support Services Asst., GS- 7 COMMUNICATIONS Asst. for Info Sys, LTC

SUPPORT SERVICES Assistant for Support, GS- 14

Support Specialist, GS- 11 PERSONNEL Assistant for Personnel, GS- 13

Special Assistant, LTC Personnel Specialist, GS- 11

TECHNOLOGY Director, SES- 5 Secretary, GS- 9 Program Analyst, GS- 15 Program
Engineer, GS- 14 FINANCIAL MANAGEMENT

Director, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 13 Budget
Analyst, GS- 13 Budget Analyst, GS- 13 Budget Analyst, GS- 11/ 12/ 13
Financial Support Spec., GS- 11

DEMAND REDUCTION Deputy Director, PAS EX- III

Secretary, GS- 9 Asst. Deputy Director, SES- 2

Staff Director, COL Grants Administrator, GS- 15 Senior Policy Analyst, GS-
15 Program Supt. Spec., GS- 12

EDUCATION Senior Advisor and Chief, SES- 3

Bus/ Med/ Ent. Analyst, GS- 14 Mgmt & Contract Spec., GS- 14

Management Analyst, GS- 13 Special Assistant, GS- 13 Policy Analyst, PMI GS-
9

Secretary, GS- 8 PREVENTION Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, PMI GS- 9

Policy Analyst, GS- 14 TREATMENT Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, GS- 15 Cocaine Analyst, LTC

SPECIFIC DRUGS Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst,
GS- 14

Heroin Analyst, LTC STATE & LOCAL

Deputy Director, PAS EX- III Secretary, GS- 8 Asst. Deputy Director, SES- 2
Prog. Mgmt Coordinator, GS- 15

Acting Staff Director JUSTICE & LAW ENFORCEMENT

Branch Chief, GS- 15 Law Enforcement Analyst, LTC

Policy Analyst, PMI GS- 9 HIDTA Director, ES- 1 Policy Analyst, GS- 14
Policy Analyst, GS- 14 Policy Analyst, GS- 13

Secretary, GS- 8 REGIONS Branch Chief, GS- 15 South West/ Border Analyst,
GS- 14

Policy Analyst - East, GS- 14 SUPPLY REDUCTION

Deputy Director, PAS EX- III Secretary, GS- 9 Secretary, GS- 8 Asst. Deputy
Director, SES- 1

Staff Director, CDR Advisor, COL Staff Assistant, GS- 7

PROGRAM, BUDGET, RES, EVAL Director, SES Secretary, GS- 9 Secretary, GS- 9
Secretary, GS- 8 Assistant Director, SES- 1

Economist, GS- 11 PROGRAMS Branch Chief, GS- 15 Drug Policy Analyst, GS- 14

Demographer, GS- 14 Policy Analyst, GS- 14 Data/ Survey Analyst, GS- 15
Policy Analyst - Int'l Supply, LT Policy Analyst - Demand, CDR

BUDGET Branch Chief, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 14
Budget Analyst, GS- 14

Budget Analyst, LTC Budget Analyst, GS- 13

Budget Analyst, GS- 9 Budget Analyst, MAJ

EVALUATION Branch Chief, GS- 15 Policy Analyst, GS- 14 Evaluation Analyst,
COL

Policy Analyst, LTC Policy Analyst, LTC Policy Analyst, LTC Policy Analyst,
GS- 9

1999 Turnover

31 civilians 10 military detailees

27% turnover rate

Management Review Office of National Drug Control Policy Page 28

ONDCP CALENDAR YEAR 2000 ACTUAL AND POTENTIAL TURNOVER

Turnover positions are presented in red text.

DIRECTOR'S OFFICE Director, PAS Personal Secretary, GS- 7 Executive
Assistant, COL Special Assistant, GS- 12

Speech Writer, GS- 14 Staff Assistant, GS- 7

Scheduler, GS- 7 Vulnerable Positions Under

Next Administration PAS Non- Career SES

Schedule C Military Detailees

CHIEF OF STAFF OFFICE Chief of Staff, SES- 6

Secretary, GS- 10 Deputy Chief of Staff, COL

Staff Assistant, GS- 7 Staff Assistant, GS- 9

STRATEGIC PLANNING Director, SES- 1 Assistant Director, GS- 15

Secretary, GS- 9 Events Assistant, PMI GS- 9

Strategic Planner, LTC Deputy Events Manager, GS- 12

Strategic Planner, GS- 13 Research Assistant, GS- 4 LEGAL COUNSEL

General Counsel, SES- 3 Secretary, GS- 9 Deputy Counsel, GS- 15 Asst. Gen.
Counsel, COL Associate Counsel, GS- 14

Attorney- Advisor, GS- 14 Attorney- Advisor, GS- 14 LEGISLATIVE AFFAIRS

Director, SES- 1 Secretary, GS- 9 Assistant Director, GS- 15 Legislative
Analyst - OSR, GS- 14 Legislative Analyst - ODR, GS- 14

Admin. Support Asst., GS- 8 PUBLIC AFFAIRS

Director, SES- 1 Assistant Director, COL Chief, Press Relations, GS- 15
Public Affairs Specialist, GS- 14 Public Affairs Specialist, GS- 11

Public Affairs Specialist, GS- 9 Admin. Assistant, GS- 7 DEPUTY DIRECTOR'S
OFFICE

Deputy Director, SES- 6 Policy Advisor, GS- 13 Confidential Secretary, GS-
10

EXECUTIVE SECRETARIAT Correspondence Manager, GS- 12 Correspondence
Specialist, GS- 10

Correspondence Assistant, GS- 6 ADMINISTRATION

Director, GS- 15 Travel Management Spec., GS- 9

Support Services Asst., GS- 7 COMMUNICATIONS Asst. for Info Systems, LTC

SUPPORT SERVICES Assistant for Support, GS- 14

Support Specialist, GS- 11 PERSONNEL Assistant for Personnel, GS- 13

Special Assistant, LTC Personnel Specialist, GS- 11

TECHNOLOGY Director, SES- 5 Secretary, GS- 9 Program Analyst, GS- 15 Program
Engineer, GS- 14 FINANCIAL MANAGEMENT

Director, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 13 Budget
Analyst, GS- 13 Budget Analyst, GS- 13 Budget Analyst, GS- 11/ 12/ 13
Financial Support Spec., GS- 11

DEMAND REDUCTION Deputy Director, PAS EX- III

Secretary, GS- 9 Asst. Deputy Director, SES- 2

Staff Director, COL Grants Administrator, GS- 15 Senior Policy Analyst, GS-
15 Program Support Specialist, GS- 12

EDUCATION Senior Advisor and Chief, SES- 3

Bus/ Med/ Ent. Analyst, GS- 14 Mgmt & Contracts Spec., GS- 14

Management Analyst, GS- 13 Special Assistant, GS- 13 Policy Analyst, PMI GS-
9 Admin. Support Assistant, GS- 8

PREVENTION Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst, PMI
GS- 9

Policy Analyst, GS- 14 TREATMENT Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, GS- 15 Cocaine Analyst, LTC

SPECIFIC DRUGS Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst,
GS- 14

Heroin Analyst, LTC STATE & LOCAL

Deputy Director, PAS EX- III Secretary, GS- 9 Asst. Deputy Director, SES- 1

Acting Staff Director JUSTICE & LAW ENFORCEMENT

Branch Chief, GS- 15 Law Enforcement Analyst, LTC

Policy Analyst, PMI GS- 9 HIDTA Director, ES- 1 Policy Analyst, GS- 14
Policy Analyst, GS- 14 Policy Analyst, GS- 13

Secretary, GS- 8 REGIONS Branch Chief, GS- 15 South West/ Border Analyst,
GS- 14

Policy Analyst - East, GS- 14 SUPPLY REDUCTION

Deputy Director, PAS EX- III Secretary, GS- 9 Asst. Deputy Director, SES- 1

Staff Director, CDR Advisor, COL Staff Assistant, GS- 7

SOURCE COUNTRY SUPPORT Branch Chief, GS- 15 Program Support Specialist, GS-
12

Colombia Analyst, GS- 14 Mexico Analyst, GS- 13 Mexico Analyst, PMI GS- 9

Policy Analyst, GS- 9 SWA/ Africa/ Europe Analyst, GS- 14

Peru/ Bolivia Analyst, GS- 14 Burma/ Thai/ SEA Analyst, LTC

PRODUCTION & TRAFFICKING Branch Chief, GS- 15 Int'l Law Enf. Analyst, GS- 13

Policy Analyst, LTC Policy Analyst, CDR Policy Analyst, LTC Policy Analyst,
MAJ

INTELLIGENCE Director, SES- 3 Intel Research Analyst, GS- 14

Intel Sharing Analyst, LTC Intel Sharing Analyst, LTC

Researcher, CPT PROGRAMS, BUDGET,

RESEARCH, & EVALUATION Director, SES- 4 Secretary, GS- 9 Assistant Director,
SES- 1

Economist, GS- 11 Policy Analyst, GS- 9

PROGRAMS Branch Chief, GS- 15 Drug Policy Analyst, GS- 14

Demographer, GS- 14 Policy Analyst, GS- 14 Data/ Survey Analyst, GS- 15
Policy Analyst - Int'l Supply, LT Policy Analyst - Demand, CDR

BUDGET Branch Chief, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 14
Budget Analyst, GS- 14 Budget Analyst, GS- 13

Budget Analyst, MAJ EVALUATION Branch Chief, GS- 15 Policy Analyst, GS- 14

Policy Analyst, LTC Policy Analyst, LTC Policy Analyst, LTC

2000 Actual Turnover*

6 civilian 6 military detailees

2000 Potential Turnover

17 filled political 30 military detailees

38% combined turnover rate

* During the time of this review

Management Review Office of National Drug Control Policy Page 29

ONDCP COMBINED CALENDAR YEARS 1999 AND 2000 ACTUAL AND POTENTIAL TURNOVER

Turnover positions are presented in red text.

