What is OPM's Role in Accountability?

In January 2001 Civil Service Rule X, Agency Accountability Systems, was created by Executive Order 13197. This rule gives the U.S. Office of Personnel Management (OPM) authority to require agencies to establish HRM accountability systems. Section 10.2 of Rule X reads as follows:

The Director of the Office of Personnel Management may require an agency to establish and maintain a system of accountability for merit system principles that (1) sets standards for applying the merit system principles, (2) measures the agency's effectiveness in meeting these standards, and (3) corrects any deficiencies in meeting these standards. (5 CFR 10.2)

This document has a two-fold purpose -1) to set standards for agencies government-wide for establishing and maintaining the internal HRM accountability systems required under Civil Service Rule X, and 2) to give OPM a framework for reviewing or assessing these systems. It is vital that expectations regarding agency internal HRM accountability systems be clear and consistent across Government. The standards are the primary vehicle for conveying those expectations.

The scope of the standards is broad, extending to all the activities of the HR staff and the line organization to manage people in accordance with the merit system principles (5 U.S.C. 2301) while avoiding prohibited personnel practices (5 U.S.C. 2302), and in support of mission accomplishment. The coverage is very broad as well, applying to all Executive agencies subject to the merit principles, regardless of the specific legal authorities under which their HR systems operate.

This order makes formal OPM's responsibility to hold Executive departments and agencies more accountable to the President for effective human resources management (HRM). By amending Civil Service Rules V and VII and adding two new Civil Service rules, it:

1. clarifies OPM's authority to require agencies to establish their own systems for ensuring that their HRM practices are consistent with merit system principles;
2. clarifies OPM's authority to collect workforce information from agencies and strengthens OPM's authority to establish basic standards of quality for the agency information; and
3. clarifies OPM's authority to review and report on agencies' HRM programs and practices that are outside Title 5, enabling OPM to share with other agencies information on the most effective programs while ensuring that any inconsistencies with merit system principles do not go unnoticed.

Historical Background

The U.S. Office of Personnel Management's authority to evaluate Federal personnel management dates from the Civil Service Act of 1883, when Congress authorized the new Civil Service Commission to "make investigations and reports on the practical effects of Commission action as well as department and agency action in accomplishing the purposes of this act." Over the years, laws such as the Veterans Preference Act of 1944, the Classification Act of 1949, and the Performance Rating Act of 1950 have extended and defined OPM's oversight authority.

Over the years, the executive branch also has augmented OPM's evaluation authority. Some important presidential documents include:

Executive Order 9830(1947), which established the role of the personnel function in the management of Federal agencies and required the Commission "to maintain an adequate system of inspection to determine that equitable and sound application of statutes, Executive orders, regulations and standards relating to personnel management is being carried out by the agencies."

Presidential Memorandum of October 9, 1969, which required agencies to establish internal personnel management evaluation systems and charged the Commission with:

1. Establishing standards for adequate evaluation systems,
2. Conducting research in and developing methods for evaluating personnel management,
3. Insuring that persons who engage in personnel management evaluation are properly qualified and receive the necessary training,
4. Assessing the adequacy of agency evaluation systems and requiring necessary improvement,
5. Maintaining its own capability to make independent evaluation of agency personnel management effectiveness sufficient to evaluate the adequacy of agency efforts and to supplement and complement such efforts, and
6. Collaborating and coordinating with the Bureau of the Budget in its overall responsibility for evaluating organization and management in the executive branch.

More recently, the Civil Service Reform Act of 1978 abolished the Civil Service Commission and replaced it with several oversight agencies, including the Office of Personnel Management. That act also expressly stated the merit system principles in their present form. Other pertinent sections of title 5, United States Code, stemming from the reform act are:

Section 1103, which authorizes OPM to execute, administer, and enforce the civil service rules and regulations as well as to conduct studies and research into methods of improving personnel management. Section 1104, which requires OPM to establish and maintain an oversight program to insure that activities under delegated authorities are in accordance with the merit system principles and OPM standards. This section also authorizes OPM to require corrective action of agencies violating any law, rule, regulation, or OPM standard.

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Definitions

Human resources management (HRM) accountability is the responsibility shared by top agency management, line managers, and HR officials for ensuring that people are managed efficiently and effectively in support of agency mission accomplishment in accordance with the merit system principles.

