Sunday Premium Pay: Millions of Dollars in Sunday Premium Pay Are Paid to
Employees on Leave (Letter Report, 05/19/95, GAO/GGD-95-144).

Pursuant to a legislative requirement, GAO reviewed federal agencies'
payment of premium pay to employees on leave, focusing on: (1) the
agencies that paid the most Sunday premium pay; (2) the total amounts of
Sunday premium pay paid to employees on leave; (3) whether employees at
selected agencies increased their leave usage after the Office of
Personnel Management (OPM) issued premium pay guidance; and (4) the
amount the agencies spent on overtime, night differential, and holiday
premium pay for fiscal year (FY) 1994.

GAO found that: (1) a 1993 court decision required federal agencies to
pay premium pay to employees regularly scheduled to work on Sunday even
if they were on leave; (2) Congress subsequently prohibited Federal
Aviation Administration (FAA) employees in such circumstances from
receiving premium pay, which saved about $6 million; (3) in FY 1993, the
Departments of Defense (DOD), Justice (DOJ), and Veterans Affairs, and
FAA paid $178 million in Sunday premium pay which comprised about 86
percent of the premium pay paid by all executive branch agencies during
that year; (4) in FY 1994, the four agencies and the Customs Service
paid $146.1 million in Sunday premium pay, of which $17.9 million went
to employees on leave; (5) after OPM issued its premium pay guidance,
leave usage on Sundays at three of the agencies increased from 0.5 to
2.7 percent whereas DOD Sunday leave usage decreased 2.3 percent; (6)
there was not enough information available to determine DOJ leave
trends; and (7) for FY 1994, the five agencies reviewed paid $760
million, $5.94 billion, and $419.2 million in night differential,
overtime, and holiday premium pay, respectively.

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

 REPORTNUM:  GGD-95-144
     TITLE:  Sunday Premium Pay: Millions of Dollars in Sunday Premium 
             Pay Are Paid to Employees on Leave
      DATE:  05/19/95
   SUBJECT:  Federal employees
             Variable incentive pay
             Employee incentives
             Annual leave
             Sick leave
             Federal personnel law
             Judicial opinions
             Budget outlays
             Cost control
             Leave claims
IDENTIFIER:  Voluntary Leave Transfer Program
             
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Cover
================================================================ COVER


Report to Congressional Committees

May 1995

SUNDAY PREMIUM PAY - MILLIONS OF
DOLLARS IN SUNDAY PREMIUM PAY ARE
PAID TO EMPLOYEES ON LEAVE

GAO/GGD-95-144

Sunday Premium Pay


Abbreviations
=============================================================== ABBREV

  DOD - Department of Defense
  DOJ - Department of Justice
  DOT - Department of Transportation
  VA - Department of Veterans Affairs
  FAA - Federal Aviation Administration
  FBI - Federal Bureau of Investigation
  OPM - Office of Personnel Management
  VHA - Veterans Health Administration

Letter
=============================================================== LETTER


B-260238

May 19, l995

The Honorable Jim Lightfoot
Chairman
The Honorable Steny H.  Hoyer
Ranking Minority Member
Subcommittee on Treasury, Postal Service,
 and General Government
Committee on Appropriations
House of Representatives

The Honorable Richard C.  Shelby
Chairman
The Honorable J.  Robert Kerrey
Ranking Minority Member
Subcommittee on Treasury, Postal Service,
and General Government
Committee on Appropriations
United States Senate

This report responds to the direction in the conference report
accompanying the Treasury, Postal Service, and General Government
Appropriations Act of 1995 that we examine and report on the payment
of premium pay to employees on sick leave.\1 The objectives of our
review were to determine (1) the agencies that pay the most Sunday
premium pay and the amounts paid; (2) to the extent possible, the
amounts of Sunday premium pay paid to employees on leave at selected
agencies; and (3) whether employees' Sunday leave usage at these
agencies increased after issuance of the Office of Personnel
Management (OPM) letter stating that agencies must pay Sunday premium
pay to full-time employees who are regularly scheduled to work on a
Sunday, but who take paid leave during the tour of duty.\2 This
report provides the Sunday premium pay information for fiscal year
1994 and, where possible, compares Sunday leave usage for comparable
pay periods both before and after issuance of the letter.  We also
determined the amounts the agencies we reviewed spent on overtime,
night differential, and holiday premium pay for fiscal year 1994. 


--------------------
\1 H.R.  Rep.  No.  103-741, 103d Cong., 2d Session 29, Sep.  22,
1994. 