SOURCE COUNTRY SUPPORT Branch Chief, GS- 15 Program Support Specialist, GS-
12

Colombia Analyst, GS- 14 Mexico Analyst, GS- 14

Mexico Analyst, LTC Mexico Analyst, PMI GS- 9

Policy Analyst, GS- 9 SWA/ Africa/ Europe Analyst, GS- 14

Peru/ Bolivia Analyst, GS- 14 Burma/ Thai/ SEA Analyst, LTC

PRODUCTION & TRAFFICKING Branch Chief, GS- 15 Int'l Law Enf. Analyst, GS- 13

Policy Analyst, LTC Policy Analyst, CDR Policy Analyst, LTC Policy Analyst,
MAJ

INTELLIGENCE Director, SES- 3 Intel Research Analyst, GS- 14

Intel Sharing Analyst, LTC Intel Sharing Analyst, LTC

Researcher, CPT STRATEGIC PLANNING

Director, SES- 1 Assistant Director, GS- 15

Secretary, GS- 9 Events Assistant, PMI GS- 9

Strategic Planner, LT Strategic Planner, LTC Deputy Events Manager, GS- 12

Strategic Planner, GS- 13 Research Assistant, GS- 4

CHIEF OF STAFF OFFICE Chief of Staff, SES- 6

Secretary, GS- 10 Deputy Chief of Staff Staff Assistant, GS- 7 Staff
Assistant, GS- 9 LEGAL COUNSEL

General Counsel, SES- 3 Secretary, GS- 9 Dep. Gen. Counsel, GS- 15 Asst.
Gen. Counsel, COL Associate Counsel, GS- 14

Attorney- Advisor, GS- 14 Attorney- Advisor, GS- 13

DIRECTOR'S OFFICE Director, PAS Personal Secretary, GS- 7 Executive
Assistant, COL Special Assistant, GS- 12

Strategic Planner, COL Confidential Assistant, GS- 13 Confidential
Assistant, GS- 11

Speech Writer, GS- 14 Scheduler, GS- 11 Staff Assistant, GS- 7

Scheduler, GS- 8 LEGISLATIVE AFFAIRS

Director, SES- 1 Secretary, GS- 9 Assistant Director, GS- 15 Legislative
Analyst - OSR, GS- 14 Legislative Analyst - ODR, GS- 14

Legislative Assistant, GS- 13 Legislative Specialist, GS- 9 Admin. Support
Asst., GS- 8

PUBLIC AFFAIRS Director, SES- 1 Secretary, GS- 9 Assistant Director, COL
Chief, Press Relations, GS- 15 Public Affairs Specialist, GS- 14 Public
Affairs Specialist, GS- 12 Public Affairs Specialist, GS- 12 Public Affairs
Specialist, GS- 9

Press Relations Asst., GS- 5 Admin. Assistant, GS- 7 DEPUTY DIRECTOR'S
OFFICE

Deputy Director, SES- 6 Policy Advisor, GS- 13 Confidential Secretary, GS-
10

EXECUTIVE SECRETARIAT Correspondence Manager, GS- 12 Correspondence
Specialist, GS- 10

Correspondence Assistant, GS- 6 ADMINISTRATION

Director, GS- 15 Travel Management Spec., GS- 9

Support Services Asst., GS- 7 COMMUNICATIONS Asst. for Info Systems, LTC

SUPPORT SERVICES Assistant for Support, GS- 14

Support Specialist, GS- 11 PERSONNEL Assistant for Personnel, GS- 13

Special Assistant, LTC Personnel Specialist, GS- 11

TECHNOLOGY Director, SES- 5 Secretary, GS- 9 Program Analyst, GS- 15 Program
Engineer, GS- 14 FINANCIAL MANAGEMENT

Director, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 13 Budget
Analyst, GS- 13 Budget Analyst, GS- 13 Budget Analyst, GS- 11/ 12/ 13
Financial Support Spec., GS- 11

DEMAND REDUCTION Deputy Director, PAS EX- III

Secretary, GS- 9 Asst. Deputy Director, SES- 2

Staff Director, COL Grants Administrator, GS- 15 Senior Policy Analyst, GS-
15 Program Support Specialist, GS- 12

EDUCATION Senior Advisor and Chief, SES- 3

Bus/ Med/ Ent. Analyst, GS- 14 Mgmt & Contract Spec., GS- 14

Management Analyst, GS- 13 Special Assistant, GS- 13 Policy Analyst, PMI GS-
9

Secretary, GS- 8 PREVENTION Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, PMI GS- 9

Policy Analyst, GS- 14 TREATMENT Branch Chief, GS- 15 Policy Analyst, GS- 14
Policy Analyst, GS- 15 Cocaine Analyst, LTC

SPECIFIC DRUGS Branch Chief, GS- 15 Policy Analyst, GS- 14 Policy Analyst,
GS- 14

Heroin Analyst, LTC STATE & LOCAL

Deputy Director, PAS EX- III Secretary, GS- 8 Asst. Deputy Director, SES- 2
Program Mgmt. Coordnatr, GS- 15

Acting Staff Director JUSTICE & LAW ENFORCEMENT

Branch Chief, GS- 15 Law Enforcement Analyst, LTC

Policy Analyst, PMI GS- 9 HIDTA Director, ES- 1 Policy Analyst, GS- 14
Policy Analyst, GS- 14 Policy Analyst, GS- 13

Secretary, GS- 8 REGIONS Branch Chief, GS- 15 South West/ Border Analyst,
GS- 14

Policy Analyst - East, GS- 14 SUPPLY REDUCTION

Deputy Director, PAS EX- III Secretary, GS- 9 Secretary, GS- 8 Asst. Deputy
Director, SES- 1

Staff Director, CDR Advisor, COL Staff Assistant, GS- 7

PROGRAMS, BUDGET, RESEARCH, & EVALUATION

Director, SES Secretary, GS- 9 Secretary, GS- 9 Secretary, GS- 8 Assistant
Director, SES- 1

Economist, GS- 11 PROGRAMS Branch Chief, GS- 15 Drug Policy Analyst, GS- 14

Demographer, GS- 14 Policy Analyst, GS- 14 Data/ Survey Analyst, GS- 15
Policy Analyst - Int'l Supply, LT Policy Analyst - Demand, CDR

BUDGET Branch Chief, GS- 15 Budget Analyst, GS- 14 Budget Analyst, GS- 14
Budget Analyst, GS- 14

Budget Analyst, LTC Budget Analyst, GS- 13

Budget Analyst, GS- 9 Budget Analyst, MAJ

EVALUATION Branch Chief, GS- 15 Policy Analyst, GS- 14 Evaluation Analyst,
COL

Policy Analyst, LTC Policy Analyst, LTC Policy Analyst, LTC Policy Analyst,
GS- 9 Vulnerable Positions Under

Next Administration PAS Non- Career SES

Schedule C Military Detailees

Management Review Office of National Drug Control Policy Page 30

3.2.1 (d) Reasons for Turnover

ONDCP, as a federal agency governed by the procedures and practices of the
EOP, is expected to experience normal turnover of approximately 21%. 25 Some
turnover is expected due to the political nature of some of the higher level
positions. Given ONDCP's high actual turnover rates across all status
positions, however, the project team attempted to identify issues of concern
that should be addressed.

ONDCP does not conduct formal exit interviews with departing staff. When
staff members leave the agency, they complete a checklist of administrative
procedures. No formal documentation is made concerning their experiences,
reasons for leaving, or future endeavors. Assuming that departing staff
would candidly discuss issues or concerns, ONDCP cannot effectively evaluate
its internal performance without a formal record of exit interviews.
Assumptions can be made, but without formal interviews, ONDCP cannot
identify or directly address the retention and turnover issues that impact
its knowledge base.

