Department of Energy - oregonlivemedia.oregonlive.com/business_impact/other/BPAreport.DOE.pdf · 2016. 11. 7. · Power Administration (BPA) the week of June 17, 2013. The detailed

Department of Energy Washington, DC 20585

AUG 13 2013

MEMORANDUM FOR ELLIOT E. MAINZER, ACTING ADMINISTRATOR

BOf!;NNE:::;;R ~~ . --------

FROM: KEN HT. VENUtO, DIRECIOK

SUBJECT:

OF OF HUMAN CAPITAL MANAGEMENT

TEMPORARY SUSPENSION OF ALL DELEGATED HUMAN RESOURCES

AUTHORITIES FOR BONNEVILLE POWER ADMINISTRATION

Pursuant to 5 CFR 250, the Department of Energy, Office of Human Capital Management (DOE HCM)

conducted a Human Capital Management Accountability Program (HCMAP) audit of the Bonneville

Power Administration (BPA) the week of June 17, 2013. The detailed report, dated August 13, 2013,

providing the results of that audit is attached. In summary, BPA received an overall evaluation of Not

Met in three out of the four key areas of human resources (HR) activity (Strategic Alignment, Leadership

and Knowledge Management, and Talent Management), and received only a Partially Met in the other

key area (Results-based Performance Culture) .

This audit is the culmination of a number of associated reviews conducted by the DOE HCM staff of

BPA's HR activities during the past several months, including the review triggered by an Office of

Inspector General (OIG) Complaint. The actions taken to date as a result of these reviews are

chronicled as follows :

• On April 2, 2013, DOE HCM sent a memorandum to BPA directing that all outstanding and future

BPA hiring actions stemming from delegated examining activities be submitted to DOE HCM for

review and approval before proceeding due to the significant number of veterans' preference

violations the DOE HCM audit staff identified in support of an OIG investigation.

• On May 24, 2013, DOE HCM sent a memorandum to BPA temporarily suspending BPA's

delegated examining authority based on an additional review of BPA hiring cases by DOE HCM's

audit staff supporting an independent audit by OPM of BPA HR activities, conducted the week of

April 22, 2013. The DOE HCM staff found improper hiring practices specifically associated with

the application and adjudication of veterans' preference and the improper application of

qualifications procedures.

• On June 21, 2013, DOE HCM sent a memorandum to BPA temporarily suspending BPA's

classification and merit promotion hiring authorities based on the preliminary findings identified

on BPA's tri-annual HCMAP audit (subject of the attached report) conducted the week of June

17, 2013. In a vast majority of BPA's merit promotion cases, DOE HCM's audit staff found

@ Printed with soy ink on recycled paper

inappropriate use of essay questions and selective placement factors, discrepancies in applicant

evaluations, and inappropriate management access to certificates.

• On July 9, 2013, DOE HCM sent an e-mail to BPA temporarily suspending BPA's authority to take

any further adverse actions against BPA employees as a result of potential violations of

whistleblower protection.

The totality of the findings from these reviews, including those outlined in the attached HCMAP audit

report, reveal a troubling number of errant personnel practices between FY 2010 and FY 2013 in which

BPA did not properly follow applicable laws, regulations, or DOE policies. The extent of the issues

reflects a broad lack of knowledge and understanding of the laws, regulations, and DOE policies

applicable to the proper management of a Federal workforce, not only by BPA HR staff, but by BPA

management as well.

The DOE HCM staff identified some possible contributing factors to this situation during the course of

their audits and reviews that warrant additional consideration and attention. These are as follows:

• Over the past few years, BPA has' chosen to hire individuals without any prior Federal HR

knowledge or experience into key HR management positions and in HR staff specialist positions.

• BPA has chosen not to disseminate or follow written DOE orders and policy guidance, as well as

any verbal direction from proper HR authorities in DOE Headquarters, associated with the

implementation and execution of Federal HR activities.

o BPA has been slow in implementing an effective automated hiring process, thus having to rely

on cumbersome paper-based manual processes. Moreover, BPA's current automated HR

systems are either not connected to or not well integrated with the DOE automated HR systems

resulting in a lack of transparency of BPA HR activities and challenges in obtaining timely and

accurate data. This will also hinder the efficient completion of the enormo'-1S workload .

associated with reconstructing errant hiring cases and executing proper corrective actions.

As a result of the issues identified, all remaining HR authorities delegated to BPA per DOE Re-delegation

Order No. 00-010.01-01.13A are hereby temporarily suspended. All BPA HR activities, ranging from the

processing of personnel transactions to performance management and employee and labor relations,

must be reviewed and approved by DOE HCM before BPA can proceed

m I will act as the approving authorities for DOE HCM. This suspension will remain in place until

such time as BPA's HR staff is properly trained, HR procedures consistent with Federal regulations and

DOE policies are established, and BPA can clearly demonstrate the ability to properly execute compliant

HR activities under Title 5.

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Going forward, there are numerous corrective actions that will need to be taken, many of which are

outlined in the attached audit report. The level of effort needed to complete all required corrective

actions is monumental and the road to full recovery will be extremely challenging. The entire DOE HCM

staff is committed to helping BPA achieve fully complaint HR activities.

Should you have any questions or need clarification, please contact me directly at {202) 586-7138 or

have your staff contac . ffice of Strategic Planning and Policy at (202)

586-9239.

3

Human Capital Management Accountability Program

(HCMAP)

The Department of Energy Bonneville Power Administration Human Resources Office

FY'13 - Audit Report

Office of the Chief Human Capital Officer Office of Strategic Planning and Policy

Human Capital Policy Division Human Capital Management Accountability

August 13, 2013

U.S. Department of Energy Office of the Chief Human Capital Officer Office of Strategic Planning and Policy

Human Capital Policy Division Human Capital Management Accountability Program Team

The Bonneville Power Administration - August 2013

Table of Contents

I. Executive Summary....................................... 3

11. Strategic Alignment........................................ 10

111. Leadership and Knowledge Management . . . . . . . . . 13

IV. Results-Based Performance Culture................... 19

V. Talent Management........................................ 26

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The Bonneville Power Administration -August 2013

,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

Executive Summary Per Title 5 CFR 250.203, each agency is responsible for maintaining a comprehensive, integrated set of human capital goals and objectives, with detailed policy and program priorities and initiatives, consistent with agency strategic plans and annual performance goals. These human capital goals and objectives must address each of the human capital management systems included in the Human Capital Assessment and Accountability Framework (HCAAF). The HCAAF consists of human capital systems/drivers that tie human capital management to the merit system principles - a cornerstone of the American civil service - and other civil service laws, rules, and regulations.

As required by 5 CFR 250.203, each agency has delegated responsibility to implement a human capital accountability program. For the Department of Energy (DOE), the program is codified in DOE's Order 328.1 dated August 1, 2008. The Human Capital Management Accountability Program (HCMAP) is responsible for maintaining the Department's accountability system by ensuring all Servicing Human Resources Offices are in line with merit system principles, are not engaged in prohibited personnel practices and are properly executing federal regulations and requirements established by the US Office of Personnel Management (OPM) and the Department of Energy. Pursuant to Bonneville Power Administration's (SPA's) Delegation of Authority, in order to ensure SPA meets the requirements of the DOE Order 328.1 and the delegated authority, the audit team conducted an evaluation of SPA Human Resources programs and services.

The primary focus of the audit was to evaluate and assess the levels of compliance, effectiveness, and efficiency within each of the following drivers: • Strategic Alignment (workforce and strategic planning) • Leadership and Knowledge Management (Training) • Results-based Performance Culture • Talent Management (Staffing, Recruitment, Special Programs and Classification)

The process consisted of case file management and review, position classification and posttion management, analyses of corporate documentation as provided by management, and quantitative and qualitative assessments, such as surveys and interviews. The common dominators for selecting cases were the number of hires (recruitment actions) within the last 3-years, personnel actions and awards processed, implementation of new hiring initiatives and reforms, mission critical occupations, and past human capital accountability audits.

The process consisted of evaluating the following: • Random sample of personnel actions from FY'10 to FY'12; • Review of business practices, policies, and procedures for all drivers;

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• Random sample of position descriptions (at all grade levels); • Random sample of performance-related actions; and • Analysis and evaluation of workforce planning efforts.

The attached report identifies specific standards, critical success factors and expected outcomes for each of the drivers. Each standard was assessed to determine if the expected outcome/critical success factors were met for each identified standard. The following criteria were used to determine the assignment of MET, PARTIALLY MET or NOT MET to the expected outcomes:

• MET - 80% of the expected outcomes met the critical success factors of the standard(s)* • PARTIALLY MET - 70% - 79% of the expected outcomes met the critical success factors of the standard(s)* • NOT MET - less than 70% of the expected outcomes met the critical success factors of the standard(s)*

*Note: Required Actions may be identified within each assessment as "MET' or "PART/ALLY MET." However, if there are required actions stemming from egregious findings or systemic practice(s) which result in violations of the law (e.g. , veterans' preference or merit system principle violations), the assessment shall result in "NOT MET' regardless of the number of expected outcomes that met the critical success factors.

In addition to the HCAAF metrics, we have included appendices for you to refer to for further information and action. The appendices are used to list al l required and recommended actions comprehensively, and to provide more specific information for any personnel action, recruitment case file, and/or classification item that requires individual corrective action.

Required actions must be implemented within the identified timeframe. Required actions are stated when:

• Regulatory or Departmental violations have been cited; or • Enhancements must be made to ensure corporate results/outcomes are tangible and clear. • In some instances, a pattern in organizational behavior may have been noted that could pose a regulatory or programmatic

issue in the future.

Recommended actions are provided for clarity on how to improve operational procedures. A timetable for implementation of all accepted recommendations must be realistic and achievable.

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Upon completion of the required actions/recommendations, the Office of Human Capital Management will review the results and assess the outcomes to ensure compliance.