\2 OPM, FPM Letter 550-79, August 20, 1993. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

A 1993 court decision interpreting the leave provisions in title 5 of
the United States Code\3 held that federal employees who took leave
on a Sunday for which they were scheduled to work (i.e., scheduled to
work in advance of the work week) were entitled to Sunday premium pay
even though they did not work.  Accordingly, federal agencies began
paying Sunday premium pay to employees who were on leave. 
Subsequently, Congress included language in the Department of
Transportation's appropriations for 1995 that had the effect of
nullifying the court's decision with respect to Federal Aviation
Administration (FAA) employees.  The provision in the appropriations
law prohibits the payment of Sunday premium pay to an FAA employee
who takes leave on a Sunday on which the employee was regularly
scheduled to work.  Extending a similar prohibition to all federal
employees would reduce federal payroll costs by millions of dollars. 

The five agencies we reviewed--FAA,\4 U.S.  Customs Service, and the
Departments of Defense (DOD), Justice (DOJ), and Veterans Affairs
(VA)--paid $146.1 million in Sunday premium pay under 5 U.S.C. 
5546(a) and 19 U.S.C.  267 in fiscal year 1994.\5 Using leave
information provided by the five agencies, we estimated that $17.9
million of the $146.1 million in Sunday premium pay was paid to
employees on leave. 

Based on comprehensive leave data we obtained from Customs and our
analysis of leave records and other data for a portion of the
employees at DOD, FAA, and VA, we estimated\6 that leave usage on
Sundays had increased anywhere from 0.5 to 2.7 percent at three of
the agencies since the OPM letter stating that agencies must pay
Sunday premium pay to employees on paid leave was issued.  At DOD,
leave data indicated that the percentage of employees taking leave
after the issuance of the letter decreased by 2.3 percent.\7

In fiscal year 1994, federal agencies paid night differential,
overtime, and holiday premium pay in the amounts of $760.0 million,
$5,940.8 million, and $419.2 million, respectively. 


--------------------
\3 Title 5 is the statutory authority that governs the appointment
and pay setting for most federal employees.  Federal employees are
paid by authorities granted under a number of different laws
contained in several titles of the United States Code. 

\4 We limited our review of Sunday premium pay at the Department of
Transportation (DOT) to FAA because Sunday leave usage data were only
available for FAA. 

\5 This amount does not include any Sunday premium pay paid under
statutory authorities other than 5 U.S.C.  5546(a) and 19 U.S.C. 
267. 

\6 DOJ's leave trend could not be determined because DOJ, except for
the Federal Bureau of Investigation (FBI), was not able to provide
summarized leave information for leave periods before issuance of the
OPM letter. 

\7 The percentage of DOD employees taking leave on all days also
decreased between these 2 periods. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The Sunday premium pay law provides that "an employee who performs
work during a regularly scheduled 8-hour period of service .  .  .  a
part of which is performed on Sunday is entitled to pay for the
entire period of service at the rate of his basic pay, plus premium
pay at a rate equal to 25 percent of his basic pay."\8 (See 5 U.S.C. 
5546(a).) Prior to recent rulings by the courts, the long-standing
administrative practice was not to pay Sunday premium pay to
employees on annual or sick leave.  In interpreting the Sunday
premium pay provision, the Comptroller General held that payment of
the premium to employees on annual or sick leave was not appropriate
since the premium was necessarily dependent upon the employee
actually performing work on a Sunday.\9

In 1993, however, the United States Court of Appeals for the Federal
Circuit affirmed a 1991 decision of the United States Claims Court
holding that federal police officers were entitled to Sunday premium
pay for scheduled hours they did not work and for which they were
charged annual or sick leave.\10 The court held that the leave laws
prevent any reduction in customary and regular pay, including Sunday
premium pay, regardless of whether the employee actually worked as
scheduled on Sunday.  Subsequently, in view of the court's decision,
OPM issued instructions to agency heads stating that full-time
federal employees covered by the Sunday premium pay provision in
title 5 must be paid Sunday premium pay, not only for sick and annual
leave absences but also for home and shore leave, leave for jury or
witness service, military leave, funeral leave, and excused absences
approved by agencies.\11 Customs also determined that the 50-percent
Sunday premium pay provided for by 19 U.S.C.  267 was payable to
Customs officers who took paid leave on Sundays. 