Our research indicates that exit interviews are commonplace within the
private sector, nonprofit, and social mission organizations. Particularly in
the private sector, exit interviews are one of the primary vehicles by which
an organization can assess its employee satisfaction and make necessary
adjustments. In most private sector organizations, human resources staff
members collect exit interview data to determine consistent themes to
address. Unique, isolated issues are also considered, as required.

Thus, exit interviews are highly recommended for any place of employment.
Employees often discuss the issues that influence their decision to leave.
Some common themes are listed below.

? Inadequate career development

? Promotion ceilings

? Inadequate training

? Lack of staff appreciation

? Difficult work environment

? Non- competitive compensation

? Excessive workload

? Unpleasant working relationships with management and/ or peers

? Pursuit of better opportunities Human resources subject matter experts use
exit interviews as issue- identifiers. Ultimately, exit interview data that
leads to organizational improvements often positively influences retention
and turnover rates.

25 Attrition data collected from Office of Personnel Management's Employment
Trend Report dated November 1998.

Management Review Office of National Drug Control Policy Page 31

Our interviews with ONDCP staff suggested three primary reasons for the
agency's turnover: (1) leadership style, (2) heavy workload, and (3) career
development and promotion issues for civilians. The interviews yielded the
following:

Leadership Style: “He's difficult to work for” 26

? The current Director's leadership style has been described as aggressive,
highpressure, and military- oriented. Under the current directorship, a
military structure has been imposed on a previously civilian culture. As
incompatibilities have developed, people have made the decision to leave.

? The Director drives himself, the organization, and its people to meet his
exceedingly high expectations. Consequently, the pace is relentless, high-
pressured, and expedient in nature.

? The professional debate among ONDCP experts is primarily paper- based and,
according to some staff members, can be somewhat restrictive. Individuals
expressed concern that a substantial reliance on written communication poses
a disincentive to freely debating contentious issues since written
information can be attributed directly. It may also be time consuming. The
primarily paper- based system could make for an intellectually restricted
environment for credentialed professionals who are accustomed to free and
open oral debate of the issues. 27

? The leadership is focused on “the mission and the budget,” 28
with little attention given directly to the organization's people. According
to the Director's schedule, he spends approximately 8% of his non- office
time on internal matters. 29

Our general finding is that work- style conflicts, high stress levels, and
demanding conditions have yielded a difficult work environment.

Operational tempo/ workload is extremely high

ONDCP's workload has increased substantially, with the addition and/ or
growth of the HIDTA, Media Campaign, and Drug Free Communities programs.
ONDCP was expected to staff these programs by recruiting within the
authorized 124 FTE civilian ceiling. The workload situation has become
problematic, given the unfilled positions associated with the recruitment
and retention problems. 30

26 General comment from ONDCP staff members. 27 On page 1 of the ONDCP
response, ONDCP indicated that the report displays a misunderstanding of the
requirement for transparency in government. The project team recognizes that
ONDCP is required to comply with the Administrative Procedures Act and the
Records Management by Federal Agencies Act. It is our opinion, however, that
the primary reliance on written communication with few forums for verbal
debate “could” contribute to a restricted environment,
particularly with staff members under pressures of expediency and aware of
confidentiality issues and subpoenas at the highest levels of government. 28
Barry McCaffrey, Director, ONDCP during interview at ONDCP. 29 Scheduling
meetings, senior staff meetings, and personnel interviews (see Table 11). 30
On page 8 of the ONDCP response, ONDCP states that “recruitment has
not been problematic for

ONDCP” and that the assertion is unsubstantiated. The project team
supports the original statement that recruitment and retention have been
issues for ONDCP. Identifying and recruiting appropriate candidates

Management Review Office of National Drug Control Policy Page 32

? The HIDTA program has grown from 15 to 31 programs in the last four years
and has been staffed with 5 FTE (originally from the Bureau of State and
Local Affairs) and 2 Budget Analysts. The budget analysts have been required
to handle the 100% increase in HIDTA budget activities.

? The Media Campaign, ONDCP's multi- million dollar operational program, has
been staffed with 7 FTE (originally in Demand Reduction) to execute the
agency's largest program.

? The Director's Schedule utilizes up to 17 FTE for development, strategy,
planning, and execution of activities. The Director's Schedule involves FTE
drawn from the component and policy offices, causing additional workload for
those components that are responsible for ONDCP's primary objectives.

ONDCP has requested additional FTE to support the increase in operational
program requirements in an effort to maintain its ability to meet
coordination and compliance objectives and to support the Director's
Schedule. Out of concern that the authorized 124 civilian FTE ceiling has
never been met and given the agency's recruitment and retention problems,
Congress has rejected the FTE requests. ONDCP has absorbed the increase in
operational activities with the existing FTE, without changing the level of
effort dedicated to supporting the Director's priorities. Thus, the general
operational tempo and per capita workload of the organization is very high
as the employees take on additional responsibilities.

Career development, organizational development, promotion, and training
opportunities are limited

Career Development: There is no standard career development strategy or
program for ONDCP civilian staff to advance within the federal system.
Although we found that there are some individual efforts by well-
intentioned managers to create staff development opportunities, there is no
consistent, centralized career development strategy within the agency. Few
component or office heads have been able to provide federal career- related
incentives, such as training, to their staff. Monetary incentives are
distributed for excellent performance, but the awards are relatively small.

Organizational Development: Our interviews also revealed that there is no
current documentation of component office mission statements and position
descriptions, 31 leading to the conclusion that there may be little formal
organizational development planning taking place. Without a formal
development plan for the overall internal organization, it would be
impossible for individual staff members to visualize, let alone achieve,
career development objectives. And because there is little attention from
the leadership, organizational planning and career development practices are
being sidelined.

who will remain in positions for a significant period of time is an
important part of the retention strategy of an organization. 31 The only
documents made available in this review were position descriptions and
office mission

statements last updated in May 1996.

Management Review Office of National Drug Control Policy Page 33

Promotion Opportunities: Because ONDCP is a small, specialized agency with
specific areas of expertise, there are relatively few promotion
opportunities. 32 It is difficult for staff members to move within the
agency, due to the specialized nature of the work. But there are also other
internal promotion impediments, such as the ONDCP- specific GS- 14 policy
that does not allow a GS- 15 promotion unless the position involves a
supervisory role. Thus, ONDCP has lost civilian staff to other federal
agencies offering GS- 15 opportunities that do not require supervisory
roles. Further complicating the situation and limiting promotion
opportunities for GS- 14 individuals may be the fact that many of the GS- 15
equivalent supervisory duties and functions are currently being carried out
by Lieutenant Colonel and Colonel level military detailees (See also
Appendix I, reference to interview with Director McCaffrey in the June 2000
issue of The Reserve Officer Magazine). 33

ONDCP's policy and program coordination work also requires individuals with
advanced training and experience. The size and structure of the agency
creates another promotion ceiling for GS- 15 individuals due to the limited
number of SES positions available.

Training: There are also very limited training opportunities for career
civilian staff. The FY 1996 training budget was approximately $30,000, and
has not increased significantly over the past four years with the increase
from 40 to 124 FTE. The training budget allocation is devoted primarily to
educational programs for senior leadership, such as the $7,000 senior
executive course at Harvard University. The remaining budget pool does not
provide adequate training funds for ONDCP's support staff, analysts, and
managers. Without training opportunities in management or relevant areas of
specialization, career civilian staff have limited opportunities to advance
toward personal and professional development objectives.

These issues of career development, organizational development, promotions
and training do not affect the military detailees. The Department of Defense
handles standard human resource management practices such as career
development, personal development, and training for all military members.

32 On page 8 of ONDCP's response, ONDCP states that “the report
erroneously states that ‘there are relatively few promotion
opportunities' within the agency.” In the following paragraph of
ONDCP's response, ONDCP also states that as a small agency of 124 FTE, ONDCP
cannot offer the same diversity of professional opportunities that larger
federal agencies and departments do. The project team supports the original
statement, consistent with ONDCP's response, that because ONDCP is a small,
specialized agency with specific areas of expertise, there are
“relatively” few promotion opportunities. 33 On page 8 of
ONDCP's response, ONDCP states that “the report inaccurately
characterizes military

detailees as impediments to promotion” since military detailees do not
occupy civilian FTE positions. The project team supports the original
statement based on interviews and on information gathered from extensive
research into the Director McCaffrey's public record (See Appendix I,
reference to an interview with Director McCaffrey in the June 2000 issue of
The Reserve Officer Magazine). Military detailees perform important
supervisory functions and other significant duties that contribute to the
ongoing operations of ONDCP. The majority of these supervisory functions and
duties would be performed by civilian employees, either through increased
operational tempo or increased staff resources, were the arrangement for 30
military detailees to be terminated. If the civilian employees were
performing the supervisory functions, then there would be more opportunities
for civilians to be promoted into supervisory positions under the existing
policy.