The following is a summary of the June 2013 audit:

Strategic Alignment Assessment Tools (60% of the expected outcomes were achieved and met the critical success factors of the standards) which results in an overall NOT MET determination. Specifically, areas evaluated include:

Interviews and Focus Groups Human Capital Management Strategic Plan Updated SOPs Staffing Plan and Critical Hiring List FY 10 Accomplishments Employee Survey Results and Recommendations Section II HCAAF - Strategic Alignment System

Leadership and Knowledge Management Assessment Tools (54% of the expected outcomes were achieved and met the critical success factors of the standards), which results in an overall NOT MET determination. Specifically, areas evaluated include:

Individual Development Plans (IDP's) Reviewed Training Processes, Orders, and Standard Operating Procedures Interview with Training Officer and Team Lead, Human Resources Officer

Results-Based Performance Culture (71 % of the expected outcomes were achieved and met the critical success factors of the standards), which results in an overall PARTIALLY MET determination. Specifically, areas evaluated include:

Performance appraisals and plans Non-Performance based awards Performance awards

Talent Management (26% of the expected outcomes were achieved and met the critical success factors of the standards), which results in an overall NOT MET determination. Specifically, areas evaluated include:

Staffing and Recruitment - NOT MET Delegated Examining case files

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U.S. Department of Energy Office of the Chief Human Capital Officer Office of Strategic Planning and Polley



Merit Promotion case files Compensation Incentive packages to include superior qualifications

Classification - NOT MET Reviewed position descriptions for consistency Conducted desk audits

Issues identified during the review that are of major concern and among the most notable required actions are listed below. Other required and recommended actions may be found within the report and/or the attached appendices.

1. To be in compliance with 5 CFA 430.204 and SPA PL 430-1, the SPA Human Capital Management (HCM) must ensure the following actions take place with the onset of the FY14 appraisal period.

• Ensure that supervisors and managers throughout the organization are informed/provided a copy of the critical element definition. • Review performance plans at the beginning of the appraisal period to ensure compliance with 5 CFR 430.204. • Review performance plans at the beginning of the appraisal period to ensure compliance with BPA PL 430-1 , which requires critical

elements to be written using the SMART model (Specific, Measureable, Achievable, Relevant, Time-Focused}.

2. Of great concern is that a majority of SPA's performance plans include a critical element that is based solely on behavioral expectations, which is not in accord with 5 U.S.C. §4302(b)(1). SPA must revise its employee performance management pr0gram to conform the Department's performance management program, in which behavioral factors are used as contributing factors, rather than a critical element based entirely on behavior that cannot be objectively evaluated or measured.

3. To be in compliance with PL 451-1, Section II E, the SPA HCM must develop a process which requires rating officials to certify that monetary awards provided during the appraisal period that were related to the employee's performance plan, were taken into account when the annual performance award was determined.

+. Approximately 32 cases were found in which SPA HCM approved creditable service for new employees without forwarding the request for approval to Director, Office of Human Capital Management (HCM) at DOE headquarters for approval as is required. Citation: 5 CFR 630.205 states that the head of the agency or his or her designee, at his or her sole discretion, may provide credit for non-Federal work experience. HG Policy Guidance Memorandum #20 - Crediting Directly Related Service for Annual Leave states that servicing HR offices must submit these requests to the Director, Office of Human Capital Management for approval.

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5. In approximately 54% of cases reviewed, major violations were identified such as applicants not receiving the appropriate consideration, and in which veterans' preference laws and/or merit system principles were violated. In more than half of these cases, it was noted that SPA contractors were selected for the positions. Cases in which positions had career ladders were also reviewed and it was noted that some veteran applicants were qualified at only the lowest grade level of the positions, but clearly met the qualifications at the higher grade levels also. Veterans were disadvantaged by not receiving consideration at the highest grade level for which qualified. Some non-veteran applicants may not have been qualified at the highest grade level for which they were eligible as well. The serious nature of these findings results in the requirement for SPA to reconstruct all hiring case files between FY10 and FY13. It is also required that SPA provide written responses to the Human Capital Policy Division on the overall outcome of each case; regularize any illegal appointments identified; and offer of priority consideration or priority placement, as applicable to the identified disadvantaged candidates. Citation: 5 USC 1104 (c), 5 USC 2301 (8) (1 ), 5 USC 2302 (b) (11) and (12).

6. Numerous cases were found in which SPA staff altered the cut-off score on category rating cases after the vacancy announcement closed and applications had been received. In many instances, the cut-off score was changed to as high as 99 or 100 points, and it was also noted that for positions that had career ladders the cut-off scores were changed to different scores for each grade level of the position. SPA must immediately discontinue altering or modifying the cut-off score after vacancy announcements have been posted. The new procedures put in place by SPA in May 2012 that reportedly corrected this problem were still inappropriate because they continued to allow altering the cut-off score after the job announcement was posted as long as HCM staff provided HCM leaders with written justification for doing so. The cut-off score should never be altered after the job announcement has been posted, regardless of the justification. SPA must conduct qualification analysis based on OPM standards and discontinue the procedure of using the minimum qualification process as a method to determine who will be among the best qualified. Citation: Policy Memorandum Guidance #10, OPM Qualification Standards, Delegated Examining Handbook, Title 5 CFR 330 and 5 USC2301.

7. Whenever an illegal appointment has been identified, SPA must immediately contact the Office of Human Capital Management, Office of Strategic Planning and Policy, Human Capital Policy Division (HC-11) for remedial guidance. In addition, in cases where lost consideration is evident, SPA must immediately coordinate with HC-11 to add those candidates to the priority consideration list, contact those candidates who failed to receive appropriate consideration and offer priority consideration and/or placement where appropriate.

8. Numerous cases were found in which KSA's used to rate applicants were not measurable, and were exposed to a very subjective rating process by SPA subject matter experts. SPA must ensure all rating factors are objective and measurable. Rate, rank and refer candidates solely on the

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basis of the relative ability, knowledge and skills of the position, after fair and open competition. Citation: 5 U.S.C. 2301 (b) (2) and 5 U.S.C. 2301 (b) (1).

9. The audit revealed BPA continues to require applicants to respond to KSA's with narrative essay responses. This is in violation of the President's Hiring Reform memorandum issued in May, 2010. BPA must discontinue the practice of requiring applicants to respond to KSA's with narrative essays at the time of application. Citation: Improving the Federal Recruitment and Hiring Process, dated May 11, 2010.

10. Numerous cases were reviewed in which BPA staff erroneously disqualified or mis-qualified applicants based on their demonstrated knowledge and experience. BPA must ensure all candidates' qualifications are reviewed and assessed in accordance with the Qualification Standards and any other rating criterion that is directly related to the position being filled. Citation: 5 U.S.C 2301 (b) (1) 5 CFR 300.103.

11. Numerous cases were found in which the specialized experience statements used to determine applicants' basic qualifications were overlyrestrictive, did not show distinguishable differences between grade levels, or that were not supportable based on the duties/knowledge required by the position. BPA must determine specialized experience statements that are distinguished per grade level, develop job analysis and crediting plans that have a rational relationship between performance in the position to be filled and the employment practice used. BPA must use certification requirements that are not overly restrictive so that competition is fair and open. Citation: 5 USC 2301 (b) (1) and 5 CFR 300.103 (a) and 5 CFR 300.103 (b).

12. Numerous cases were found in which SPA used "de facto" screen-outs by disqualifying applicants when they did not meet an individual KSA, which is supposed to be used only to rank applicants, not disqualify them. BPA must immediately discontinue the practice of eliminating candidates from consideration for failing to identify or address a particular knowledge, skill and/or ability. Citation: Improving the Federal Recruitment and Hiring Process, dated May 11, 2010.

13. A majority of the positions reviewed failed to have written evaluation statements prepared for the classification of the position to explain how the HR Specialist arrived at the proper classification for the title, series, and grade of the position. This was a finding in the HCMAP report of 2010, in which SPA was directed to ensure proper evaluation statements were prepared for every position classified. SPA must ensure all positions have either a written or Factor Evaluation System (FES) evaluation statement that describes how the pay plan, title, series, and grade level were determined. For positions for which the classification is derived through application of a factor evaluation system standard SPA must include a narrative explanation that describes how the position meets the factor level assigned, exceeds the factor level immediately below the factor level assigned, and fails to meet the factor level immediately above the factor level assigned. For narrative based position classification standards SPA must ensure the evaluation statement explains how the position meets the narrative level assigned, exceeds the narrative level immediately

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Upon receipt of this report, you will have an opportunity to provide a timetable for implementing all required actions as well as the listed recom~endation$. To facilitate re orting and tracking the responses, please use the provided excel file. The responses should be sent t~

~ ,~. f the Office of Strategic Planning and Policy, Human Capital Policy Division (HC-11) within 90 days of the date from this report. The accounfability team will track and monitor the status of the actions, including progress, which will be reported to the US OPM.

Attachment(s) 1. Appendix A - Recommended Actions - Staffing 2. Appendix B - SF-50 Corrections - Staffing

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STANDARD: The agency human capital management strategies are aligned with mission, goals, and organizational objectives and integrated into its strateaic clans, performance plans, and budaets. The Strategic Alignment System includes the following Critical Success Factors: Critical Success Factor: Human Capital Planning- The agency designs a coherent framework of human capital policies, programs, and practices to achieve human caoital reauirements to directlv suooort the aaencv's strateaic olan.

Expected Outcomes of Critical Success Factors

Human resources policies and programs are aligned with organizational mission, strategic goals, and performance outcomes.

Assessment

0Met

[8J Not Met

0 Partially Met

Systems exist to continually assess and improve human I [8J Met capital planning and investment and their impact on mission accomplishment. I 0 Not Met

Findings/Required or Recommended Actions

A number of BPA HR policies contain direction to staff to undertake processes that facilitate violations of merit system principles and other Federal regulations and/or Departmental policies. In addition, BPA HCM has not adequately followed nor implemented the Department's guidance on the Pathways program. While SPA makes a formidable effort in having documented policies in place, they do not effectively align with the overall mission and perfonnance outcomes. The systemic violations committed as a result of these policies culminate in an overall negative impact to BPA's entire workforce, and the corrective actions required are anticipated to be extremely high in volume.

Required Action: Consult and work with the Office of Human Capital Management, Human Capital Policy Division (HC-11) to ensure that polices are alianed with the Deoartment's, OPM and Title 5 reaulatorv reauirements. BPA has a Talent Management Strategy (TMS) for 2013-2014 which is directly related to the succession/ workforce plan which is laid out until 2018. The system is dependent upon manager/supervisor knowing their workforce and incorporating that knowledae into the olannina document. This document is laid out in easv to

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LJ Partially Met I read format with definitions in understandable terminology has been found to be of universal use for all managers, supervisors and employees throughout the organization.

