The initial dust has settled a bit around the NAPA report on the proposed Office of Personnel Management reorganization, and as a long-time civil service expert (who dares to admit as much!), I must say that, while I agree with its findings and recommendations, the cynic in me suggests that its broader conclusions about the role of that agency have the potential to become yet another case of déjà vu all over again. That is, unless the new OPM director takes a number of concrete (and potentially controversial) actions.

The right answer, as far as it goes, but…

First the good news. As I said, in my humble opinion, the NAPA panel came up with the right answer to the most immediate question: Don’t merge. Leave OPM alone, at least when it comes to its place—and its relative independence—in the Executive Branch.

That wasn’t an easy conclusion to reach, given the all-too-legitimate criticism of OPM’s performance from virtually all of its stakeholders, in part because reorganization is too often the ‘easy button’ in Washington. However, the NAPA panel avoided that temporary relief (to their great credit) and instead, went on to assert that OPM should retool its ‘compliance cop’ culture and become more of a strategic partner to its client agencies.

Maybe I’ve been in the civil service business too long, but the idea that OPM should be a ‘strategic partner’ to federal agencies seems like a rhetorical pronouncement from Captain Obvious … after all, that’s why my former mentor Scotty Campbell proposed an OPM in the first place, and it’s certainly why I went there as its Associate Director for Strategic HR Policy way back in 2002.

But somewhere along the way, OPM veered from that course, and we’re left with a NAPA report that has to remind us of that fact once again. Unfortunately, the NAPA report is just too short when it comes to tangible things the Biden Administration can do to reset that culture, especially if it is to avoid the temptation to swing the pendulum from one extreme to the other.

So what can OPM’s soon-to-be-new leadership do? How can they begin to change its compliance culture, make it more strategic without abandoning the still extant need to promulgate and enforce civil service law and regulation? That’s what I’d like to outline below, and I’ll warn readers now that it may take more than one of these columns to do so, so please bear with me.

Change out OPM’s senior leadership structure  

First, OPM must ‘refresh’ its senior leadership team with individuals that bring experiences from outside OPM, especially at the agency level. That’s happening with the appointment of new leaders in Employee Services and HR Solutions, and I applaud their appointments, but there is a risk that these are seen—by OPM staff and more importantly, agency chief human capital officers—as just another swing of the policy pendulum from right to left. Thus, while I want those new leaders (and the new director, should she be confirmed) to succeed, the ‘refresh mechanism’ must be institutionalized if OPM’s culture is to really change.

How? Start by recompeting OPM’s remaining associate and deputy associate director positions. Open them up for new career talent. For the record, that pains me to suggest that, because I know and respect all of the current ADs and DADs.  But with all due respect, leadership must drive culture change, and leaders who’ve been ‘born and bred’ in OPM may have a hard time seeing that forest for the trees, and by recompeting their jobs, they’ll get the chance to demonstrate that … or not, as the case may be.

And turnabout is fair play. I’d also establish the requirement that agency CHCOs, as well as their bureau-level HR directors, have leadership-level OPM experience as well. In other words, both sets of leaders should have ‘walked a mile in each other’s shoes’ before they’re put in charge of civil service policy and/or operations. And to avoid ‘homesteading’ in either case, I’d announce and fill all of these jobs on a rotational basis, every 2-3 years—think of it as strategic career development—so that no incumbent gets too complacent or stale, or forgets where they came from … and may eventually go back to!

And to sustain all this rotational reassignment program, OPM could manage it via a career development board comprised of current and/or former ‘line’ SES members (as opposed to former CHCOs )—in other words, those who have a stake in ensuring accountability and independence on both sides of the career leadership equation.

There’s precedent, but it won’t be easy

Can this work? I’ve personally seen it succeed three times before, in the Internal Revenue Service, in the Intelligence Community, and even in OPM itself.

In the IRS back in the late 1990’s, Congress—in response to hundreds of cases of alleged taxpayer abuse—mandated the transformation of its culture from compliance to customer service, and I was part of the IRS leadership team brought in to do so. But instead of swinging from one of those two extremes to the other, we tried to strike a delicate balance between the two. In other words, it wasn’t compliance or customer service, but rather we tried to put an ‘and’ between the two.

And one of the ways we did that was to require every one of IRS’s 1500 GS-15s and senior execs to recompete for their jobs, and in so doing, demonstrate (to interview panels and selecting officials, and ultimately, in their performance contracts) that they could strike that balance as well.

To say that that evoked some ire is an understatement (indeed, we were accused of ‘ethnic cleansing’ among other nefarious things), but we stuck by our guns, and while IRS has had its difficulties since, those of us career executives there at the time all agreed that more than anything else, that re-competition helped to change the ‘mindset’ of the Service, from one that was all about compliance to one that tried to strike a balance between that extreme and its customer service counterweight.

I also saw it work in the IC after 9-11, when yet another congressional commission concluded that the failure of the Intelligence Community’s senior leaders to ‘connect the dots’ associated with the terrorist plot stemmed from their historically insular career paths. To remedy that, the commission mandated a civilian version of the US military’s ‘joint duty’ program — that is, requiring one or more interagency assignment as a prerequisite to senior executive rank. Think of it as a sixth executive core qualification.

Congress left most of the details to us (I was part of the IC’s leadership at the time), but we did just that. Not immediately, as we’d done in the IRS—after all, we were at war at the time—and not without much bureaucratic pain and suffering, but over three years and from the top ranks on down, so that eventually, every senior leader in the IC knew what it was like to walk a mile in another agency’s shoes. That requirement, established by regulation rather than by law, exists to this day, and its transformative effects are apparent.

Finally, we did the same thing at OPM in the early 2000s, when Kay Coles James was confirmed as its director. She reorganized OPM, opened up all the agency’s AD and DAD jobs for competition, and made a concerted effort—along with her newly-appointed career leaders to fill their ranks with people who understood the balance between compliance cop and strategic partner. And I believe that it started to work; but alas, that process was never institutionalized, in part the fault of the agency’s career leaders, so OPM reverted. And that’s where it is today.

Play the leadership ‘long game’

All of these transformations depended on the will (and the courage) of their respective leadership teams, both political and career. All of them tried to change the culture of their respective institutions by changing the culture of their career leaders. And at least two of them succeeded. Indeed, that became one of the most long-lasting legacies of the political leadership when they moved on.

To be sure, this takes time—to lay out the ‘refresh’ policy, announce and operationalize it in a way that doesn’t look like a political purge (a la Schedule F), get new leaders in place, and let them do their thing both internally and externally—but as that legendary Washington football coach George Allen once said, the future is now, so it’s time to start building a ‘new’ OPM culture.

With over twenty years of service as a member of the Senior Executive Service, Dr. Ronald Sanders has held senior career positions with DOD, IRS, OPM, and the US Intelligence Community. The former Chair of the Federal Salary Council, he is currently Staff Director for Florida’s Center for Cybersecurity.

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