Management Review Office of National Drug Control Policy Page 34

3.2.1 (e) Human Resource Business Practices

The ONDCP personnel group is currently staffed with one FTE responsible for
all of the agency's human resources activities. 34 Although there are shared
responsibilities with the Executive Office of the President, 35 this single
individual must attend to all ONDCPspecific areas of human resource
management including the hiring strategy, payroll, security clearances and
work authorization, organizational planning, and employee relations. Those
areas require significant time and resources. Consequently, other proactive
human resource management areas such as career development, retention
strategy, etc. have been neglected.

Human resource management is commonly organized around five process areas:
recruiting, HR information systems, career development, compensation and
benefits (operations), and training/ organizational development. A graphical
illustration is presented in Figure 10. Each of these process areas are
staffed with sufficient resources to develop, coordinate, and execute
personnel issues, policies, and programs that support an organization's
people.

Figure 10: Typical Human Resources Organizational Chart

Organizations of 100 to 150 employees generally have an HR staff of between
2 to 4 people. In those organizations with few resources, there are several
HR processes that can be outsourced, such as recruiting, HR information
systems, and compensation and benefits (operations). According to HR subject
matter experts, the two key areas that

34 On page 7 of the ONDCP response, ONDCP indicated that the personnel
office has currently assigned two FTE to the agency's civilian personnel
activities. Although ONDCP may have assigned two FTE to the office, ONDCP
had only one individual serving in the office during the term of this
review. 35 On page 7 of the ONDCP response, ONDCP asserts that the review
team had failed to note that the

Executive Office of the President (EOP) supports ONDCP in certain human
resource practices. The project team acknowledges that ONDCP has, on a case
by case basis, outsourced certain human resource activities associated with
recruiting and HR systems to EOP. The project team supports the original
statement, acknowledging a partnership with EOP. This statement also
highlights the fact that human resource activities that should remain
resident within ONDCP were being handled by one individual during the period
of this review. As a result, the more pro- active HR activities, such as
Career and Organizational Development, were not being attended to because
there was not enough staff support.

Human Resources Director

Recruiting HR Information Systems Career

Development Compensation & Benefits

Training & Organizational

Development

HUMAN RESOURCES ORGANIZATIONAL CHART

Management Review Office of National Drug Control Policy Page 35

must remain resident are career development and training and organizational
development. HR experts indicate that these areas are organization-
specific, and require an organization's internal leadership and management
to make decisions regarding its planning and execution, and the resulting
overall retention strategy.

Recruitment, training and career development, and compensation/ benefits are
seen as key contributors to staff retention and succession planning.
Business practices indicate that the relationship between recruiting,
training, and compensation/ promotion must be consistent and effective.

Recruiting is a joint effort among human resources and business units.
Expectations management is important for both the organization and the
recruiting candidates. The identification of specific skill sets based on
the organization's planning and development is also vital to the success of
recruiting and retention strategies.

Training serves as an incentive for people to stay in an organization,
particularly if the training is connected to an individual's career and
personal interests and addresses internal promotion opportunities.
Organizations must ensure that opportunities are given to staff to use the
training. Investing resources into training must be coupled with a strategy
for retaining and recruiting staff and with career development strategies.

Subject matter experts also indicate that compensation and benefits are very
important. Among the social mission organizations, compensation is a minor
influence on turnover because individuals are primarily attracted to the
nature of the work. However, other benefits and incentives such as monetary
and personal recognition, training, forms of staff appreciation, vacation,
management awards, and challenging assignments are important to the
organization's retention strategy. If all of these areas are addressed, then
organizations usually experience low turnover and high- quality employee
satisfaction.

A graphical illustration that compares ONDCP's human resources practices to
other organizations' business practices is presented below:

Table 10: Human Resource Practices in Organizations Interviewed ONDCP GE PwC
AMA AHA AP

Training ??? ?

Career Development ?????

Recruiting Success ?????

Organizational Planning ?????

Retention Strategy ?????

Compensation/ Benefits ??????

ONDCP = Office of National Drug Control Policy

GE = General Electric

PwC = PricewaterhouseCoopers

AMA = American Medical Association

AHA = American Heart Association

AP = America's Promise

Management Review Office of National Drug Control Policy Page 36

3.2.1 (f) Other Relevant Business Practices – Leadership Style

We found that leadership style and personality are key influences on overall
culture, particularly in organizations with a social mission. In a general
sense, the leader sets the “tone” for the workplace through his
or her interaction with staff and the development of internal policy. Over
time, staff tend to align themselves with the beliefs and actions of the
leader, effectively shifting the culture of the organization to mirror the
strong characteristics of its leader. Those individuals with beliefs or
behaviors at odds with the leadership tend to seek other opportunities.

Organizations with a social or vocational mission, like America's Promise,
Office of National AIDS Policy, and the Food and Drug Administration are
often led by a public “personality” or strong figure. Other
successful organizations, like General Electric, have well- known,
charismatic leaders. In researching these organizations, we identified
several consistent characteristics:

? At America's Promise, General Colin Powell has created a culture that
mirrors many private sector firms. There are no military detailees in the
organization and few individuals that have recently separated from the Armed
Forces. At America's Promise, members of the leadership are in continuous
verbal dialogue with staff to enhance the performance of the organization.
The entire leadership of America's Promise, including General Powell, tends
to be hands- on and interactive with staff, but does not micromanage
individuals who have been delegated some form of autonomy in carrying out
their respective responsibilities.

? The AIDS Czar Director, Sandra Thurman has a small office of five staff
members, so a rather informal organizational and leadership style is in
place. This office does not have authority over any of the departments or
agencies it works with. Consequently, Director Thurman relies solely on her
ability to foster positive working relationships with departments and
agencies involved in the AIDS prevention initiative.

? At General Electric (GE), CEO Jack Welch emphasizes decentralization of
power and the creation of autonomy for manager level staff. His belief is
that this practice encourages professional debate and discussion within the
organization, and provides the latitude for managers to proactively search
for solutions to client needs. An example of this is a program called the
“Workout Process.” This program consists of hundreds of
employees bringing up issues with senior leadership in the attempt to
identify and eliminate unneeded processes and tasks remaining from previous
years, when management had more layers. The workout team meets outside of
its normal work environment to discuss the issues and develop
recommendations. Team recommendations are presented to responsible managers,
who must accept or reject the proposal on the spot.

Management Review Office of National Drug Control Policy Page 37

3.2.1 (g) The Director's Schedule

ONDCP's operational tempo and workload are largely influenced by the
leadership's activity level, commonly referred to as "The Director's
Schedule." The Director's Schedule documents trips, events, media affairs,
congressional testimony, office time, other appointments, and meetings with
drug, community relations, law enforcement, and government experts.

As stated earlier in this report, the current Director secured an FTE
authorization of 124 positions plus 30 military detailees when he took over
in 1996. The Director structured the organization to handle ONDCP's primary
objectives of policy, coordination, and compliance and to coordinate his
external schedule. At the behest of the Administration, the Director created
a process within ONDCP to handle his external schedule so that he could use
the “bully pulpit” to raise the awareness of the American public
to the dangers of drug use.

ONDCP is the fourth most often mentioned Cabinet office in the news media 36
and the current Director is a well- known figure internationally. Our
purpose in presenting the information in this section is only to create
transparency with regard to the existence of this event- based apparatus and
to clarify the number of resources that a media presence of this nature and
magnitude requires.

The Director's Schedule involves up to 17 FTE, 37 including effort from
several of the component groups. The FTE assist in areas of policy and
product (message) development, strategy and long range planning, internal
and external coordination, event planning and advance work, communications
with Congressional district offices and news affiliates, correspondence with
the local print media, and general administration (travel, security, etc).

Using the Director's calendar, we analyzed the activities to examine the
amount of time allocated to specific activities on his schedule. Although
the information is not conclusive, it provides a useful indicator of how the
Director spends his time and how much effort must be devoted to creating a
sustained media presence. We recognized during our review that the Director
spends a significant amount of time in his office reviewing and studying
material. We focused the analysis, however, on activities with external
stakeholders such as the media, physicians and medical experts, law
enforcement experts, and federal, state, local, and international government
officials. Using data from six randomly selected months between November
1998 and November 1999, we extrapolated to one year of time and evaluated
the following: activity type, number of activity occurrences, activity's
total hours, average time (in minutes) per activity occurrence, activity 's
percent of total work time, and activity's percent of total non- office
time.

36 According to ONDCP's Office of Public Affairs, the ONDCP ranks fourth
behind the Department of Defense, the Department of State, and the
Department of Justice. 37 See Footnote 10.