Critical Success Factor: Workforce Planning- The organization identifies the human capital required to meet organizational goals, conducts analyses to identify competency gaps, develops strategies to address human capital needs and close competency gaps, and ensures the organization is appropriately structured. Workforce planning is approached strategically and in [8J Met BPA uses and improves on theirTMS which has championed as a process for an explicit documented manner based upon workforce workforce planning. It is a two year planning cycle which connects directly to the analysis and assessment of future needs to support D Not Met processes and activities by BPA stakeholders and managers. Additionally, BPA will mission accomplishment. continue to use the TMS as a way to enhance workforce planning by defining

Mission-critical occupations (MCOs) (including leadership positions) and competencies, including competency gaps, are identified and documented, providing a baseline of information for the agency to develop strategies to recruit, develop, and retain talent needed for program performance.

D Partially Met metrics against which BPA can measure its alignment to the Right Size and Composition, Right Skills and Competencies and Positive Work Environment objectives. This gives BPA a much clearer approach to workforce planning and a better way to forecast potential personnel risk.

LJ Met I While BPA has a focus in some areas of bridging competency gaps for some MCO's, such as GS-201-Human Resources Specialist, current indications reveal a

D Not Met I broad lack of basic knowledge of the GS-201 HR staff as required in both OPM classification and qualification standards in order to effectively carry out the

cgj Partially Met I responsibilities of Human Capital Programs.

Required Action: BPA must focus on ensuring key HCM management and staff positions are filled by candidates with appropriate Federal HR knowledge and experience, and on developing internal federal workforce. Once the development initiatives are in place, BPA must include these internal and external approaches to close identified gaps in critical areas.

Agency workforce planning and management practices I D Met include strategies such as:

- Restructuring I D Not Met

At the present, BPA's TMS document has set HCM priorities around restructuring, recruiting, retraining, redeployment etc. in accordance with BPA mission accomplishment. However, SPA's HAIT systems do not integrate with Departmental HAIT systems, and the data transfer process is done manually. This - Competitive sourcing

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Human Capital Polley Division Human Capital Management Accountability Program Team


- Redeployment - Retraining - Technology solutions.

~ Partially Met I effort requires the work of a number of BPA resources, which results in erroneous data, reporting, and overall inefficiency of process.

Recommended Action: BPA HCM should examine ways to better connect or integrate BPA HR IT systems with DOE HR IT systems.

Critical Success Factor: Human Resources as Strategic Partner· Human resources (HR) professionals act as consultants with managers to develop, implement, and assess human capital policies and practices to achieve the organization's shared vision. Senior leaders, managers, HR professionals, and key stakeholders contribute to the human capital vision and the agency's broader strategic planning process. HR professionals and key stakeholders are involved in I IZI Met I As mentioned previously, BPA professionals and stakeholders are heavily involved strategic and workforce planning efforts. in the workforce and succession planning arena.

The HR function is adequately staffed and prepared, in competencies and resources, to proactively partner and consult with line managers.

D Not Met

D Partially Met 0Met

r8J Not Met

D Partially Met

A predominant number of key HR positions have been filled by individuals with no Federal HR experience. BPA's HR staff has recently been de-certified by OPM, and had HR authorities suspended in the areas of delegated examining, merit promotion, and position classification by the OCHCO, as a result of pervasive violations of HR laws and regulations. In addition, there is a relatively high number of HR staff relative to the serviced population (roughly 80 feds and 30 cont ractors to service the Organization of 3, 100 employees).

Required Action: BPA must focus on ensuring key HCM management and staff positions are filled by candidates with appropriate Federal HR knowledge and experience. BPA must focus on developing internal Human Resources Workforce strategies that will enhance HR competencies and facil itate effective partnerships with line managers.

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'

STANDARD: Agency leaders and managers effectively manage people, ensure continuity of leadership, and sustain a learning environment that drives continuous improvement In performance, and pfovide a means to share critical knowledge across the organization. Knowledge management must be supported by an appropriate investment in training and technology.

The Leadership and Knowledge Management System includes the following Critical Success Factors:

Critical Success Factor: Leadership Succession Management: The organization identifies leadership competencies and establishes objectives and strategies to ensure there is a continuous pipeline of available leadership within the orQanization.

Expected Outcomes of I Assessment Critical Success Factors

Continuity of leadership is ensured through I D Met succession planning and executive development programs that address needs identified through I D Not Met competency gap analysis and result in a diverse pool of qualified internal, other Government, and I [8JPartially Met non-Government sources for all mission-critical leadership positions.

Findings/Required or Recommended Actions

BPA's 2010 Workforce Plan made managerial and executive development priority efforts. Since 2010, BPA has worked to create a robust leadership development strategy. Its current leadership development efforts include the implementation of several programs in FY13: Leadership Foundations, Leadership Essentials, and a Leadership Forum. They also implemented an Executive Excellence Program to provide development and coaching to their executive corps.

Analysis revealed a gap in BPA's leadership development efforts at the emerging leader level. BPA isn't scheduled to implement the emerging leader program until FY14 and existing programs are targeted to individuals already identified as supervisors or leaders. This is a key level of engagement as it feeds the leadership pipeline.

Based on responses received from LKM staff, it is unclear as to how individuals will be identified and selected into the leadership development pipeline.

BPA has created a comprehensive leadership development strategy. However, 14

A comprehensive management succession program provides training to employees to develop them as managers for the agency.




SPA is lacking a strategy for addressing the needs of its entire workforce. BPA could improve its processes for assessing competency and skill levels of current workforce using assessment instrument(s). Currently, assessments appear to be limited to individuals within existing leadership development programs; this approach does not adequately prepare SPA to address the workforce development needs of its entire organization.

DMet BPA's Leadership Foundations, Leadership Essentials, and Leadership Forum programs are solid components of a comprehensive management succession

D Not Met program. However, SPA is still working to implement a program for emerging leaders which is scheduled to be up and running in FY14. Once the Emerging

~Partially Met Leaders Program is fully operational, SPA will have a comprehensive succession program to provide training to its employees to develop them as managers for the agency.

BPA has a solid process for selecting applicants into its leadership development programs that meets guidance in 5 CFR 410-412. The only other area in which SPA could improve is by clearly defining/describing how individuals are/will be initially identified for participation in the management succession program and subsequent leadership development pipeline. SPA would benefit from illustrating what it is doing to ensure it is developing diverse pool of qualified leaders and managers from within SPA as well as other Government, and non-Government sources for all mission-critical leadership positions.

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Critical Success Factor: Integrity and Inspiring Employee Commitment: Leaders maintain high standards of honesty and ethics that serve as a model for the whole workforce. Leaders promote teamwork and communicate the organization's shared vision to all levels of the organization and seek feedback from employees. Employees respond by maintaining high standards of honesty and ethics. Leaders and employees maintain high standards I D Met Feedback and observations from the BPA focus groups indicates an environment of honesty and ethics. lacking trust. BPA implemented policies, procedures and practices that led to an

[gi Not Met overwhelming number of violations of merit system principles and veterans' preference. BPA also proposed adverse actions on a number of employees who

D Partially Met I have or may have raised concerns or cooperated with officials involved with several investigations/audits of BPA. In addition, the manner in which BPA management has used "Behavioral Performance Expectations" as a basis for adverse actions against employees tends to stifle honest and open communication and feedback.

Required Action: BPA must ensure all HR practices and procedures adhere to all Federal laws, regulations and DOE policies.

Leaders promote teamwork and communicate the I D Met organization's shared vision to all levels of the organization, and seek feedback from employees. I D Not Met

Information gathered through focus groups, staff interviews, and during recent audit activities indicates an atmosphere of distrust at BPA. In certain organizational elements within BPA, in particular within Human Capital Management, there is a lack of teamwork and communication between managers and employees. However, these indications of barriers in communication and teamwork were not identified as pervasive to all of BPA.

[gi Partially Met

The organization meets the training requirements I LJ Met of the Ethics in Government Act; maintains a system for identifying violations and taking I [gj Not Met corrective actions.

Recommended Action: BPA should put in place initiatives/plans to address and amend communication and teamwork between HCM Managers and Employees.

A comprehensive review of training records for all BPA employees, FY10-FY11-FY12, revealed less than 25% of the workforce has having completed its mandatory training requirements of the Ethics in Government Act. While the actual population of employees having completed this training may be substantially

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LJ Partially Met I higher, there is no way of verifying thing based on the system of record.

Required Action: Ensure all BPA employees take required training courses and all training is properly tracked and recorded.

Critical Success Factor: Continuous Leaming: Leaders foster a learning culture that provides opportunities for continuous development and encourages employees to participate. Leaders invest in education, training, and other developmental opportunities to help themselves and their employees build mission-critical competencies. The organization fosters a culture of continuous learning and high performance through investments in education, training, and other developmental opportunities that help employees build mission-critical competencies.

0Met

D Not Met

[g]Partially Met

Training and development initiatives and I LJ Met strategies support mission-critical competencies, are linked to the agency mission, and have I D Not Met demonstrated a positive impact on agency mission accomplishment. I [g]Partially Met

The organization uses appropriate learning I ~Met technology and innovative learning strategies to meet the training and development needs of the I D Not Met workforce.

D Partially Met

BPA has a highly specialized and technical workforce. The FY10 Workforce Plan identified succession planning, learning and development, and specialized training as treatments for specific occupations identified as "high risk." However, due to BPA's lack of an organizational approach to systematic skills assessment and individual development planning, it is unclear to what degree BPA has been successful in addressing mission-critical competencies. This presents a serious gap in BPA's LKM strategy.

Training and development activities support the development of both technical skills and core competencies. While these activities are clearly linked to BPA's mission and business goals, focus group feedback and review of materials failed to demonstrate a clear linkage to the Department of Energy, agency mission and goals. In addition, the decentralized nature of BPA's training activity and lack of an organizational approach to individual development planning present serious gaps in BPA's LKM strategy.

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The organization administers a process to evaluate training and development program impact in terms of learning, performance, work environment, and contribution to mission accomplishment.

IZI Met

D Not Met

D Partially Met

Training programs comply with the provisions of 5 I LJ Met U.S.C. 4101and5 CFR 410 and 412.