In 1994, Congress addressed the issue of paying Sunday premium pay to
employees on leave at FAA.  During testimony for their fiscal year
1995 budget, DOT officials estimated that they would need $6 million
to pay Sunday premium pay to FAA employees on leave.  The
subsequently enacted Department of Transportation and Related
Agencies Appropriations Act for fiscal year 1995, however,
specifically stated that none of the funds in the bill would be
available for paying premium pay under title 5 to any FAA employee
unless such employee actually performed work during the time
corresponding to such premium pay.  An accompanying House
Appropriations Committee Report\12 stated that "the Committee finds
it incredible that the FAA should be forced to pay a premium for time
not actually worked, while budget constraints required a hiring
freeze on critical positions and the release of first-line air
traffic control supervisors and key maintenance technicians." The
report said that the savings resulting from the restriction on Sunday
premium pay would enable the Committee to include additional funding
for air traffic staffing. 


--------------------
\8 Customs officers are an exception and receive 50-percent premium
pay for Sundays under 19 U.S.C.  267. 

\9 See 53 Comp.  Gen.  292 (1973); 46 Comp.  Gen.  158 (1966). 

\10 Armitage v.  United States, 991 F.2d 746 (Fed.  Cir.  1993),
affirming Armitage v.  United States, 23 Cl.  Ct.  483 (1991). 

\11 OPM, FPM Letter 550-79, August 20, 1993. 

\12 H.R.  Rep.  No.  103-543, 103d Cong., 2d Sess.  46, June 9, 1994. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :3

We selected the five agencies in our review by identifying the four
agencies--DOD, DOJ, FAA, and VA--that paid the most Sunday premium
pay in fiscal year 1993\13 and Customs because it was specifically
identified in the conference report.  These five agencies paid a
total of $178.0 million\14 in Sunday premium pay to employees under
all pay systems during fiscal year 1993, which comprised about 86
percent of Sunday premium pay paid by executive departments during
that fiscal year. 

We obtained the total amount of Sunday premium pay paid to federal
agencies' employees from OPM's Workyears and Costs Reports for fiscal
years 1993 and 1994.  The five agencies provided the amounts of their
Sunday premium payments for fiscal year 1994. 

To determine the number of employees who took Sunday leave in fiscal
year 1994 and the leave usage patterns of employees before and after
issuance of the OPM letter, we analyzed pay and leave data.  We did
not verify the Sunday premium pay and leave data provided by the
agencies' payroll systems. 

For Customs, we obtained leave information for all the agency's
employees for fiscal years 1993 and 1994.  For DOJ, leave information
was available for all employees, but only for calendar year 1994.\15
Both DOD and VA are in the process of automating their time and
attendance systems, but the majority of their employees' time and
attendance records for fiscal year 1994 were not in an automated
system.  The largest, single DOD automated payroll system does have
time and attendance information for approximately 397,000 of the
914,000 civilian DOD employees worldwide.  We obtained Sunday leave
data for the employees scheduled to work on Sundays from this system
for calendar year 1994 because these data were more readily available
than for fiscal year 1994, and we used these data to estimate total
Sunday leave for DOD.  To obtain information on VA employees who took
leave on Sundays, we selected samples of 180 of the 886 employees who
received Sunday premium pay at 2 of VA's 186 installations that paid
Sunday premium pay in fiscal years 1993 and 1994 under title 5.  Our
samples are projectable only to all the employees at these two VA
installations.  We analyzed these 180 employees' time and attendance
records for fiscal years 1993 and 1994.  FAA provided Sunday leave
and pay data for most of its employees but only from April 4, 1993,
through May 28, 1994, because it is in the process of converting to a
new payroll system. 

Although we preferred to compare the hours employees were scheduled
to work with the actual annual and sick leave hours used rather than
the number of employees scheduled and the number of instances
employees took leave, only Customs and VA provided us with the hours
employees were scheduled to work on Sunday.  Also, none of the
agencies had readily available data on which employees used annual
and sick leave on the same Sunday or worked and took leave on the
same Sunday.  Therefore, for consistency, we used the number of
employees scheduled to work on Sunday and the number of instances
those employees took leave to determine leave usage rates.  Using the
number of employees scheduled to work and the instances employees
took leave can inflate the leave usage percentage since an employee
who worked and took leave part of the day would be counted in the
same manner as an employee who took leave for the whole day.  Also,
an employee who took both annual and sick leave on the same Sunday
would count as two leave instances of 8 hours on the same day. 