Management Review Office of National Drug Control Policy Page 38

Based on the results of our analysis, we estimated that the Director spends
an average of 54% of his non- office time involved in Media/ Event affairs,
38 8% in meetings with medical/ drug experts and on drug issues, 39 14% in
meetings with government leaders, 3% in meetings regarding community
relations, and 6% in meetings with law enforcement experts. 40

Annually, the Director spends approximately:

? 560 hrs. at approximately 650 Media Events, Appearances, Speeches, or on
Media Issues; 41

? 110 hrs. at approximately 160 meetings with Medical/ Drug Experts or on
Drug Issues;

? 35 hrs. at approximately 45 meetings for Community Relations; and

? 60 hrs. at approximately 50 meetings with Law Enforcement. A
representative table of our analysis is presented below with the full detail
available in Appendix J.

Table 11: Director's Activity Time Scheduling Category

(Activity Type) Number of

Activities (Blocks of

Time) Estimated

Hours Average

Time (Min) Per Activity

Percentage of Total Work Time

Percentage of Non- Office

Time

Office Time+ 644 569 53 35% ---Scheduling Meetings 26 28 65 2% 3% Senior
Staff Time/ Meetings 72 64 53 4% 6% Budget Meetings 18 10 32 1% 1% Personnel
Interviews 34 27 48 2% 3% IPR*- Drug Issues 42 25 35 2% 2% IPR- Media/
Events 206 147 43 9% 14% Media Affairs/ Events/ Trips 434 413 57 26% 40%
Meetings: Government Leaders 164 144 53 9% 14% Meetings: Community Relations
42 36 52 2% 3% Meetings: Medical/ Drug Experts 118 87 44 5% 8% Meetings: Law
Enforcement Experts 48 61 76 4% 6% Total 1611 100% 100% + Time spent
reviewing and studying material. * Interim Progress Review – military
term, ONDCP interviews.

38 This number represents media interviews, speeches and appearances that do
not involve dialogue with event representatives or experts (40%), and
preparation for Media/ Events (14%). On page 11 of the ONDCP response, ONDCP
states that “the assertion that 54 percent of the Director's non-
office activities are media events is absurd.” The project team
emphasizes that the original text refers to “Media/ Events,”
rather than “media events.” The project team also supports its
original statement based on the minute by minute analysis of the Director's
Schedule calendar. 39 This number is the sum of "IPR- Drug Issues" and
"Meetings: Medical/ Drug Experts" (see Table 11). 40 This analysis does not
include travel time to and from events, which is also significant. 41
Appearances and speaking engagements that did not involve dialogue with
event representatives or

experts were included in this category.

Management Review Office of National Drug Control Policy Page 39

Analysis of Media/ Events and Policy Affairs

Using the Director's calendar, we categorized and charted the Media/ Events
activities to examine the average time allocated to specific Media/ Event
categories on the schedule: type of activity, number of occurrences,
activity's total hours, and average number of minutes per occurrence (see
Table 12).

Based on our analysis, the Director makes an estimated 386 public
appearances per year, via addresses/ remarks/ speeches and media interviews/
tapings/ videos. He spends an estimated 290 hours at these public
appearances. 42 The Director also attends approximately 90 media- related
meetings/ briefings/ working meals, spending an additional 120 hours per
year.

Table 12: Director's Media/ Event Schedule Media Affairs Category

(Activity Type) Number of Events/ Activities Estimated

Hours Percent of Time/ Category Average Time

(Min/ Event)

Address/ Remarks/ Speech 118 162 29% 82 Interviews/ Tapings/ Videos 268 129
23% 29 Sub- Total 386 290 ----- ----

Meetings/ Briefings/ Working Meals 70 93 16% 80 Attends/ Visits 20 28 5% 85
Sub- Total 90 121 ----- ----

IPR * - Media/ Events 206 147 26% 43 Total- Media Affairs 682 560 100% ----
Percentage of Total Time 54% * Interim Progress Review – military
term, ONDCP interviews

The Director also attends approximately 250 drug- related (medical/ drug,
IPR's, community relations, law enforcement) meetings, at approximately 210
hours per year. We understand that the Acting Deputy Director of ONDCP
handles many medicallyoriented and scientifically- oriented meetings and
public appearances as well. 43

42 This does not include travel time to and from events. 43 The Deputy
Director's schedule, which is significant but not listed here, is also
supported by the staff.

Management Review Office of National Drug Control Policy Page 40

A representative table of our analysis is presented below.

Table 13: Policy- Related Affairs Policy- Related Affairs Category

(Activity Type) Number of Activities Estimated

Hours Percent of Time/ Category Average Time

(Min/ Activity)

Senior Staff Time/ Meetings 72 64 15% 53 Budget Meetings 18 10 2% 31
Meetings: Government Leaders 164 144 34% 52

IPR * - Drug Issues 42 25 6% 35 Meetings: Community Relations 42 36 8% 51
Meetings: Medical/ Drug Experts 118 87 20% 44 Meetings: Law Enforcement
Experts 48 61 14% 76 Subtotal 250 209 ----- ----

Total- Policy Related 504 427 100% ---- Percentage of Total Time 43% *
Interim Progress Review – military term, ONDCP interviews

The activities that support the Director's Schedule constitute an
operational business process with a level of effort that may not have been
readily transparent to external stakeholders. With significant resources
dedicated to supporting this schedule and with the addition of programmatic
charges by Congress in recent years, there has been an erosion in ONDCP's
ability to efficiently conduct its primary objectives of policy,
coordination, and compliance.

Given that authority and institutional knowledge are concentrated centrally
with the current Director and that the depth of the knowledge base appears
to be weakened and vulnerable, the project team attempted to address the
issue of the continuity of ONDCP beyond the current Directorship. As an
official of the United States Government, the Director of ONDCP is a steward
of the public trust. It is incumbent upon the Director, therefore, to
provide for the institutionalization and continuity of the organization
beyond his or her tenure. We requested formal documentation that would give
guidance on the operations and activities of the components and functional
offices of the organization beyond its current term.

3.3 FORMAL GUIDANCE TO GOVERN THE COMPONENTS AND OFFICES BEYOND THE CURRENT
ONDCP DIRECTORSHIP WAS NOT AVAILABLE

Management Review Office of National Drug Control Policy Page 41

3. 3. 1 ONDCP- Specific written policies and procedures were not available

The project team requested ONDCP- specific written policies and procedures
that would give guidance on component and functional office activities.
These documents would provide guidance in order to avoid conflicts of
interest and would serve to govern the organization beyond the current
Directorship. In response to the original request, we were informed that
specific policies and procedures for these areas are not available. 44 (In
ONDCP's response to this report, ONDCP clarified that they do have ethics
materials and that they closely follow EOP guidance.) The main document that
outlines the missions, position descriptions, and responsibilities of the
entities within ONDCP has not been formally updated since May 1996 when
ONDCP had approximately 40 individuals on the payroll.

It is essential for organizations to have standardized policy and procedure
documents to ensure the integrity, viability, and continuity of the
organization. These documents include, for example, staff and process
manuals, position descriptions, office descriptions, office codes of
conduct, and regulation documents. Without written policies and procedures
that would preserve and manage the knowledge of the organization, an
effective transition under the next Directorship is not assured.

3.3.2 The Organization Charts provided are temporary and in conflict with
each other

The purpose of organizational structure in business operations is to create
an environment that supports the staff members' efficient execution of the
mission and of the core business processes. Without a rigorous understanding
of how misalignments in an organization's structure can produce unintended
disincentives to achieving desired behaviors, agency and department heads
could inadvertently sabotage their own efforts toward efficiently executing
the mission. If, for example, an individual has a confusing chain of command
that causes her to have burdensome reporting requirements, she may become
disgruntled or may not be able to complete all of her other
responsibilities. Establishing the correct organizational setting becomes
very important to the optimal execution of service delivery.

Organizations use charts to clearly communicate authorities,
responsibilities, and reporting structures to internal and external
stakeholders. We requested a copy of ONDCP's organizational chart. We were
provided with three distinct versions of the ONDCP “Proposed”
Organization Chart that were dated within weeks of each other: February and
March 2000. 45 All three charts conflict with reality and with each other.

44 On page 9 of the ONDCP response, ONDCP states that the conclusion
referenced above “is wrong.” The project team formally requested
access to ONDCP- specific policies and procedures governing the organization
during the week of April 17, 2000. The project team was informed that ONDCP-
specific procedures and policies do not exist. 45 Original versions of ONDCP
Organization Charts are included in Appendix C.

Management Review Office of National Drug Control Policy Page 42

The existence of several conflicting charts communicates confusion to all
stakeholders. Inconsistent communication tools are likely indicators that
there are situations where resources are not being fully optimized.

3.3.3 Other Relevant Business Practices - Policies and Procedures.

All the organizations we interviewed had some type of internal policy and
procedure document. Examples of staff manuals and regulation documents can
be found at the FDA and at America's Promise. The staff manual guides
describe the business processes of the organization and the specific
offices. FDA's regulation guides, for example, include a Compliance Policy
Guide which standardizes the way FDA issues regulatory guidance across the
agency and a Good Practice Policy which gives the inspectors a checklist of
instructions they should follow when inspecting food and drug organizations.
These internal policies must be consistent with the external policy guidance
that they hand over to their inspectors and inspected companies so that
regulations are completed according to policy.