D Not Met

r8]Partially Met

BPA's leadership development system clearly addresses the requirements set forth in USC 5 CFR 412. However, current workforce development practices for the general workforce outside off ormal leadership development programs are inadequate and do not fulfill the requirement set forth in 5 U.S.C. 4101 and 5 CFR 410 as stated in the excerpt below:

Required Action: Ensure clear, comprehensive development program for BPA's general workforce is implemented that identifies mission-critical occupations and competencies; identifies workforce competency gaps; includes strategies for closing competency gaps; and assesses periodically, but not less often than annually, the overall agency talent management program to identify train ing needs within the agency as required by section 303 of Executive Order 11348. Citation: 5 CFR 410.201

Critical Success Factor: Knowledge Management: The organization systematically provides resources, programs, and tools for knowledge sharing across the organization in support of its mission accomplishment.

The organization's knowledge management I IZI Met process provides a means to share critical knowledge across the organization and supports I D Not Met appropriate investments in training and technology. 0Partially Met

The New Employee On-boarding and New Manager programs are excellent tools to foster knowledge transfer within BPA. The current New Employee Orientation (NEO) /New Manager Orientations provide new employees with a comprehensive understanding of BPA's mission and functions. In addition to these efforts , BPA has implemented additional efforts by way of executive coaching and mentoring activities. They are also working to implement an executive instructor cadre in

18




FY14.

Recommended Action: To improve continuity and help ensure sustained success of these efforts, recommend BPA adopt and implement a more systematic approach to assessing critical skills for the entire workforce, identifying and addressing skills gaps using these valuable resources.

Information technology tools that facilitate 0Met This portion of the audit was conducted offsite. A comprehensive review of training gathering and sharing knowledge within and records for all BPA employees, FY1O-FY11-FY12, revealed a significant lack of outside the agency are available to employees to D Not Met consistency in the tracking and reporting of training costs versus training-related improve individual and organizational travel costs. performance. ~Partially Met

Required Action: A process must be put in place to promote greater consistency and to ensure the accurate reporting of actual training costs versus training-related travel costs.

19




BPA ·Results-Oriented Performance Culture System

STANDARD: The agency has a diverse, results-oriented, high-performing workforce and a performance management system that differentiates between high and low levels of performance and links individual/team/unit performance to organizational goals and desired results effectively.

A Results-Oriented Performance Culture includes the following Critical Success Factors:

Critical Success Factor: Communication: The agency has a process for sharing information and ideas about the organization with all employees. This vital process includes eliciting employee feedback and involvement so all employees play an appropriate role in planning and executing the mission.

Expected Outcomes of Assessment Findings/Required or Recommended Actions Critical Success Factors

The strategic plan has been shared with and/or l2S] Met BPA's Human Capital Management (HCM) uses a variety of processes, methods, is accessible to all employees. Employees are and tools to share human capital information and ideas about the organization with all knowledgeable about the strategic plan and D Not Met employees. Examples include: all-employee meetings, all-employees emails from their role in supporting the agency's mission the CEO, COO, Public Affairs, BPA's internal website, posters/flyers, pamph lets, etc. and performance goals. D Partially Met

HCMAP Survey Results » There are processes or methods used to ensure employees are

knowledgeable about the strategic plan and their role in supporting the agency's mission and performance goals. (57% strongly agree/agree)

» There are processes or methods used to share information and ideas about the organization with all employees. (56% strongly agree/agree)

Critical Success Factor: Performance Aooraisal: The agency has a process under which performance is reviewed and evaluated. Employees have a direct line of sight between l2S] Met Each fiscal year, BPA's Administrator hosts an all-employee meeting to address the performance elements (performance accomplishment of the previous year's key and cross agency targets as well as share expectations) and the aqency mission. These D Not Met the new targets for the upcoming year; these targets are posted to BPA's internal

20




links have been communicated to and are understood by employees, enabling them to focus their work effort on those activities most important to mission accomplishment. All employees are held accountable for achieving results that support the agency's strategic plan goals and objectives.

0 Partially Met

Supervisors and managers use performance I D Met results to offer feedback, identify developmental needs to help improve employee performance, I ~Not Met and address instances of poor performance.

0 Partially Met

website and results are posted quarterly via performance dashboards.

In addition, BPA's Strategic Direction (multi-year strategic plan) pamphlets are distributed to employees, and Strategy Maps are posted throughout the building. Employees are encouraged to familiarize themselves with the targets and strategy maps to not only understand BPA's business goals but also to understand the steps needed to achieve them.

HCMAP Survey Results ~ There are processes or methods used to ensure that employees have a

direct line of sight between performance elements (performance expectations) and the agency mission. (46% strongly agree/agree)

~ Employees are held accountable for achieving results that support the agency's strategic plan, goals and objectives. (46% strongly agree/agree)

~ My supervisor involves me in the development of my performance plan. (72% strongly agree/agree)

~ I feel my performance elements are clear, concise, and measurable. (73% strongly agree/agree)

~ My performance plan is communicated to me at the beginning of the appraisal period by my supervisor. (86% strongly agree/agree)

A majority of BPA's performance plans consist of only two critical elements, one of which is a "Behavioral Performance Expectations" element that is based solely on behavior, which is not in accordance with 5 U.S.C. §4302(b)(1 ). Rather than being linked to the performance of the job, the majority of the Behavioral Performance Critical Elements were generic requirements that lacked clarity. For example: Proactively resolves conflict with others. This requirement does not clearly identify to the employee what "proactively" or "conflict" means to the rating official nor does it inform the employee of how the rating official will determine whether the requirement is met.

21




This critical element does not allow the rating official to objectively and accurately evaluate the job performance of employees, nor is the use of such a critical element aligned with the Department's approved performance policy, structure, and OPM's regulatory requirements.

• 5 U.S.C. § 4302 (b)(1); Under regulations which the Office of Personnel Management shall prescribe, each performance appraisal system shall provide for- (1) establishing performance standards which will, to the maximum extent feasible, permit the accurate evaluation of job performance on the basis of objective criteria (which may include the extent of courtesy demonstrated to the public) related to the job in question for each employee or position under the system.

• 5 CFR 430-203; Critical element means a work assignment or responsibility of such importance that unacceptable performance on the element would result in a determination that an employee's overall performance is unacceptable.

• DOE 0 331.1 C 4b(3); A plan must only contain critical elements that are specific, measurable, achievable, relevant to the work performed, linked to organizational mission and goals, and time-bound; contributing factors; and may include dates, or milestones for specific deliverables or projects. Each critical element will include at least one contributing factor.

Required Action: To provide employees with a transparent performance program that accurately assesses performance and ensures compliance with 5 U.S.C. §4302(b)(1 ), 5 CFR 430-203, and DOE 0 331.1 C, the SPA HCM must revise its employee performance management program to conform the Department's performance management program. Rather than having the "stand alone" Behavioral Performance critical element that cannot be objectively evaluated, the BPA HCM must follow the Department's policy of using "Contributing Factors", wh ich are the required manner of performance that is directly linked to each individual critical element.

22




The performance appraisal system(s) are established and administered in accordance with 5 U.S.C. chapter 43 or other congressionally-mandated enabling legislation, DOE policy and guidance and local program policy and guidance.

DMet

D Not Met

~ Partially Met

Sixteen FY13 performance plans containing 70 critical elements were reviewed for regulatory compliance. Although, the review revealed a vast improvement over the FY1 O audit where only 17% of the plans reviewed contained critical elements that were aligned, results-focused and measureable, the majority of the FY13 employee plans reviewed contained critical elements that did not met the following definition in 5 CFR 430-203.

• 5 CFR 430-203; Critical element means a work assignment or responsibility of such importance that unacceptable performance on the element would result in a determination that an employee's overall performance is unacceptable.

In cases where the critical element definition was met, if the critical element contained a result or outcome, it was lacking a measure for the expected result or outcome. If the critical element happened to contain both a result and a measure, it was limited to one or two sub elements within the critical.

Critical elements referenced '1imely", "accurately", or "effectively", but did not provide a definition or explanation, (e.g. timely is within 3 days, 1 week, etc.) to clearly identify the rating official's expectations.

Required Action: To be in compliance with 5 U.S.C. §4302(b)(1), 5 CFR 430-203, and DOE 0 331.1 C, the SPA HCM must ensure the following actions take place with the onset of the FY14 appraisal period.

• Ensure that supervisors and managers throughout the organization are informed/provided a copy of the critical element definition.

23




Pay adjustments, cash awards, and levels of pay are based on the results of the appraisal process, and accurately reflect and recognize individual performance and/or contribution to the agency's performance.

• Review performance plans at the beginning of the appraisal period to ensure each critical element meets the critical element definition; incorrect critical elements should immediately be returned to the rating official for correction.

• Review performance plans at the beginning of the appraisal period to ensure each critical element contains a result or outcome, and a measure for the expected result or outcome; critical elements lacking both of these requirements should immediately be returned to the rating official for correction.

Required Action: When critical elements lack clarity, the expected result for satisfactory performance can easily be misinterpreted by the employee. To ensure employees know how their performance will be measured, the BPAHCM must review performance plans at the beginning of the appraisal period to ensure compliance with BPA PL 430-1 and DOE guidance, which requires critical elements to be written using the SMART model (Specific, Measureable, Achievable, Relevant, TimeFocused). Performance plans lacking critical elements that are results focused and contain a measure by which performance can be evaluated should immediately be returned to the rating official for correction.

Recommended Action: The majority of the critical elements indicate that the rating official will assess performance through the observation of and/or feedback received on the employee. To promote a high performing, results-based workforce, the audit team encourages the BPA HCM to focus training on writing performance standards that contain credible measure rather than relying totally on the rating official's observation and/or feedback from others as these assessment options are subjective and may be difficult to uphold before a third party (e.g. Merit System Protection Board).

~ Met I One Hundred percent of the performance awards and Quality Increases reviewed were processed in accordance with PL 451-1 , SPA Recognition System and PL

D Not Met I 531/451 , Quality Step Increases. There were no instances in which an employee whose current rating of record is below the Significantly Exceeds Expectations level

D Partially Met I received a OSI. 24




One Hundred percent of the Within Grade Increases (WGI) cases reviewed were processed in accordance with regulatory guidance. There were no instances in which an employee whose current rating of record is below the Meets Expectations level received an award or WGI.

