| Positive Steps
Overall, the GAO is positive about the DHS final regulations, noting
they “contain many of the basic principles that are consistent
with the proven approaches to strategic human capital management.”
One area of particular note for the GAO is the involvement of employee
representatives moving forward. The GAO testimony notes that the
continuing collaboration provisions of the final regulations enable
employee representatives to discuss views with DHS officials and/or
submit written comments. According to the GAO, this is a notable
improvement over the proposed regulations.
Another positive step in the final regulations noted during testimony
is the plan to establish a process for DHS to evaluate the implementation
of its human capital system. The GAO argues that high-performing
organizations constantly collect and analyze data in order to review
and revise their human capital systems based on data-driven lessons.
The GAO approves of DHS’ plan to replace the General Schedule
(GS) system with occupational clusters and pay bands because: (1)
it believes the GS system is hindering comprehensive human capital
reform; (2) today’s complex job market requires both the granularity
and the flexibility pay banding provides; and, (3) these changes
are necessary as the organization seeks to link pay to performance
and to improve hiring.
When the proposed regulations were released, the GAO had expressed
concerns about the DHS Secretary’s authority to identify specific
offenses for which removal would be mandatory. The GAO’s desire
was that the process for determining and communicating about these
offenses be “explicit and transparent” and that the
process allow for employee representative and congressional shareholder
input. The final plan allows for publishing a listing of these offenses
in the Federal Register and addressing correspondence concerning
these offenses to employees on an annual basis.
Challenges Await
In its testimony, the GAO notes that these regulations are “an
outline and not a detailed, comprehensive plan of how the system
will be implemented.” While the GAO testimony applauds the
progress DHS made between the proposed and final regulations, it
points out numerous areas in which additional work is still needed
and/or where DHS faces real challenges.
DHS, and in fact all pay-for-performance systems, grapple with
the problem of linking individual, team, and unit performance to
organizational goals and success. In order both to operate effectively
and to gain acceptance, the DHS system will have to determine how
to create a “line of sight” connecting individual performance
plans to team, unit, and agency plans. Additionally, the agency
will need to determine how it balances performance among those constituents,
an issue not addressed under the GS system.
The GAO takes exception to DHS’ plan to allow, rather than
require, the use of competencies to provide a full assessment of
performance. The GAO argues that the development of effective employee
competencies, and then successful management of them, drives appropriate
employee behaviors. In other words, it is necessary to use competencies
to ensure attainment of goals. The GAO believes that DHS, therefore,
must require their use, not simply allow it.
The movement to a system based on pay for performance requires
that managers and supervisors can make meaningful distinctions in
employee performance. The GAO points to two areas in the DHS plan
that it believes do not support DHS’ ability to effectively
differentiate employee performance. First, pass/fail grading is
meaningless in a pay for performance environment because it provides
too little differentiation among employees. Yet, there are circumstances
in the DHS plan in which pass/fail grading still is used. Additionally,
GAO recommends using four summary rating levels—to provide
greater granularity and flexibility—rather than the three
levels the DHS plan outlines.
One of the greatest concerns of employees affected by the DHS system
change is the provision of adequate safeguards to ensure a fair
application of pay increases; employees are most concerned about
supervisors’ ability to assess performance fairly. The DHS
plans a new Compensation Committee, to replace the Performance Review
Board (PRB), which is tasked with ensuring equity. But, as the GAO
points out, it is the effective implementation of such a committee
that is essential, not the mere existence of it.
The GAO argues that the kind of institutional change required by
the implementation of DHS’ new human capital system—and
similar large-scale organizational change initiatives—requires
the development of a chief operating officer/chief management officer
(COO/CMO) position. The point of this position is threefold: (1)
to focus attention on the issue and thereby overcome the organization’s
natural resistance to change; (2) to integrate the new system into
other management systems and avoid stovepipes; and, (3) to focus
accountability for implementation in one position to ensure ownership.
Finally, the GAO identifies the need for DHS to develop and sustain
an effective two-way communication program. DHS’ final plan
outlines several one-way communication activities. The GAO argues
that DHS cannot successfully implement its new human capital system
unless it executes on a plan to collect, understand, and act on
feedback from employees, customers, and key stakeholders.
The new DoD and DHS human capital plans have been met with cheers
and jeers by government workers, employee representatives, members
of Congress, and other government watchers. What’s clear is
that the tide has turned for the management of the government workforce;
change is inevitable. Given the high profile of DHS’ human
capital changes and their potential impact on other agencies, staying
abreast of such commentary is essential for human capital leaders
across the government. |