3. 4 SUMMARY OF HR AND ORGANIZATIONAL ANALYSIS

In summary we have observed that although the organization is generally
sophisticated and accomplished, there is a shortage of investment and staff
resources to accomplish all of the activities and objectives imposed upon it
by the Congress, the Director, and the legislative charter. The shortage is
equally attributable to the increase in workload associated with new
activities, supporting the Director's priorities, and the inability of the
organization to recruit and retain qualified staff.

In the course of this evaluation, the project team identified the following
issues that raise a concern about the future continuity of ONDCP: 1)
authority is centralized and a significant amount of institutional knowledge
resides with the current Director; 2) the knowledge base has been eroded by
recruitment and retention problems in recent years; 3) relative to its size,
an inordinate number of leadership and professional staff positions (up to
38%) may be vulnerable in calendar year 2000; and 4) ONDCP- specific written
guidance addressing the activities within the components and functional
offices that would contribute to the continuity of the organization appears
to be largely absent.

Management Review Office of National Drug Control Policy Page 43

4.0 BUDGETING, ACCOUNTING, AND FINANCIAL REPORTING SYSTEMS AND INTERNAL
CONTROLS

As part of this review, the project team was asked to provide organizational
solutions and recommendations for improving the performance, efficiency, and
effectiveness of ONDCP's internal controls. In the course of our review, the
project team conducted a number of interviews with key financial management
personnel and also with key stakeholders. We complemented the interviews
with general and web- based research. The combination of interviews and
research provided a foundation for the determination of our findings. In
addition, we also developed our approach based on the findings,
recommendations, and conclusions drawn from other areas of the management
review.

In looking at internal financial controls, we focused on the following
areas:

? the risk of a breakdown in internal financial controls within ONDCP;

? levels of discretionary and non- discretionary operational budgetary
funding;

? impact of the progressive increase in workload and operational tempo on
the Financial Management Office (FMO); and

? potential for improvement through reengineering working practices and
introducing new technology.

To evaluate the risk of a breakdown in internal financial controls within
ONDCP the project team challenged the roles, responsibilities, and ways of
working against an internal controls framework. This framework consists of
six key internal controls that we would expect to be in place in the
financial office of any organization. The framework and our findings are
presented in the Summary Analysis of ONDCP Internal Financial Control Risks
in Appendix D.

ONDCP outsources many of its financial operational activities, such as
procurement and payment of vendors, contract management, and payroll. ONDCP
employs the Administration Office of the EOP (AOEOP) for reviewing and
processing financial transactions. In addition, ONDCP uses the contracting
capabilities of the Department of Health and Human Services (HHS) for large
and complex Media Campaign contracts. 46

46 Please note that a review of internal financial controls of AOEOP or HHS
has not been undertaken as it is outside of the scope of this management
review.

4.1 INTERNAL CONTROL RISK

Management Review Office of National Drug Control Policy Page 44

ONDCP still has approval authority over these contracts because the Director
approves every initiative. In addition, there is a management and contract
specialist who acts as a liaison between HHS and other contractors involved
in the Media Campaign. Therefore, ONDCP has oversight control over the
actual execution of these contracts. ONDCP recognizes the limitations of its
own organization and the capabilities of others, and by outsourcing these
activities, ONDCP brings inherent strength in internal financial controls.

As can be seen from the review of internal controls, on the whole ONDCP
appears to be at a low to medium risk of any breach in confidence that the
organization is not adhering to sound and prudent internal financial
controls. We believe, however, that there is an area that should warrant
further attention. There is a potential internal control risk arising from
not adequately matching the increased responsibilities and workload with the
required investment in the financial management infrastructure. The
potential implications of not mitigating the risk of a breakdown in the
management, supervisory, and personnel internal controls are:

? Lack of quality assurance over work products due to time pressures;

? Inappropriate levels of authority, delegation, and decision- making, given
underlying roles, responsibilities, and competencies; and

? A decline in customer service from the FMO. We classified this as a medium
risk. Should the investment not be made, however, there would be increased
exposure and a greater likelihood of a breakdown in this area.

Management Review Office of National Drug Control Policy Page 45

We have provided an analysis of the discretionary funding available to the
Director and his senior management team. This analysis is detailed in Table
14 below.

Table 14: Analysis of Discretionary and Non- discretionary Funding 47

Budget Line Item Discretionary NonDiscretionary Notes $million $million

Personal Services 10.40 $0.5 million was reprogrammed to Other Services
because not able to fill all 124 FTE positions

Travel and Transportation of Things 0.72

Rents, Comm., & Utilities 2. 54 Printing & Reproduction 0. 45 Other Services
4.71 Used $0.5 million for contractual services procured

from HHS Supplies, Materials and Equipment 0.30

Model State Drug Law 1. 00 Policy Research 1.10 CTAC 29.00 Mandated by
Congress, and “passed though” by

ONDCP HIDTA program 186.50 Mandated by Congress, and “passed
through” by

ONDCP Special Forfeiture Fund (Media Campaign funds) 216.50 Mandated by
Congress, and “passed though” by

ONDCP

1999 Total Budget* 5.88 447.34 Re- programming Total 0. 50 (0.50) Percentage
of Total Budget 1.4% 98.6%

* Budget numbers in table may be rounded. 47 Based upon the FY 1999 Budget
Submission.

4.2 DISCRETIONARY AND NON- DISCRETIONARY FUNDING AVAILABLE TO THE DIRECTOR
AND ONDCP SENIOR MANAGEMENT

Management Review Office of National Drug Control Policy Page 46

Table 14 show that less than 2% of the current funding is discretionary. In
addition, the absolute monetary value is nominal at $6.4 million per annum
-- miniscule against the annual cost of the entire federal government. The
low dollar value of discretionary funds, combined with our analysis
indicating that there is a low to medium risk of a breach in financial
internal controls provided us with enough evidence to support our findings.
The project team then redirected the focus of the review to the assessment
of other areas of management.

The HIDTA program has received additional funding over the last several
years through the approval of Congress. This increase in funding generated
additional workload. The increase in program workload has not been matched
with an investment in the FMO infrastructure; thus, the workload has been
handled through an increase in the “operational tempo” of the
organization in order to gain more results from existing resources.

As can be seen from the graph in Figure 11, the level of funding for the
HIDTA program has increased significantly since the appointment of the
current Director. The number of HIDTAs has more than doubled from 15 in 1996
to 31 in 2000, with funding rising from $102.9m to $191.2m in the same
period.

Significantly, the number of FMO staff assigned to manage the program has
remained constant at two people. Figure 11: Graph Showing the HIDTA Funding

Levels and Number of Programs Over Time

0 50

100 150

200 250

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000

HIDTA Funding ($ m)

0 5

10 15

20 25

30 35

Number of HIDTA Programs

HIDTA Funding ($ m) Number of HIDTA programs

Over the last four years, two staff members have been managing approximately
1,400 individual HIDTA budgets, requiring preparation and validation,
maintenance, reprogramming, and financial reporting. Their only functional
support comes from the Florida HIDTA Center, which submits invoices for all
HIDTA purchases. One FMO staff member at ONDCP must still review the
purchase invoices and send them to the EOP Office of Administration for
payment processing. The workload associated with the manual processes has
increased by a significant factor, with the more than doubling of the number
of HIDTAs. ONDCP has not recruited additional staff or developed enabling
technologies to support the increase in workload.

4.3 THE IMPACT OF THE PROGRESSIVE INCREASE IN WORKLOAD AND OPERATIONAL TEMPO
WITHIN THE FINANCIAL MANAGEMENT OFFICE

Management Review Office of National Drug Control Policy Page 47

In our review the project team identified potential weaknesses in internal
controls, generally centered on a lack of investment in the FMO
infrastructure to meet the increase in workload. To address these
weaknesses, and to mitigate further risk, ONDCP could reengineer working
practices and introduce new technology. The HIDTA program can be used as an
example to illustrate these opportunities.

4.4.1 Reengineering ways of working

The FMO is required to assist the HIDTA funding recipients in preparing
detailed budgets. The FMO is also required to monitor any subsequent
reprogramming of these budgets. Any simple reprogramming which merely moves
funds from one object class to another within that individual HIDTA is
approved by the appropriate HIDTA Director. The approved reprogramming is
then submitted for the ONDCP HIDTA Program Office to review and for the FMO
staff to process the reprogramming transaction. A more complex reprogramming
involving movement of funds between initiatives and/ or agencies (to include
reprogramming of funds from federal budgets to grants, from grants to
grants, or from federal budgets to federal budgets) requires approval of the
appropriate HIDTA Director and/ or HIDTA Executive Committee, the ONDCP
HIDTA Director, and the FMO staff, who in turn must process the
reprogramming transaction. To date, there have been a total of 2,000
reprogramming transactions.