Critical Success Factor: Awards: The organization takes actions to recognize and reward individual or team achievement that contributes to meeting organizational goals or improving the efficiency, effectiveness, and economy of the Government. The organization has created a "reward ~ Met BPA PL 451-1 establishes policy and procedures to create a "reward environment" environment" beyond compensation and that contributes to attracting, retaining and motivating employee. BPA's goal is to benefits that contributes to attracting, retaining, D Not Met have a recognition-rich culture where significant accomplishments and noteworthy and motivating employees. efforts are recognized and employees feel appreciated for their contributions to

Awards and recognition are processed according to law and OPM and agency regulations and procedures.

D Partially Met BPA's success. The BPA HCM has multiple non-monetary and honorary awards to motivate employees.

0Met

D Not Met

Of the 49 non-performance based awards (e.g. Special Act, Time-Off, and On-the· Spot) reviewed, 81% contained accurate justifications, were processed in accordance with PL 451-1.

C8J Partially Met I PL 451·1, Section II E, states: "An employee may not receive more than one award for the same contribution. For example, if an employee is given a performance award but also received an On-the-Spot or Special Act award earlier for performance related to the employee's performance standards, the value of the earlier award must be taken into account in determining the amount of the subsequent award." Approximately 14 % of the monetary award cases reviewed contained justifications that included accomplishments/outcomes that were also part of the employee's performance plan and therefore, should have been taken into account when determining the employee's annual performance award. However, the audit team was unable to determine if, in fact, these monetary awards were taken into account when the employee's annual performance award was determined because there is no established mechanism or process to capture this information.

25




Required Action: To be in compliance with PL 451-1, Section II E, the SPA HCM must develop a mechanism or process which requires rating officials to certify that monetary awards provided during the appraisal period that were related to the employee's performance plan, were taken into account when the annual performance award was determined.

26




The Talent Management System includes the following Critical Success Factors: Critical Success Factor: Recruitment: The workforce plan drives the aggressive and strategic recruitment of diverse and qualified candidates tor the agency's workforce.

Retention: Leaders, managers, and supervisors create and sustain effective working relationships with employees. The workplace is characterized by: • A motivated and skilled workforce • Attractive and flexible working arrangements • Compensation packages and other programs used to hire and retain employees who possess mission-critical skills, knowledge, and competencies.

Expected Outcomes of Critical Success Factors

Workforce competency gaps are closed through the use of effective recruitment and retention strategies, creating a high-performing workforce.

Assessment I Findings/Required or Recommended Actions

D Met I BPA ensures that most external Job Opportunity Announcements (JOA's) are posted on the internet via www.usajobs.gov. although a few cases were found where the

D Not Met I www.usajobs.gov posting was not evident. In addition, BPA has identified their mission critical occupations through their work force plan. The review showed that BPA does use

r8] Partially Met / recruitment and retention incentives, but in many instances they were not offered in conjunction with positions identified in their workforce plan as hard-to-fill (i.e., many were offered for mid-level administrative positions}. BPA must ensure that when compensation incentives are offered, the offer coincides with their overall workforce plan and focuses on hard-to-fill and mission critical occupations when economically feasible.

ostina, the team noticed that in some instances in

27

Senior leaders and managers are involved in strategic recruitment and retention initiatives, ensuring the necessary organizational focus is provided and resources are allocated to achieve recruitment and retention goals.




particular those instances where the recruitment was limited to BPA only, the postings were not placed on www.usajobs.gov . While this is not prohibited, the team recommends BPA reconsiders this practice to ensure that all BPA employees are given a fair and open opportunity for new placements and/or promotion opportunities.

Recommend Action: Continue to conduct workforce and trend analysis to determine the most appropriate grade level to fill positions and the best sources of applicants. Develop a recruitment strategy which includes plans to conduct targeted outreach and recruitment activities to ensure a viable and manageable intensive pool of interested, diverse, and well qualified applicants.

Recommended Action: Consider posting BPA internal positions on www.usajobs.gov . This will promote an opportunity for all BPA employees to see internal postings beyond BPA internal intranet site.

LJ Met I In reviewing the case files and meeting with BPA staff members, it appears that BPA has the necessary resources to effectively recruit and retain qualified individuals. However,

D Not Met I BPA's recruitment efforts could be more effective, particularly within Human Capital Management. HCM must work closely with hiring officials to determine in advance the

r2J Partially Met I actual skills required for successful performance in positions (as outlined in properly classified position descriptions) and target those skills set during their recruitment efforts.

Recommended Action: Educate panel members, subject matter experts and selecting officials on rating, ranking and selecting candidates on the basis of their relative ability, knowledge, and skills.

Recommended Action: Begin to forcefully examine and identify the necessary ski lls and competencies required for all mission critical positions. Ensure that at the beginning of the recruitment efforts, those skills are identified and targeted to ensure a viable applicant pool.

28

Recruitment strategies are appropriately aggressive and multi-faceted to ensure a sufficient flow of quality applicants to meet staffing needs identified in the workforce plan.




LJ Met For majority of the audit cycle, BPA continued to use a non-automated recruitment process to accept and review applications, contrary to the recommendations of the HCMAP audit

12:?J Not Met from 2010. This was a continued issue stemming from the 2010 HCMAP audit review that identified significant weaknesses and vulnerabilities in using a manual recruitment process. D Partially Met Based on the fact that this was a finding in the 2010 HCMAP review, along with the fact that this practice has continued at BPA it is impossible to rate BPA as effective in this area. Not using an automated system can potentially increase human errors such as an oversight or inconsistent methodologies, especially if there is a significant amount of applications. Examples of such are evident in many of the cases reviewed during this audit. It is noted that in late 2012 BPA implemented an automated hiring system. However, a review of the processes in place in the automated system shows several significant erroneous procedures that must be corrected in order to prevent continued systemic violations of merit system principles and other regulatory requirements. While BPA has identified their staffing needs in a workforce plan, it is hard to determine any concerted efforts made in achieving their workforce needs, due to their continued practice of hiring candidates who lack essential skills needed for their higher graded positions, i.e., Human Resources Specialists in the GS-201 series. Vacancies are being posted via www.usajobs.gov however; the applications are being collected manually, which can potentially delay BPA in meeting their End-To-End dates and requirements.

Required Action: Work with Human Capital Policy Division to institute appropriate recruitment procedures into an automated recruitment system that complies with all Federal laws, regulations, and agency policies. The procedures implemented in the system should also effectively address recruiting strategies for each position advertised.

29

Flexible compensation strategies are used as needed to attract and retain quality employees who possess MCOs.

Quality of work/life programs are provided and obstacles to recruitment and retention of a quality workforce have been addressed, positioning the agency to be successful in acquiring and retaining the talent needed for program goals and objectives.




LJ Met I BPA uses the ability to recruit individuals to appointments above the minimum rate, otherwise known as superior qualification appointments quite frequently. Other strategies

D Not Met I that have been identified are recruitment incentives and tuition assistance programs. However, BPA must fairly assess the applicants who are afforded these opportunities to

~ Partially Met / ensure that they are in fact superiorly qualified; the positions are hard-to-fill and/or mission critical and that compensation offers are not solely based on the candidates existing nonfederal salary. In addition, BPA must assess their recruitment needs to determine prudent use of compensation incentives per the Office of Personnel Management's recommendation. While conducting the review, the team noted highly paid recruitment incentives for positions that are very easy to fill through normal recruitment efforts, i.e., Human Resource Specialists.

Required Action: Ensure that all recruitment incentives are appropriately justified, consistently, and at all times. To facilitate this process, conduct (or continue to conduct) workforce and trend analysis to determine the most appropriate time to use compensation incentives and recognize that it should not be offered for all positions. Develop a recruitment strategy which includes plans to conduct targeted outreach and recruitment activities to ensure a viable and manageable pool of interested, diverse, and well qualified applicants. After ensuring that recruitment efforts reached targeted applicant pools, if the need remains to offer compensation incentives, BPA should exercise prudence in doing so. Citation: Agency Memorandum, dated March 12, 2012, Prudent use of superior qualifications and advance in hires; and OPM's memorandum dated 21312010, Plan to improve the administration and oversight of Relocation, Retention and Retention Incentives.

~Met I Based on the Department's time and attendance reporting system "ATTAPS", BPA actively participates in DOE's Flexi-place program by authorizing some employees to telework in

D Not Met I remote locations. This can potentially attract highly qualified candidates in applying for the position.

D Partially Met

30

Recruitment, hiring, and merit promotion processes adhere to the merit system principles in 5 U.S.C. 2301 and follow other pertinent legal and regulatory requirements, including other congressionally-mandated enabling legislation.

Effective use of the American Recovery and Reinvestment Act direct hiring authority and other strategies to assist the organization's mission in meeting the Departments ARRA hiring initiatives. Retention policies and practices adhere to merit system principles and other Federal laws, rules, and regulations.




LJ Met C8J Not Met

0 Partially Met

Not Applicable

1:8] Met

D Not Met

D Partially Met

The HCMAP team identified approximately 54% of cases reviewed that contained major violations such as cases in which applicants did not receive the appropriate consideration, and in which veterans' preference laws and/or merit system principles were violated. In more than half of these cases BPA contractors were selected. The infractions in these cases were the result of a many erroneous practices and procedures used by BPA staff that included changing the Best Qualified cut-off scores in Category Rating cases after announcements were published, inappropriately disqualifying applicants due to overly restrictive specialized experience requirements, and using applicant responses to individual KSA's as a basis for screening applicants out. As a result, all hiring cases between FY 1 O and FY13 will have to be further evaluated and reconstructed, to identify any additional illegal appointments and provisions of priority consideration for applicants for the next, like or similar vacancies.

Required Action: Reconstruct all hiring case files between FY10 and FY13, provide a response to the Human Capital Policy Division on the overall outcome of each case; regularize any illegal appointments identified; and offer of priority consideration or priority placement, as applicable to the identified disadvantaged candidates. Citation: 5 USC 1104{ c ), 5 USC 2301 (8) (1 ), 5 USC 2302 (b)(11) and (12). BPA did not actively participate in the use of the American Recovery and Reinvestment Act during this review period.

BPA's retention policies adhere to merit system principles and the Departments guidance.