Our calculations at the two agencies for which we had both the
numbers of employees scheduled to work and taking leave and the hours
of work scheduled and hours of leave taken, however, indicated a
relatively small variance between the alternative leave usage
calculations.  The leave usage percentage based on employees at the
two VA installations and Customs was 1.2, 1.5, and 2.5 percent higher
than the hourly based leave usage percentage, respectively. 

Customs provided the actual amounts of Sunday premium pay paid to
employees on leave.  To make estimates of the amounts paid to
employees on leave at DOD, DOJ, FAA, and VA, we first determined the
percentage of employees scheduled to work Sundays who used leave.  We
then multiplied this percentage by the respective agency's total
Sunday premium pay for fiscal year 1994.  DOD, FAA, and VA estimates,
although not based on a statistically valid sample for projection to
all employees, were computed to provide some indication of the amount
of Sunday premium pay paid to employees on leave. 

We requested comments on a draft of this report from the secretaries
of the departments or their designees and the Director of OPM.  Their
comments and our evaluation of them are discussed on pages 9, 10, and
11 of this report. 

Our work was done in Washington, D.C., between December 1994 and
April 1995 in accordance with generally accepted government auditing
standards. 


--------------------
\13 Fiscal year 1993 data on Sunday premium pay were the most current
information available at the time we selected agencies for review. 

\14 This figure includes the total amount of Sunday premium payments
of the Departments of the Treasury and Transportation because the
amounts paid solely by Customs and FAA, respectively, were not
readily available. 

\15 Only FBI leave data were readily available for fiscal year 1993. 


   SUNDAY PREMIUM PAY PAID TO
   EMPLOYEES ON LEAVE
------------------------------------------------------------ Letter :4

Table 1 shows that the five agencies we reviewed paid a total of
$146.1 million in Sunday premium pay to employees in fiscal year
1994.  Of this amount, the agencies paid an estimated $17.9 million,
or 12.3 percent, to employees who used leave on one or more Sundays
in fiscal year 1994. 



                           Table 1
           
             Sunday Premium Pay Paid to Employees
           Scheduled to Work and Employees on Leave
                on Sundays in Fiscal Year 1994

                    (Dollars in millions)

                                     Percentage    Estimated
                                             of       amount
            Employees      Sunday  employees on         paid
            scheduled     premium  Sunday leave    employees
Agency      Sundays\a         pay           \bc     on leave
---------  ----------  ----------  ------------  -----------
Customs        36,490        $4.7          6.9%         $0.3
DOD         566,569\d        39.6        11.9\e        4.7\e
FAA           416,894        45.3        14.5\e        6.6\e
DOJ           330,243        21.2        11.0\e       2.3\e\
VA            4,253\d        35.3        11.3\e      4.0\e\f
============================================================
Total                      $146.1                      $17.9
------------------------------------------------------------
\a Represents the number of instances all employees in the agency
were scheduled to work on Sundays during the year. 

\b Represents the percentage of employees scheduled to work on one or
more Sundays in a pay period who took leave. 

\c As explained in the scope and methodology section of this report,
we would have preferred to compare the hours employees were scheduled
to work with leave hours used rather than the number of employees
scheduled and the number of instances employees took leave, but we
did not have sufficient hourly leave information for all agencies. 

\d Represents only the number of instances a portion of the employees
were scheduled to work Sundays at DOD for calendar year 1994 and at
VA for fiscal year 1994.  (See the scope and methodology section of
this report.)

\e See scope and methodology section for explanations of how these
estimates were derived. 

\f VA's leave usage percentage is based on only two installations;
our projection of amounts paid to employees on leave at these two
installations is $57,179.00. 

Source:  GAO analysis of Sunday premium pay and leave information
provided by the agencies. 


   SUNDAY LEAVE TRENDS BEFORE AND
   AFTER OPM LETTER
------------------------------------------------------------ Letter :5

Table 2 shows that at Customs, FAA, and VA, a higher percentage of
employees took leave on Sundays after OPM's August 20, 1993, letter
requiring agencies to pay employees on leave at the Sunday premium
rate.\16 One agency, DOD, experienced a decrease in the percentage of
employees taking leave on Sundays.  Sufficient leave information was
not available for us to make the comparison at DOJ. 