The constant reprogramming of funds drives the workload through the
maintenance and update of the budget. The success and growth of the HIDTA
program requires complementing growth of business practices and adequate
oversight. Reengineering ways of working could relieve unnecessary workload
for the FMO. For example, devolving control and delegating processing for
simple reprogramming within the HIDTAs to the HIDTA Directors and regional
staff could result in a potential reduction in the workload burden of the
FMO, and could also make the HIDTA Directors more accountable and empowered
in applying their funds, measuring outcomes, and reporting budget
adjustments.

4.4.2 Investing in technology

Accounting and budgeting for the growing number of geographically dispersed
HIDTAs are supported by a Microsoft Access database. The characteristics and
attributes of user requirements for fiscal control, program management, and
information reporting lend themselves to improvement through new technology.
For example, a web- based budgeting system could support real- time HIDTA
program management, providing improved inherent internal financial controls,
and providing the visibility of program information for users and management
alike.

Little effort is needed to discover opportunities for improvement through
reengineering working practices and introducing new technology. It must be
stressed that these

4.4 POTENTIAL FOR IMPROVEMENT BY REENGINEERING WORKING PRACTICES AND
INTRODUCING NEW TECHNOLOGY.

Management Review Office of National Drug Control Policy Page 48

opportunities have also been recognized by the FMO. The ability of the FMO
to capitalize on these opportunities, however, is being hindered by the day-
to- day operational tempo and the lack of investment funding.

Management Review Office of National Drug Control Policy Page 49

Appendix A: ONDCP Employees Interviewed *

Title, Office

Director Deputy Director Chief of Staff Deputy Chief of Staff Assistant for
Personnel Asst. Deputy Director, Bureau of State and Local Affairs Acting
Deputy Director, Supply Reduction Asst. Deputy Director, Demand Reduction
General Counsel, Office of Legal Counsel Acting Director, Office of
Programs, Budget, Research & Evaluation Director, Financial Management
Office Director, Counter- Drug Technology Assessment Center Director, Office
of Legislative Affairs Director, Office of Intelligence Senior Advisor &
Chief, Media Campaign Director, Office of Administration Acting Director,
Office of Public Affairs Director, Office of Strategic Planning Asst.
Director, Office of Public Affairs Executive Assistant to the Director
Budget Analyst, Financial Management Office Budget Analyst, Financial
Management Office Budget Analyst, Financial Management Office Budget
Analyst, Financial Management Office Branch Chief, Production & Trafficking

* Participation in the interview phase of the project does not indicate
knowledge or concurrence with the information presented in this report.

Management Review Office of National Drug Control Policy Page 50

Appendix B: The External Organizations Researched and/ or Interviewed in the
Public and Private Sector *

* Participation in the interview phase of the project does not indicate
knowledge or concurrence with the information presented in this report.

Senior manager interviews with the following organizations:

United Kingdom Anti- Drug Coordinator Unit Office of National AIDS Policy
America's Promise American Heart Association American Medical Association
Food and Drug Administration Bureau of Alcohol, Tobacco, and Firearms
General Electric PwC Human Resources Office of U. S. Trade Representatives

Research on the following organizations:

Business Software Alliance Immigration and Naturalization Service US
Conference of Mayors US Surgeon General Department of Defense - Legislative
Affairs Health and Human Services

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Appendix C: Three Original Versions of ONDCP Organization Charts

Please see the pages to follow

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Appendix D: Summary Analysis of ONDCP Internal Financial Control Risk

Internal control Internal control description What we observed Evaluation of
risk Segregation of duties Clear segregation of duties for all areas of the
financial management cycle; for example, procurement and vendor payment
authority are separate within the organization.

There are clear segregation of duties within the Financial Management Office
(FMO) and also within the infrastructure of ONDCP, particularly between the
Office of Administration and the FMO.

Very Low

Organizational Clear roles and responsibilities within the organization,
with segregated organizational duties; for example, financial management of
programs is separate from program management.

Within ONDCP, the FMO is a separate organizational entity, reporting
directly to the Director.

In addition, as ONDCP is an EOP agency, there is an additional reporting
requirement to EOP financial management staff.

EOP Financial Management staff ensure that financial and contractual
transactions are not considered improper or unethical, and that they will
pass “the Washington Post test.”

The recent centralization of FMO staff has removed staff from the day- to-
day contact with the management of the programs. While this may improve
segregation of duty internal control, it otherwise decreases organizational
oversight.

Low to medium, but see observations on Personnel controls

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Internal control Internal control description What we observed Evaluation of
risk Authorization All transactions are subject to the correct and proper
level of authorization; for example, procurement approval limits are in
place and adhered to.

All financial transactions, including budget preparation and execution, and
procurement and payment of suppliers are authorized both internally within
ONDCP and also by EOP staff members.

Budget preparation, major contracts, and other significant financial
transactions by size or content are all subject to sign- off by the
Director.

Very low

Accounting Accounting controls are in place; for example, general ledger and
cash accounts are reconciled on a timely and periodic basis.

EOP maintains the financial systems.

Internal budgeting and accounting systems for the HIDTA program, for
example, are reliant upon either manual processes or unsophisticated
automation through Access databases.

While the Access databases may be considered “fit for purpose,”
the FMO has not received the required investment in Information Technology
for custom systems to support program delivery, or for the use of web- based
solutions that would improve operations and customer service of the HIDTA
program.

Medium

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Internal control Internal control description What we observed Evaluation of
risk Management, Supervisory, and Personnel Competent and experienced staff
members are performing financial management activities. Staff

members are subject to appropriate levels of management and supervision; for
example, managers are providing quality assurance over financial management
work products.

The staff members in the FMO are experienced and competent to perform their
duties, based on their length of service and qualifications.

The HIDTA Program has received an increase in funding, through the approval
by Congress. This increase in funding generates additional workload.

Increased program workload has not been matched with an investment in the
FMO infrastructure, rather the workload has been absorbed by an increased
“operational tempo” in order to gain more results from existing
resources.

Medium

Physical All assets are protected securely Not applicable Not applicable

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Appendix E: U. S. Department of Justice Office of Legal Counsel

Memorandum for Agency General Counsels Re: General Guidance on the Federal
Vacancies Reform Act of 1998 March 22, 1999

Please see the pages to follow

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Appendix F: ONDCP's Response Letter to a Preliminary Draft of the Report

Please see the pages to follow

Management Review Office of National Drug Control Policy

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Appendix G: Legislative Citations

21 USC SEC. 1703. APPOINTMENT AND DUTIES OF DIRECTOR AND DEPUTY DIRECTORS

(b) Responsibilities The Director ( 1) shall assist the President in the
establishment of

policies, goals, objectives, and priorities for the National Drug Control
Program; (2) shall promulgate the National Drug Control Strategy under
section 1705( a) of this title and each report under section 1705( b) of
this title in accordance with section 1705 of this title; (3) shall
coordinate and oversee the implementation by the National Drug Control
Program agencies of the policies, goals, objectives, and priorities
established under paragraph (1) and the fulfillment of the responsibilities
of such agencies under the National Drug Control Strategy and make
recommendations to National Drug Control Program agency heads with respect
to implementation of Federal counter- drug programs; (4) shall make such
recommendations to the President as the Director determines are appropriate
regarding changes in the organization, management, and budgets of Federal
departments and agencies engaged in drug enforcement, and changes in the
allocation of personnel to and within those departments and agencies, to
implement the policies, goals, priorities, and objectives established under
paragraph (1) and the National Drug Control Strategy; (5) shall consult with
and assist State and local governments with respect to the formulation and
implementation of National Drug Control Policy and their relations with the
National Drug Control Program agencies; (6) shall appear before duly
constituted committees and subcommittees of the House of Representatives and
of the Senate to represent the drug policies of the executive branch; (7)
shall notify any National Drug Control Program agency if its policies are
not in compliance with the responsibilities of the agency under the National
Drug Control Strategy, transmit a copy of each such notification to the
President, and maintain a copy of each such notification; (8) shall provide,
by July 1 of each year, budget recommendations, including requests for
specific initiatives that are consistent with the priorities of the
President under the National Drug Control Strategy, to the heads of
departments and agencies with responsibilities under the National Drug
Control Program, which recommendations shall ( A) apply to the next budget
year scheduled for formulation under chapter 11 of title 31, and each of the
4 subsequent fiscal years; and (B) address funding priorities developed in
the National Drug Control Strategy;