31




Recruitment and Placement review includes the following factors: Delegated Examining:

• Overall Content of Vacancy Announcements • Case Examining files (applications and supporting documentations) Coding and Processing of Hiring Actions • Job Analysis Conformance with Uniformed Guidelines and Evaluation Criteria • Selectee(s) application and certificate of eligible's

Merit Promotion and Internal Placement • Overall Content of Vacancy Announcement • Case file (applications and supporting documentation) • Coding and Processing of actions (competitive promotions, reassignments, transfers and reinstatements) • Job Analysis and Evaluation Criteria Conformance with Uniformed Guidelines • Selectees application and certificate of eligibles

Superior Qualification - Appointments above the minimum rate • Justification and Supporting documentation

Recruitment and Relocation Incentives • Justification oackaaes and Suooortina documentation

32




• Alignment with Mission Critical Occupations along with staffing plans Di rect Hiring Authorities to include ARRA hiring initiatives

• Appropriate use of any direct hiring authorities for Procurement and IT Specialist vacancies or any approved designated positions the Department has authorized the use of direct hiring.

Documented job-analysis process that are valid (as I D Met defined in the Uniform Guidelines) are used as a

The HCMAP team found well-documented job analyses for most of the cases reviewed. However, many cases that were announced outside of BPA's internal workforce contained overly restrictive KSA's which required overly restrictive, organizational specific knowledge not attainable outside of the Federal workforce. In addition BPA erroneously used KSA's as screenout factors in many of the case files reviewed.

basis to identify objectives, assessable KSA's and/or I ~ Not Met competencies appropriate to the positions being filled, including any selective placement factors for both Merit Promotion and Delegated Examining. In addition to the Job Analysis, the appropriate qualification standard should be included in the case examining file.

Assessment criteria (e.g., crediting plans, occupational questionnaires) are aligned with job analyses; they make clear and appropriate distinctions between creditable levels of qualifications and do not contain in appropriate measures (e.g., knowledgeable peculiar to agency regulations or processes which could be learned relatively quickly). Hiring Management (when used) contained

D Partially Met

Required Action: Develop job analysis and crediting plans that have a rational relationship between performance in the position to be filled and the employment practice used. Use certification requirements that are not overly restrictive so that competition is fair and open. Discontinue the practice of eliminating candidates from consideration for failing to identify or address a particular knowledge, skill and/or ability.

Required Action: Include a signed copy of a job analysis and crediting plan in all delegated examining and merit promotion case files. Rate and rank candidates using valid job analysis that are conducive to the Uniform Guidelines. Citation: 5 USC 2301 (b) (1) and 5 CFR 300.103 (a) and 5 CFR 300.103 (b).

D Met I The cases reviewed had crediting plans which were based on the job analysis. KSA quality levels were clearly defined and allowed for quality level distinctions among the

~ Not Met I applicants. However, there were also many external recruitment cases in which the KSA's were too narrowly defined, requiring knowledge which could only be obtained

D Partially Met I through employment at BPA. In addition, BPA continues to use assessment criteria that are against and/or not in compliance with the Hiring Reform. Pervasive use of KSA's and requiring applicants to respond to KSA's with written narratives at the time of application is prohibrted.

33




retrievable documentation that links job-related KSA's with a job analysis and the supplemental questions Required Action: Ensure that all rating factors are measurable. Rate, rank and refer upon which applicants are evaluated. candidates solely on the basis of the relative ability, knowledge and skills of the position,

after fair and open competition. Citation: 5 U.S.C. 2301 (b) (2) and 5 U.S.C. 2301 (b) (1).

Required Action: Discontinue the practice of requiring applicants to respond to KSA's with written narratives at the time of application. Citation: Improving the Federal Recruitment and Hiring Process, dated May 11, 2010.

Public notice and merit promotion vacancies meet 0Met Overall, the vacancy announcements were posted on www.USAJobs.gov and applicants legal and regulatory requirements, including posting were given a sufficient length of time to ensure fair and open competition. Most of the on USAJobs. Length of open periods is appropriate ~Not Met announcements identified the duties, qualification requirements and other pertinent to the type of positions announced and to the relevant information to help facilitate the application process from interested candidates. However, applicant pools. Vacancies opening and closing D Partially Met improvement is needed with the internal vacancy announcements pertaining to the periods are valid and adequately justified. Vacancy identification and definition of well qualified requirements for CTAP purposes and announcements include a definition of well qualified ensuring that the announcement states the basis of rating. In addition, for public notice for CTAP/ICTAP eligibles in addition to identifying all announcements, there are many cases in which the specialized experience is overly required information from applicants and restrictive and overly baring, potentially skewing the applicant pool or hindering the ability distinguished specialized experience that fits the for fair and open competition. applicant pool (meaning not to agency specific or restrictive thus limiting the qualified applicant pool) . Required Action: Specialized experience statements: All specialized experience

statements should be clearly distinguished per grade level. Each grade level should have a meaningful level of experience required for each position, at each grade level, keeping in mind the requirements highlighted in Qualification Standards, Policies Instructions, section E. Citation: Qualification Standards, Policies Instructions, section E.

Required Action: Prepare vacancy announcements consistent with public notice requirements. Ensure announcements include the number of positions to be filled (or a standard statement, e.g., number of positions subject to change) and the appropriate Equal Employment Oooortunity Statement that includes sexual orientation as prescribed

34




in 5 CFR 330.707 and Executive Order 13087. Avoid using language not relevant to the competitive process, e.g., Time in Grade on public notice vacancy announcements. Ensure merit promotion announcements clearly identify the area of consideration and the definition of well qualified as it pertains to CTAP/ICTAP eligibles. Citation: 5 CFR 330.707 and Executive Order 13087

Policies and procedures on acceptance and 0Met SPA has policies and procedures in place for accepting and processing applications from processing of applications, including from status status applicants and such instructions are specified in the vacancy announcements. applicants, are appropriate, specified clearly in ~Not Met There is also an active policy or standard operating procedure that contains information vacancy announcements, and consistently applied. on accepting late applications from 10-point preference eligibles. However, BPA HCM There is an active policy or standard operating D Partially Met staff consistently misapplied category rating throughout the period by the changing the procedure that contains information on accepting late cut-off scores tor the Best Qualified category (i.e., applicants referred to selecting official) applications from 10-point preference eligibles. after vacancy announcements were published. In many instances the cut-off score was

changed to as high as 99 or 100 points, and it was also noted that for positions that had career ladders the cut-off scores were changed to different scores for each grade level of the position. This practice resulted in an extremely high volume of violations of veterans' preference, and merit system principles, and many illegal appointments. When BPA changed its procedures for Category Rating in mid-2012, the new direction to HCM still employed the erroneous practice of changing the cut-off scores but required HCM staff to prepare written justification to HCM leaders. Additionally, erroneous information was included regarding the merging of categories in the 2010 SOP for Category Rating that was used for a majority of the audit review period.

Required Action: Immediately discontinue any practice of altering the cut-off score after the job announcement has been posted. BPA's operating procedural guidance must be re-written to comply with Federal regulations and agency policy regarding the acceptance of applications and the Category Rating process. Consult and work with the Office of Human Capital Management, Human Capital Policy Division (HC-11) to ensure that polices are aligned with the Department's, OPM and Title 5 regulatory requirements.

Delegated Examining and Merit Promotion case files ~Met Most Delegated Examining and Merit Promotion case files were organized and readily are organized and readily available (with all available for review. Most supporting documentation was obtainable, thus giving the

35




information needed to reconstruct case files) . In addition, supporting documentation is included in file along with timely and accurate notices of results.

LJ Not Met I HCMAP team the ability to reconstruct cases where applicable. There were however, many cases that the team was unable to render a conclusion, although they were

D Partially Met I reconstructable.

DE operations reflect adherence to the expectations I D Met of the Pledge to Applicants that enable rather than deter applicants from applying for vacancies (e.g ., I [8] Not Met plain-language vacancy announcements with clear application procedures; meaningful definitions of I D Partially Met qualifying specialized experience specific to positions advertised; clear descriptions of evaluations methods; timely applicant updates on status of applications; and timely hiring process).

Training and comprehension: Federal staff members I D Met conducting competitive examining have a current DE certification from OPM and a clear understanding and I [8] Not Met applicability of internal and external recruitment process. D Partially Met

BPA's use of Delegated Examining disregarded the adherence to the Pledge to Applicants. BPA's processes deterred applicants from applying for vacancies and or obstructed the merit system principles of many applicants. While some of BPA's announcements allowed meaningful distinction of specialized experience, in some cases the specialized experience and/or qualification requirements were overly restrictive and not appropriately applied. In addition, BPA continued to use and required applicants to respond with narrative essay answers to KSA's (contrary to the requirements of the Hiring Reform) that resulted in many applicants losing consideration for position for which they would otherwise have qualified for. Up until mid 2012, BPA continued to use an antiquated manual recruitment process (in spite of what was recommended to them in 201 O) that could have skewed the applicant process and deterred applicants from applying for BPA positions.

Required Action: BPA must adhere to the Pledge to Applicants, the Presidential Hiring Reform of 2010, and to any Departmental or OPM policies relating to Delegated Examining and Category Rating.

All of BPA's HR Specialist's who performs DE functions have been de-certified by the Office of Personnel Management as a result of a lack of institutional/fundamental knowledge in the core areas of delegated examining, merit promotion and qualification determinations.

Required Action: Direct all HR Specialist's that are involved with every aspect of Delegated Examining and Merit Promotion to take the following courses (at minimum): Basic Staffing, Classification, Job Analysis and KSA Examining, Delegated Examining

36




Recruitment activities use appropriate sources in an I LJ Met endeavor to achieve a diverse applicant pool from all segments of society. I D Not Met

~ Partially Met

Late applications are appropriately reviewed to I ~ Met determine if they meet valid exceptions and are processed accordingly and consistently. In case- I D Not Met examining situations, late applications from 10-point preference eligibles are retained and referred for I D Partially Met future vacancies as appropriate. The application process complies with the merit I D Met system principles and related legal requirements. For example, appropriate qualification standards are I ~ Not Met used; applicants with comparable qualifications receive appropriate and comparable treatment. I D Partially Met

Training, Qualification Analysis and Pay Setting. It was not clear from a staffing perspective if BPA makes a concerted effort to reach out to diverse applicants from all segments of society.