A human resources management accountability system is a process for ensuring that HRM accountability is established and maintained over time.

Standards

The HRM accountability system must support the organization's mission

It must clearly address and directly support the overall organization's mission-related strategic goals and objectives, as well as those of the HR function itself.

The system should determine whether the agency has established and is executing effective human capital strategies, including but not necessarily limited to those delineated 5 CFR 250, Standards, Systems and Metrics - SSMs - (e.g., getting and keeping necessary talent, establishing and sustaining a culture of high performance, promoting effective leadership, etc.), in support of its mission and goals. It should also determine whether the HR function is adequately organized and equipped to support these strategies.

The HRM accountability system must enable the agency to identify and resolve significant problems.

It must be sufficiently targeted and comprehensive to enable the organization to identify problems or less than successful results in a timely and systematic way, especially those that pose a high risk to organizational integrity and effectiveness. The system must also enable the organization to take prompt actions to correct problems or improve sub-standard results.

Kinds of problems or issues to be addressed include HRM practices that

1. result in failure to meet organizational mission goals,
2. increase the organization's financial or legal vulnerability,
3. give rise to systemic violations of employee protections or veterans preference, or
4. lead to loss of integrity in the eyes of the public or otherwise undermine the integrity of the organization.

The HRM accountability system must provide for balanced measurement of agency human resources management.

Balance is achieved by including measures in each measurement category, as defined below. The measures chosen for use must, in the aggregate, provide a reasonable overall assessment of agency HRM -- including

1. success in carrying out agency human capital strategies,
2. effectiveness of HRM programs,
3. efficiency of HR processes, and
4. compliance with legal requirements.

The measures regarding human capital strategies must include the SSMs. Overall, measurement data will typically be drawn from a variety of sources, such as the Central Personnel Data File (CPDF) or other databases of workforce demographics, surveys of customer or employee perceptions, cost or financial data, and information from systematic internal and external reviews of records and operations.

The HRM accountability system itself and the results of its application must be documented.

The system's objectives, methods, measures, processes, and results must be documented and information generated by the system disseminated sufficiently to allow for informed review and action by appropriate officials.

Documentation should typically include

1. a description of the system and its purposes and processes,
2. results of the system's ongoing determination of HRM results,
3. recommendations for dealing with deficiencies identified, and
4. actions taken in response to recommendations.

HRM Measurement Categories

Below are four broad categories within which measures must be developed and utilized by the agency. For each category there are examples of measures that might be used. The examples are intended only to aid in understanding the categories, and are not intended to direct or limit in any way an agency's choice of measures.

1. Strategic Alignment - Measures in this category address the extent to which HR goals and programs are aligned with and support the agency mission. Examples: the degree to which targeted competency gap reductions in agency restructuring plans are met, agency staff possesses competencies needed for mission-critical activities, the effectiveness of the agency's strategy for managing employee performance, or the extent to which employees understand how their jobs fit in and contribute to fulfilling the agency mission.
2. HRM Program Effectiveness - Measures in this category address the extent to which HR programs achieve their desired outcomes, as well as the capacity of the HR staff and line managers to support effective HRM programs. Examples: retention rates, the level of employee satisfaction with agency HRM programs, the extent and effectiveness of training and development activities, the level of diversity in the workforce relative to the population at large, or data on the competencies of the HR workforce.
3. HR Operational Efficiency - Measures in this category address the degree of efficiency of HR service delivery and the capability of the human resources and other staff to support it. Examples: accuracy and timeliness of personnel processes, including time to hire; effective use of human resources information technology including the accuracy of the HRIS data base; total cost of HR per serviced employee; or cost of a given HRM activity such as staffing, benchmarked against other agencies' data or tracked internally over time.
4. Measures of Legal Compliance - Measures in this category address the extent to which HRM activities are carried out in accordance with the merit system principles and other pertinent laws and regulations. Measures should address the HRM-related actions of line managers as well as the HR staff's adherence to procedural requirements. Examples: level of compliance with veterans preference or whistleblower provisions, managers' knowledge of the merit principles, findings from internal or external HRM reviews, or results of quality control checks of CPDF data, employee files, or personnel actions.

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