Management Review Office of National Drug Control Policy

Page 58 (9) may serve as representative of the President in appearing

before Congress on all issues relating to the National Drug Control Program;
(10) shall, in any matter affecting national security interests, work in
conjunction with the Assistant to the President for National Security
Affairs; (11) may serve as spokesperson of the Administration on drug
issues; (12) shall ensure that no Federal funds appropriated to the Office
of National Drug Control Policy shall be expended for any study or contract
relating to the legalization (for a medical use or any other use) of a
substance listed in schedule I of section 812 of this title and take such
actions as necessary to oppose any attempt to legalize the use of a
substance (in any form) that( A) is listed in schedule I of section 812 of
this title; and (B) has not been approved for use for medical purposes by
the Food and Drug Administration; (13) shall require each National Drug
Control Program agency to submit to the Director on an annual basis
(beginning in 1999) an evaluation of progress by the agency with respect to
drug control program goals using the performance measures for the agency
developed under section 1705( c) of this title, including progress with
respect to ( A) success in reducing domestic and foreign sources of illegal
drugs; (B) success in protecting the borders of the United States (and in
particular the Southwestern border of the United States) from penetration by
illegal narcotics; (C) success in reducing violent crime associated with
drug use in the United States; (D) success in reducing the negative health
and social consequences of drug use in the United States; and (E)
implementation of drug treatment and prevention programs in the United
States and improvements in the adequacy and effectiveness of such programs;
(14) shall submit to the Appropriations committees and the authorizing
committees of jurisdiction of the House of Representatives and the Senate on
an annual basis, not later than 60 days after the date of the last day of
the applicable period, a summary of ( A) each of the evaluations received by
the Director under paragraph (13); and (B) the progress of each National
Drug Control Program agency toward the drug control program goals of the
agency using the performance measures for the agency developed under section
1705( c) of this title; and (15) shall ensure that drug prevention and drug
treatment research and information is effectively disseminated by National
Drug Control Program agencies to State and local governments and non-
governmental entities involved in demand reduction by ( A) encouraging
formal consultation between any such agency that conducts or sponsors
research, and any such agency that disseminates information in developing
research and information product development agendas;

Management Review Office of National Drug Control Policy

Page 59 (B) encouraging such agencies (as appropriate) to develop and

implement dissemination plans that specifically target State and local
governments and nongovernmental entities involved in demand reduction; and
(C) developing a single interagency clearinghouse for the dissemination of
research and information by such agencies to State and local governments and
nongovernmental agencies involved in demand reduction.

21 USC SEC. 1705. DEVELOPMENT, SUBMISSION, IMPLEMENTATION, AND ASSESSMENT OF
NATIONAL DRUG CONTROL STRATEGY

(a) Timing, contents, and process for development and submission of National
Drug Control Strategy

(3) Process for development and submission (A) Consultation In developing
and effectively implementing the National Drug Control Strategy, the
Director ( i) shall consult with ( I) the heads of the National Drug Control
Program agencies; (II) Congress; (III) State and local officials; (IV)
private citizens and organizations with experience and expertise in demand
reduction; (V) private citizens and organizations with experience and
expertise in supply reduction; and (VI) appropriate representatives of
foreign governments; (ii) with the concurrence of the Attorney General, may
require the El Paso Intelligence Center to undertake specific tasks or
projects to implement the National Drug Control Strategy; and (iii) with the
concurrence of the Director of Central Intelligence and the Attorney
General, may request that the National Drug Intelligence Center undertake
specific tasks or projects to implement the National Drug Control Strategy.

5 CFR Sec. 304.102 PERSONNEL CHAPTER I-- OFFICE OF PERSONNEL MANAGEMENT PART
304-- EXPERT AND CONSULTANT APPOINTMENTS

Table of Contents Definitions. For purposes of this part: (a) An agency is
an executive department, a military department, or an independent agency.
(b) A consultant is a person who can provide valuable and pertinent advice
generally drawn from a high

degree of broad administrative, professional, or technical knowledge or
experience. When an agency requires public advisory participation, a
consultant also may be a person who is affected by a particular program and
can provide useful views from personal experience. (c) A consultant position
is one that requires providing advice, views, opinions, alternatives, or

recommendations on a temporary and/ or intermittent basis on issues,
problems, or questions presented by a Federal official.

Management Review Office of National Drug Control Policy

Page 60 (d) An expert is a person who is specially qualified by education
and experience to perform difficult and

challenging tasks in a particular field beyond the usual range of
achievement of competent persons in that field. An expert is regarded by
other persons in the field as an authority or practitioner of unusual
competence and skill in a professional, scientific, technical or other
activity. (e) An expert position is one that requires the services of a
specialist with skills superior to those of others

in the same profession, occupation, or activity to perform work on a
temporary and/ or intermittent basis assigned by a Federal official. For
example, a microbial contamination specialist may apply new test methods to
identify bacteria on products, a computer scientist may adapt advanced
methods to develop a complex software system, or a plate maker may engrave a
novel design. (f) Intermittent employment, as defined in part 340, subpart
D, of this chapter, means employment without

a regularly scheduled tour of duty. (g) Temporary employment means
employment not to exceed 1 year. An expert or consultant serving

under a temporary appointment may have a full- time, part- time, seasonal,
or intermittent work schedule. (h) Employment without compensation means
unpaid service that is provided at the agency's request and

is to perform duties that are unclassified. It is not volunteer service.

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Appendix H: ONDCP Mission Statements and Position Descriptions

? Office of the Director, ONDCP Mission Statement, May 1996: The Director of
the Office of National Drug Control Policy is charged with formulating,
evaluating, coordinating, and overseeing both international and domestic
anti- drug abuse functions by all Executive Branch agencies, and ensuring
that such functions sustain and complement State and local anti- drug abuse
efforts.

? Director, ONDCP Position Description, May 1996: The Director of ONDCP is a
member of the President's Cabinet, the National Security Council, and is the
principal Administration and national spokesperson on illicit drug use and
related issues. The Director's role is to create a national understanding of
the nature of the threat from illicit drug use and the importance of
resisting drug abuse and its consequences at all levels of society. The
Director also serves as the “drug issues advocate” within the
Federal government, developing collaborative, bipartisan relationships with
the Cabinet, members of Congress, and Washington interagency community.
Additionally, the Director coordinates and oversees other national drug
control program agencies, reviews and certifies agencies' drug control
budgets, and serves as Chair of ONDCP's Research, Data, and Evaluation
Advisory Committee.

? Office of Demand Reduction, ONDCP Mission Statement, May 1996: The Office
of Demand Reduction, ONDCP, is responsible for advising the Director of
ONDCP on policies and programs to reduce the demand for drugs and ensuring
the implementation of the demand- related portions of the National Drug
Control Strategy. In carrying out this responsibility, the office advises
the Director, ONDCP, on policies, objectives, and priorities pertaining to
demand reduction

? Deputy Director of Demand Reduction, ONDCP Position Description, May 1996:
As Deputy Director of Demand Reduction, ONDCP, the incumbent is a principal
assistant to the Director, ONDCP, responsible for overseeing the demand
policy requirements and analysis and the formulation of demand reduction
issues in the government- wide National Drug Control Strategy The incumbent
is charged with assisting the Director, ONDCP with providing the executive
direction required for organizing and overseeing the activities of the
Office of Demand Reduction.

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Appendix I: Excerpt from The Retired Officer Association (TROA) Magazine,
June 2000, Vol. LVI. No. 6, “Soldiering On: General Barry McCaffrey
Talks with Tom Philpott”

(TROA:) Was there a national drug strategy before you took over? (Director
McCaffrey:) Interesting question. One thing I bring to this job is planning.
I was the Army's strategic planner, the joint strategic planner, Gen.
[Colin] Powell's National Security Council guy. So I had intellectual tools
you get from DoD where you organize one of the world's largest activities. I
knew I had to have a strategy. Turns out there was one, but I'd never heard
of it even as a cinc. It was an annual document, a throwaway. We said,
“No, we've got to have a strategy.” We also demanded, and got
written into law, a requirement for me to produce each year a five- year
budget estimate for programs. And we had the law rewritten to demand that I
create performance measures of effectiveness. Now we're building a database
to measure how programs are achieving their purpose.

(TROA:) You also beefed up the staff. (Director McCaffrey:) I said to the
secretary of Defense, “I'm not going over there if you don't give me
30 military detailees.” I needed some planners. Now, the staff
directors of the four major subcomponents of the [ONDCP] are all full
colonels. My deputy chief of staff was a full colonel. The intelligence
officer and some planners are military. This tiny number of military
officers gave a very different tempo and discipline [to] what was
essentially a dispirited, undermanned, confused group of civilians.

(TROA:) Will that military element be perpetuated? (Director McCaffrey:) It
darn sure better be. There's a billion dollars of DoD money involved, out of
$19.2 billion overall. There are national security aspects to it. The
National Guard, the Air Force and Navy, Army Special Forces, our
intelligence system are all part of this effort. So there's certainly room
for the small number of very talented, dedicated military officers.

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Appendix J: Full Breakdown of the Director's Schedule

Please see the page to follow
*** End of document. ***