Recommendation: Work with HC-13, Employment Solutions Division, in order to receive information on the best approach to reach more minority candidates, disabled candidates, and diverse applicants from all segments of society. BPA handles late 10-point preference applicants accordingly. The team found no significant issues in this area.

The application process was not compliant with merit system principles, violated personnel practices and failed to follow the requirements of OPM regulatory guidance. In addition, BPA erroneously applied the category rating process by adjusting the cut-off score (best qualified category) after applications were received and reviewed . This process resulted in several illegal appointments and violation of many applicants' merit system principles.

Required Action: Ensure that all rating factors are measurable. Rate, rank and refer candidates solely on the basis of the relative ability, knowledge and skills of the position, after fair and open competition. Citation: 5 U.S.C. 2301 (b) (2) and 5 U.S.C. 2301 (b) (1).

Required Action: Discontinue altering or modifying the cut-off score after the job opportunity announcement has been posted. Begin to conduct qualification analysis base on the OPM standards. Discontinue the process of using the minimum qualification process as a method to determine who will be among the best qualified. Citation: Memorandum Guidance #10, OPM Qualification Standards, Delegated Examining

37




When a self-assessment rating instrument is used to I D Met rank candidates, applicant responses are checked against other application materials for evidence I ~ Not Met supporting applicant ratings. Appropriate rating adjustments are made and documented. Official I 0 Partially Met transcripts or equivalent documentation support applicants who qualify based on education.

Certification activities for displaced/surplus employees I D Met (ICTAP, CTAP and RPL) are documented and meet requirements, including second reviews and I ~ Not Met notification of otherwise-eligible ICTAP candidates found not well qualified. I D Partially Met

Minimum qualification determinations are documented I D Met and can be reconstructed. Applicable qualification

Handbook, Title 5 CFR 330 and 5 USC 2301. BPA currently does not use self reporting rating instruments nor did they use an automated application system for most of the review period. BPA pervasively used inappropriate rating adjustments in cases of Category Rating and in some cases of Merit Promotion; which ultimately resulted in a number of candidates losing appropriate consideration for available positions.

Recommendation: The HCMAP team strongly recommends the consideration of an automated system in order to facilitate a seamless process of accepting and reviewing applications.

Required Action: Discontinue altering or modifying the cut-off score (best qualified category) after a job announcement has been posted. Begin to conduct qualification analysis based on the OPM standards. Discontinue the process of using the minimum qualification process as a method to determine who will be among the best qualified. Citation: Memorandum Guidance #10, OPM Qualification Standards, Delegated Examining Handbook, Title 5 CFR 330 and 5 USC 2301. The few applicants entitled to CTAP and/or ICTAP received during the review period were handled appropriately. However, we concluded that BPA was not appropriately clearing the Department's RPL process as they were previously instructed during the 2010 HCMAP. In early 2013, BPA implemented an appropriate RPL clearance process.

Required Action: The Department has created a single Reemployment Priority Lists based on geographic locations for which all components within the local commuting area must clear. Case files must be indicative of the RPL clearance. As such, unt il BPA begins to use the Department's intranet sites, they must contact someone in HC-11 to clear RPL before posting any vacancy positions. Citation: 5 CFR 330.201 (b).

BPA failed to apply the qualification standards appropriately in a majority of the cases. Candidates were not considered for lacking overly restrictive requirements and/or

38




standards are applied correctly.

Determinations regarding eligibility for veterans' preference (VP) and/or VEOA are properly made, and individuals with such preference are afforded their legal rights in recruitment, referral , consideration, and selection.

~Not Met I expected key words. SPA failed to real ize the semantics of those key words, which resulted in many applicants losing consideration for positions. SPA also used the

D Partially Met I minimum qualification review process to determine who would be among the best qualified.

Required Action: Ensure that all candidates' qualifications are reviewed and assessed in accordance with the Qualification Standards and any other rating criterion that is directly related to the position being filled. Citation: 5 U.S.C 2301 (b) (1) 5 CFR 300.103.

D Met I There were numerous cases where veterans' preference adjudication was incorrectly applied; and/or veterans' preference was not applied appropriately due to BP A's

~ Not Met I aggressive practice of changing/altering cut-off scores or best qualified categories.

D Partially Met I There were a number of cases identified where veteran candidates were only referred at the lowest grade level for positions advertised at multiple grade levels and when those veterans were clearly qualified at the higher grade levels. There were also numerous cases where veteran candidates were referred at multiple grade levels, but only selected for the lowest of those grade levels. Finally, we found many instances where veteran candidates were selected for positions, but had far more restrictive deadlines required of them to accept offers than non-veteran selectees. The nature and frequency of these occurrences give the perception of disparate treatment of veteran applicants.

Required Action: Certify eligible applicants by grade level and numerical rating (when applicable) augmented by veterans' preference status accordingly. Ensure that veterans' preference is applied and annotated accurately whenever applicable. Citation: 5 USC 3313; 5 CFR 250.101; 5 CFR 250.102 and 5 CFR 332.401.

Required Action: Ensure hiring cases are well documented to demonstrate that all applicants have been treated fairly and equitably during all phases of the hiring process. Citation: 5 USC 2301; 5 USC 2302.

39




Certification procedures involving the "rule of three", I D Met Although certificates are audited upon selection, the team noted many inconsistent methods on how the certificates are issued; lack of information on the certificates; and in many cases, the circumvention of veterans' preference as it relates to category rating.

category rating or internal placement procedures are properly followed and well documented. Selectees I [8J Not Met are qualified for positions.

Certificates are audited and documented by certified staff or trained contractors before appointees entrance on duty. Selections are properly made and actions such as declination or failure to respond are properly documented.

Candidate's interview, selection, and placement practices are "neutral" and do not arbitrarily favor or disfavor specific candidates or types of applicants ..

Decisions to use pay flexibilities for hiring (e.g., recruitment and relocation incentives and superior qualifications and special needs pay setting) are appropriately documented and justified accordingly.

D Partially Met I Required Action: Create certificate of eligibles in accordance with the guidelines indicated in the DEOH, chapter 6. Ensure that the appropriate information is visible on the certificate to include the duty station of the position being filled.

0Met

[8J Not Met

Citation: Delegated Examining Operations Handbook, chapter 6, creating certificate of eligibles.

In a majority of the cases reviewed BPA failed to treat many candidates consistently, fairly, and equitably which resulted in lost consideration for a substantial number of applicants; and a missed opportunity to compete and interview for vacant positions.

D Partially Met I Required Actions: Ensure that all candidates' qualifications are reviewed and assessed in accordance with the Qualification Standards and any other rating criterion that is directly related to the position being filled. Citation: 5 U.S.C 2301 (b) (1) 5 CFR 300.103.

Required Actions: Rate, rank and refer candidates solely on the basis of the relative ability, knowledge and skills of the position, after fair and open competition. Citation: 5 U.S.C. 2301 (b) (2) and 5 U.S.C. 2301 (b) (1).

~Met I Overall, justifications (when applicable) were located in the case files. Typically, justifications were appropriately justified and documented on the corresponding SF-50.

D Not Met I However, in a few cases, the team noted that BPA offered superior qualifications for pay parity purposes only. In a few other cases, the team noted that BPA offered

D Partially Met I compensation incentives for positions that are easily filled and/or has limited difficulties in filling the position with viable candidates. While the team did not find a large number of these instances, even a few cases may present accountability concerns for failing to

40




Established procedures for objections and requesting I LJ Met veteran pass-overs are followed and appropriate action (if any) is taken. I [8J Not Met

D Partially Met

exercise prudence with offering compensation incentives. See OPM's memorandum to CHCO's titled "Plan to improve the Administration and Oversight of Recruitment, Relocation and Retention Incentives dated 21312010.

Required Action: BPA must discontinue the practice of offering recruitment incentives for positions that are easily recruited for and available to fill without past recruitment difficulties, i.e., Human Resource Specialist.

Required Action: Discontinue the practice of using superior qualifications appointment for the purpose of setting pay at a rate comparable with the appointee's non-Federal salary. Clearly document why the appointee's qualifications were truly superior to that of others in the field or factors supporting the superior qualifications of the candidate(s) . Citation: 5 U.S.C. 1104(c) and 5 CFR 531.212.

Recommendation: Ensure that all recruitment incentives are appropriately justified and consistently at all times. To facilitate this process, conduct (or continue to conduct) workforce and trend analysis to determine the most appropriate grade levels to fill all positions and the best sources of applicants. Develop a recruitment strategy which includes plans to conduct targeted outreach and recruitment activities to ensure a viable and manageable intensive pool of interested, diverse, and well qualified applicants.

While BPA has established local policies (an improvement from the 2010 HCMAP) regarding the passover of veterans, they began to use a process (during the category rating implementation) that circumvented the veterans' preference law and allowed for the HR Specialist or Selecting Officials to modify pre-determined categories for best qualified candidates. These cases were found in large numbers and overrode the proper application of a veteran pass-over process. In many cases, this impacted the consideration and priority placement of veteran applicants.

41




Required Action: Consult and work with the Office of Human Capital Management, Human Capital Policy Division (HC-11) to ensure that BPA HCM guidance papers are aliqned with the Department's, OPM and Title 5 requlatorv requirements.

Annual self-audits of DE activities have been 0Met BPA was not conducting the annual self audits for the review period of 2010, 2011 and conducted and performed by staff who are not part of 2012. involved with the DE operations and have current DE [8J Not Met certifications. Required Action: Conduct the Annual Self Audits as required by the Office of

D Partially Met Personnel Management's Delegated Examining Handbook. Citation: Delegated Examining Operations Handbook, Chapter 7, section D.

Appropriate corrective action is taken when cases of LJ Met For those cases in which lost consideration was noted, BPA failed to take appropriate lost consideration or other types of violations are action to remedy the case file by either appointing the candidate or offering them identified. [8J Not Met priority consideration for the next, like or similar vacancy.

D Partially Met Required Action: As soon as an illegal appointment has been identified, contact the Office of HC-11 for remedial guidance. In addition, in cases where lost cons ideration is evident, immediately contact those candidates who failed to receive appropriate consideration and offer priority consideration and/or placement when aooropriate.

SF-50's and 52's are coded accurately and reflects all ~Met Overall, the SF-50's are coded with the correct NOA and legal authorities. A requirements in the Guide to processing personnel actions and the Guide to Personnel Data Standards. D Not Met

significant improvement from the 201 O HCMAP audit.