                           Table 2
           
              Sunday Leave Trends for Comparable
           Periods Before and After OPM's Letter on
                       August 20, 1993

                 Percentage of   Percentage of
                  employees on    employees on
                  leave Sunday    leave Sunday    Net change
                  before 8/20/     after 8/20/            in
Agency                    93\a            93\a   leave usage
--------------  --------------  --------------  ------------
Customs                   6.2%            6.7%         +0.5%
DOD                       13.3          11.0\d          -2.3
FAA                     12.1\b          14.6\b          +2.5
DOJ                      N/A\c          11.0\d         N/A\c
VA                         9.0            11.7          +2.7
------------------------------------------------------------
\a Percentages are based on comparable periods before and after OPM's
August 20, 1993, letter but are not for the same periods at all
agencies. 

\b FAA was not able to provide leave data for a sufficient number of
comparable pay periods before and after the letter for us to compare
similar periods, so FAA employees leave usage for pay periods from
April 4 to August 21, 1993, were compared to leave usage for pay
periods from August 22, 1993, to May 28, 1994. 

\c DOJ employees' leave record information was not available from a
systematically maintained database for pay periods prior to 1994
except for FBI employees. 

\d Figure represents calendar year 1994. 

Source:  GAO analysis of Sunday leave usage information provided by
the agencies. 


--------------------
\16 DOJ and DOD officials cited several reasons that leave usage may
have increased after August 20, 1993, including the Leave Transfer
Program being made permanent and approval of the Family Medical Leave
Act. 


   OTHER PREMIUM PAY PAID BY
   AGENCIES
------------------------------------------------------------ Letter :6

Agencies pay other types of premium pay for work performed by
employees.  Among these types of premium pay are overtime,\17

holiday,\18 and night differential.\19 Table 3 presents OPM's
preliminary figures\20 for the amounts of these types of premium pay
paid to employees by the five agencies we reviewed in fiscal year
1994. 



                           Table 3
           
                 Overtime, Holiday, and Night
               Differential Premium Pay Paid by
            Selected Agencies in Fiscal Year 1994

                    (Dollars in millions)

                                                       Night
                          Overtime     Holiday  differential
Agency                         pay         pay           pay
----------------------  ----------  ----------  ------------
Treasury\a                  $352.3      $9.2\b       $26.1\b
DOD                          992.0        45.0          62.1
DOT\a                         36.6        41.5          29.8
Justice                      404.6      23.8\b          21.2
VA                           130.2        85.8          94.6
============================================================
Total for the five        $1,915.7      $205.3        $233.8
 agencies
============================================================
Total for all federal     $5,940.8      $419.2        $760.0
 agencies
------------------------------------------------------------
\a Customs' and FAA's premium payments are part of the Departments of
the Treasury's and Transportation's total payments, respectively. 

\b OPM has requested the respective agencies to revalidate these
figures based on a preliminary quality assessment that indicated the
figures may be suspect. 

Source:  OPM's Fiscal Year 1994 Work Years and Personnel Costs Survey
(unpublished data). 


--------------------
\17 Overtime premium pay is an additional compensation paid to an
employee for work performed in excess of 8 hours in a day or in
excess of 40 hours in an administrative workweek. 

\18 Holiday premium pay is additional compensation paid to an
employee who performs work on a holiday that is not overtime work. 

\19 Night differential premium pay is a 10-percent differential
payment for regularly scheduled work performed by employees between
6:00 p.m.  and 6:00 a.m.  Customs officers are an exception,
receiving 15- to 20-percent premium pay for working between 3:00 p.m. 
and 8:00 a.m. 

\20 OPM provided these preliminary fiscal year 1994 figures with the
qualification that OPM is in the process of performing quality
assessments of the figures and reconciling with the agencies any data
problems they detect with the figures.  Thus, some revisions to the
figures are possible. 


   CONCLUSION
------------------------------------------------------------ Letter :7

Employees who take leave when scheduled to work on Sunday receive in
the aggregate millions of dollars in Sunday premium pay.  Until
recently, Sunday premium pay was generally dependent upon employees
actually performing work on a Sunday.  At FAA, Congress prohibited
payment of Sunday premium pay to employees on leave resulting in an
estimated savings of $6 million in fiscal year 1995.  Additional
savings could be achieved at other agencies, such as those we
reviewed, if Sunday premium pay were limited to employees who work as
scheduled on Sunday. 


   MATTER FOR CONSIDERATION BY
   CONGRESS
------------------------------------------------------------ Letter :8

To preclude federal employees from receiving Sunday premium pay while
on leave and to reduce governmentwide employment costs, Congress may
wish to consider requiring that employees must actually work on
Sunday to receive Sunday premium pay. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :9

We received written and oral comments from DOD and Customs.  Their
written comments are reprinted in appendixes I and II.  We received
oral comments from FAA, DOJ, OPM, and the Veterans Health
Administration (VHA), VA during May 1995.  The officials included the
Audit Liaison, DOT; the Director, Audit Liaison Office, DOJ; the
Assistant Director, Office of Compensation Policy, OPM; and several
Directors of VHA, VA.  Customs, DOD, FAA, and OPM generally agreed
with our findings, conclusion, and matter for congressional
consideration.  DOJ and VHA expressed concerns that the matter for
consideration by Congress section of this report considered only cost
savings and did not consider other measures they consider relevant,
like the impact of not paying Sunday premium pay to employees on
leave may have on agency operations, including the agencies' ability
to recruit, retain, and schedule law enforcement officers,
health-care workers, and other employees who routinely work on
hard-to-staff tours, such as Sundays.  VHA stated that even though VA
uses many special salary rates for employees in hard-to-fill
positions, VA still has difficulty hiring key health-care personnel,
such as radiology technicians.  VHA also believed that if employees
were not paid premium pay when taking leave on Sundays they would be
less willing to work on Sundays.  Both VHA and DOJ indicated they
believe employees may become demoralized if a benefit were to be
taken from them. 

In addition, VHA was concerned that the $4.0 million projection
relating to premium pay paid to employees taking leave on Sundays is
based on leave usage rates at 2 of over 300 installations and is,
therefore, not a statistically valid estimate for all VA
installations.  VHA said that the two installations we reviewed are
larger installations with active unions and that these types of
installations may experience higher leave usage rates.  Thus, VHA is
concerned that Congress may take action and eliminate Sunday premium
pay to employees on leave and reduce VA's budget by $4.0 million
based on the projection.  VA would not have sufficient funds to pay
its employees if all VA installations in aggregate experienced a
Sunday leave rate lower than the 11.3 percent experienced at the two
installations. 

We appreciate DOJ's and VHA's concerns regarding the possible impact
on recruitment and retention of terminating the payment of Sunday
premium pay to employees on leave.  However, we believe that the
specific legislative authorities Congress has provided federal
agencies to address recruitment and retention problems are still the
most appropriate ways to address these issues.  The Federal Employees
Pay Comparability Act of 1990 authorized recruitment and retention
bonuses of up to 25 percent of basic pay (5 U.S.C.  5753 and 5754). 
Furthermore, agencies can request OPM to approve special salary rates
for specific occupations, grades, and locations to alleviate existing
or likely recruitment or retention problems (5 C.F.R.  530.303). 

We do not concur with VHA's concerns that employees will not be
willing to work on Sundays.  We believe that since the employees will
still receive premium pay when they work on Sunday and do not take
leave, they should still be motivated to work on Sundays.  Regarding
VHA's concerns over our projections of leave usage and the estimated
cost of paying Sunday premium pay to employees on leave, we have
added additional qualifications to table 1 and believe our report
adequately explains in the table and the scope and methodology
section the limitations of our VA projections. 

Technical comments provided by the agencies were incorporated in the
final report where appropriate. 


---------------------------------------------------------- Letter :9.1

We are sending copies of this report to the Chairmen and Ranking
Minority Members, House and Senate Appropriations Committees; the
Chairmen and Ranking Minority Members, House and Senate
Appropriations Subcommittees on Transportation and Related Agencies;
the Secretaries of the Departments of Defense, Justice,
Transportation, the Treasury, and Veterans Affairs; and the Director
of the Office of Personnel Management.  Copies will also be made
available to others on request. 

The major contributors to this report are listed in appendix III.  If
you have any questions about this report, please contact me on (202)
512-5074. 

Nancy Kingsbury
Director
Federal Human Resource
 Management Issues




(See figure in printed edition.)Appendix I
COMMENTS FROM THE DEPARTMENT OF
DEFENSE
============================================================== Letter 




(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
THE TREASURY
============================================================== Letter 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III


   GENERAL GOVERNMENT DIVISION,
   WASHINGTON, D.C. 
------------------------------------------------------- Appendix III:1

Larry H.  Endy, Assistant Director, Federal Human Resource Management
 Issues
Thomas Davies Jr., Evaluator-in-Charge
Jeffrey Dawson, Evaluator


   OFFICE OF THE GENERAL COUNSEL,
   WASHINGTON, D.C. 
------------------------------------------------------- Appendix III:2

Alan Belkin, Assistant General Counsel
V.  Bruce Goddard, Senior Attorney