Official Personnel Folders have accurate documentation in file thus supporting the accession. D Partially Met Security of examining records is proper; applicant [8J Met Examining records are maintained in a locked file room within the access controlled HR information is protected by the Privacy Act is properly office. maintained a safeguarded, and records are 0 Not Met maintained in accordance with the retention schedule.

0 Partially Met The DE coordinator submtts accurate and timely LI Met DE quarterly reports are not being issued timely if at all. quarterly workload reports via OPM's DE Information

42

System.




Not Met Required Action: Begin to issue the Delegated Examining Quarterly workload reports to the Agency's Delegated Examining Coordinator in a timely manner. Citation; Deleaated Examinina Ooerations Handbook, Aooendix C.

Ta lent Management • Position Classification

Standard: The Department's position classification program ensures positions are properly classified and are in compliance with laws, rules, and regulations which contribute to the Department's missions. The review will determine if the organization understands and applies the general concepts, and technical guidance needed to classify positions and interprets OPM's classification standards. The Talent Management System - Position Classification includes the following Critical Success Factors:

The classification program is managed efficiently, effectively and positions are properly classified in accordance with applicable regulations and guides.

Law: Classification Act of 1949, codified in Chapter 51, Title 5, United States Code.

Expected Outcomes of Assessment Findings/Required or Recommended Actions Critical Success Factors

Position{s) mle and series are properly assigned 0Met Of the positions reviewed, the majority were assigned incorrect position titles and and the appropriate classification is selected; series. classification adheres to Federal laws, rules, and [8] Not Met regulations. Required Action: Review all position descriptions associated with hiring cases

D Partially Met between FY1 O and FY13, obtain new or modify position descriptions, as necessary that adequately and accurately describes the work assigned to the position and performed by the employee. Prepare evaluation statements to determine the correct pay plan, title and series of the positions.

43

Grades properly assigned to positions and the appropriate classification is selected; classification adheres to Federal laws, rules, and regulations.

Evaluation statements are on file and discuss how the title, series, and grade were determined, and adhere to Federal laws, rules, and regulations.

Factors are consistent with duties and represent




LJ Met Of the positions reviewed, the majority were assigned incorrect grade levels. In many

~Not Met positions reviewed it was noted that higher factor levels had been assigned to the position descriptions than warranted on the basis of the BPA HCM classifier identifying work performed at BPA, as being agency-level.

D Partially Met Required Action: Review all position descriptions associated with hiring cases between FY 1 0 and FY 13 and obtain new or modify position descriptions, as necessary, so that they adequately and accurately describes the work assigned to the position and performed by the employee. Prepare written evaluation statements to determine the correct pay plan, title, series, and grade of the position.

0Met None of the positions reviewed had evaluation statements that addressed how the title, series, and grade level were determined. While the majority of the positions were

~Not Met written in the Factor Evaluation (FES) format the position descriptions did not address how the position met the assigned factor levels.

D Partially Met Required Action: Review all position descriptions associated with hiring cases between FY10 and FY13 and prepare written evaluation statements for every position that addresses how the pay plan, title, series, and grade level were determined. For positions for which the classification is derived through application of a factor evaluation system standard include a narrative explanation that describes how the position meets the factor level assigned, exceeds the factor level immediately below the factor level assigned, and fails to meet the factor level immediately above the factor level assigned. For narrative based position classification standards ensure the evaluation statement explains how the position meets the narrative level assigned, exceeds the narrative level immediately below the narrative level assigned, and fails to meet the narrative level immediately above the assigned narrative level. Evaluation statements should also address series selection and title determinations.

I I Met For the majority of the positions reviewed, the factors described in the position

44

the position title, series and duties of position. Additionally, factors are consistent with applicable standards (narrative and or factor evaluation system - FES).

FLSA determinations are correctly assigned, and determinations adhere to Federal laws, rules, and regulations. Competitive level codes and functional class (when applicable) are indicated on cover sheet

Local policy/procedures established.




descriptions were not consistent with the duties described. For example, positions [8J Not Met classified to a number of administrative occupations generally had the same

0 Partially Met knowledge requirement in Factor Level 1, Knowledge Required by the Position.

Required Action: Review all position descriptions associated with hiring cases between FY10 and FY13 and obtain new or modify position descriptions, as necessary that adequately and accurately describes the work assigned to the position and performed by the employee. Ensure the factor level descriptions are consistent with the duties assigned to the position. Prepare evaluation statements to determine the correct pay plan, title, series, and grade of the position.

0Met For some positions, FLSA determinations were either incorrectly assigned or not assigned to the position. Competitive levels were not assigned to the majority of the

[8J Not Met positions reviewed. Of the professional positions reviewed, the functional classification code was not always assigned the position.

0 Partially Met

Required Action: Review all position descriptions associated with hiring cases between FY10 and FY13 and ensure correct FLSA codes, competitive levels, and functional classification codes are appropriately assigned.

LJMet Local classification policies and procedures are in place. However, the BPA policy/procedure regarding employee classification appeal rights restricts the appeal

[8J Not Met rights to BPA and OPM; thereby denying employees the right to file classification appeals to the Department of Energy.

D Partially Met Required Action: Revise local classification procedures to ensure employees are aware of their right to file a classification appeal to the Department of Energy. Conduct employee briefings to ensure the BPA workforce is aware of the classification appeal processes available to the federal employees.

45

Position description coversheet properly filled out.

Positions descriptions are recertified in accordance with DOE policy.

New or revised classification standards applied to positions within 12 months of OPM issuance.

Accretion of duties documented, and is consistent with DOE policy.




LJ Met Of the position description coversheets reviewed, none were properly completed. Areas such as position number, level of access, financial statement required,

~Not Met competitive area, and competitive level were not recorded on the coversheet. Also, there were no position description coversheets for employees assigned to BB, BL, and

D Partially Met BS pay plans.

Required Action: Review all position descriptions associated with hiring cases between FY10 and FY13, ensure all General Schedule position description coversheets are properly completed. Provide the Department's Office of Strategic Planning and Policy with documentation which exempts BPA from using coversheets for the BB, BL, and BS positions.

LJ Met Of the GS positions classified over five years ago, none have been recertified.

~Not Met Required Action: Review all position descriptions associated with hiring cases between FY1 O and FY13 and recertify the positions older than five years with the

D Partially Met appropriate supervisors.

LJ Met The servicing human resources office has not yet applied the March 2012 OPM Position Classification Standard for Government Information Series, 0306. The

~Not Met standard should have been applied no later than March 2013.

D Partially Met Required Action: Identify those positions which would be covered by the new standard. Aoolv the standard immediately.

DMet N/A

D Not Met

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Functional duties give an accurate depiction of the position • • • ensures consistency with applicable standards and descriptions.

The organization demonstrates a complete understanding of the overall classification requirements and recognizes levels of difficulty and responsibility in terms of the grade levels established by law. The organization (overall) classifies positions consistent with the criteria and guidance issued by OPM.




I I Partially Met LJMet The majority of General Schedule position descriptions reviewed did not accurately

depict the position's functional duties. For example, the position descriptions cgi Not Met incorrectly characterized BPA as an "agency", thereby artificially inflating the factor

levels used to classify the position. D Partially Met

Required Action: Cease characterizing BPA as an independent agency and ensure new position descriptions portray the organization accurately.

LJ Met Overall, the organization does not fully demonstrate an understanding of the classification process and related classification requirements.

cgi Not Met Required Action: Current classification specialists are required to attend

D Partially Met classification training, with the selected training vendor approved by the Department's Office of Strategic Planning and Policy.

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Bonneville Power Administration Recommended Actions- Talent Management

1. BPA's HCM staff and leadership must foster a closer working relationship with the Department's Chief Human Capital Officer Office, in particular the Human Capital Policy Division. Communications should be initiated prior to entering into any questionable personnel actions or advising management on complex HR issues.

2. BPA's HCM senior HR staff and leaders work closely with the Human Resources Assistants to provide technical guidance and ensure they are aware of all updated policies and/or regulatory requirements that are relevant to their day-to-day operations.

3. Discontinue making selections from expired certificates. If a selection has not been made by the expiration date of a certificate, the Human Resources Specialist should annotate the case file and/or have the selecting official request an official extension.

4. BPA should institute a comprehensive quality control process that will monitor the efficiency of all job opportunity announcements, certificates, qualification reviews, panels and selections. More technical guidance ·and oversight should minimize significant errors and violations of regulations/law.

5. When using multiple recruitment sources, be sure to identify and distinguish different hiring authorities on selection certificates, i.e., non-competitive eligibles vs. competitive eligibles, etc.

6. When posting JOA's via AVUE use separate JOA's for merit promotion and delegated examining announcements. Recently announced positions have been posted with areas of consideration of "All U.S. Citizens", but when advertising under multiple hiring authorities JOA's should read "All Sources" in the area of consideration {AOC) and applicants must be considered under every available source they are qualified for. However, it is recommended to run different hiring authorities under separate announcements to minimize the potential for errors in the rating and management of applications.

7. Currently, BPA's process allows contractors to initiate and complete the JOA process and review of applications and HR Specialists (Federal employees) become involved once a selection has been made. HR Specialists should be

HCMAP BPA Page 1


involved and leading the work throughout all stages of the recruitment process.

8. Review selection certificates before and after selections are made to ensure adherence to applicable merit system principles and veterans' preference laws.

HCMAP BPA Page 2


Personnel Action (SF-50) Corrections Bonneville Power Administration

1. Discontinue the practice of including remark code K18 on every personnel action involving promotions and/or reassignments. K18 should only be used for reassignment actions that are not related to merit promotion or merit assignment procedures. This remark should only be used for non-competitive reassignment actions in which the NOA will be 721 and the legal authority will be N2M. See Guide to processing personnel actions, table 14-K, 14-48.

2. When BPA employees have competed and are selected from public notice vacancy announcements, AND they require a new probationary period, please ensure appropriate remark codes are applied, e.g., E07 You will be in tenure group II until you complete the one-year probationary period that began (date); then you will be changed back to tenure group I.

HCMAP-BPA Page 1

Documents

Department of Energy - oregonlivemedia.oregonlive.com/business_impact/other/BPAreport.DOE.pdf · 2016. 11. 7. · Power Administration (BPA) the week of June 17, 2013. The detailed