Commentary by Jeff Neal
Founder of ChiefHRO.com
& Senior Vice President, ICF International

This column was originally published on Jeff Neal’s blog, ChiefHRO.com, and was republished here with permission from the author.

Last week, the Government Accountability Office (GAO) issued a report on the General Schedule. The report, “OPM Needs to Improve the Design, Management and Oversight of the Federal Classification System” outlines eight key attributes of a modern classification system and assesses the degree to which the General Schedule aligns with those attributes. The eight are:

• Internal equity. All employees with comparable qualifications and responsibilities for their respective occupations are assigned the same grade level.
• External equity. All employees with comparable qualifications and responsibilities are assigned grade levels and corresponding pay ranges comparable to the non-federal sector.
• Transparency. A comprehensible and predictable system that employees, management and taxpayers can understand.
• Flexibility. The ease and ability to modify the system to meet agency-specific needs and mission requirements, including modifying rates of pay for certain occupations to attract a qualified workforce within the framework of a uniform government-wide system.
• Adaptability. The ease and ability to conduct a periodic, fundamental review of the entire classification system that enables the system to evolve as the workforce and workplace changes.
• Simplicity. A system that enables interagency mobility and comparisons with a rational number of occupations and clear career ladders with meaningful differences in skills and performance, as well as a system that can be cost-effectively maintained and managed.
• Rank-in-position. A classification of positions based on mission needs and then hiring individuals with those qualifications.
• Rank-in-person. A classification of employees based on their unique skills and abilities.

GAO recognized that some of these attributes appear to be in conflict with one another. For example, classifying positions based upon rank-in-position and based upon rank-in-person appear to be polar opposites. GAO also criticizes the Office of Personnel Management for not having adequate oversight of GS classification, not updating standards frequently enough and not adequately resourcing the program.

OPM partially concurred with most of GAO’s recommendations, but it did not concur on the issue of developing a strategy to systematically track and prioritize updates to occupational standards.

Both GAO and OPM positions have merit. GAO is correct that the GS system is outdated and overly complex. It is right that OPM has not adequately resourced the program. It is right that OPM should address the shortcomings of the GS system sooner rather than later.

OPM is correct in saying it does not need a new process to get classification standards written and updated more regularly. OPM also said it has only six full-time classification policy staff. GAO says OPM has to make tradeoffs the same as any other agency.

That last point is one that I think is important. Yes, OPM has to make tradeoffs. I have not hesitated to criticize OPM when it is off track. In this case, I think it is in a no-win situation. The agency’s recent budget requests show OPM’s appropriated dollars are significantly less than they have been in the past. The agency operates more on revolving funds than appropriations. It also has trust fund money that covers management of retirement and insurance programs.

Those color-of-money distinctions are important, because they limit the number of people OPM can devote to policy and oversight work. While the agency has more than 5,000 employees, less than 20 percent of them can be assigned policy, oversight and agency management tasks. That puts OPM in the position of playing management whack-a-mole with priorities. If they decide to devote far more resources to classification, they will have to come from other programs, leading to those programs being under-resourced.

GAO’s Recommendations

GAO’s report established a good set of criteria for an effective classification system. It also made three recommendations for executive branch action:

• Working through the CHCO Council, and in conjunction with key stakeholders such as the Office of Management and Budget, unions and others, should use prior studies and lessons learned from demonstration projects and alternative systems to examine ways to make the GS system’s design and implementation more consistent with the attributes of a modern, effective classification system. To the extent warranted, develop a legislative proposal for congressional consideration.
• Develop cost-effective mechanisms to oversee agency implementation of the classification system as required by law.
• Develop a strategy to systematically track and prioritize updates to occupational standards.
• Develop a strategy that will enable OPM to more effectively and routinely monitor agencies’ implementation of classification standards.

The first recommendation is the most critical because it could negate the need for at least one of the other recommendations. In recent years, the CHCO Council has become an effective means of driving government human capital policy. A CHCO Council working group, partnering with OMB and with unions (at the national level), could develop a set of policy recommendations that would make the current classification process far less complex, without changing the underlying laws.

That last point is critical — the likelihood of significant Civil Service reform that is enacted by the Congress is remote, due to the combination of congressional dysfunction and a lack of appetite for Civil Service reform.

Reform Does Not Require Congress to Act

How would we dramatically change GS classification without rewriting the law? Most people think the highly complex GS system is entirely a creation of the Classification Act of 1949 (as amended). It is true that the Classification Act created the General Schedule and defines each of the 15 GS grade levels.

Much of the complexity (23 occupational families and 420 job series) comes from policy decisions made by OPM and others in the 65 years since the Classification Act passed. There is no legal requirement to have 420 job series. OPM creates new series when it determines they are necessary, is asked by the White House to do so, gets statutory direction, or they are requested by agencies.

A great example is cybersecurity. There is a lot of pressure (including in the intro of the GAO report) to create a cybersecurity job series. OPM has not done so and with good reason. At the Department of Homeland Security, we had a need for more cybersecurity professionals. They were not in a single job series and could not be. Cybersecurity is a complex field that includes computer scientists, network and systems engineers, security specialists, digital forensics specialists, program managers, intelligence specialists, and about 10 more categories. A single job family cannot address so many different positions that have radically different duties and qualifications requirements.

In fact, GAO points out that the use of 420 job series adds unnecessary complexity to the GS system.

Where we need to go is in the opposite direction. The number of job series should be reduced by at least half and, more likely, by three-quarters. One reason OPM cannot maintain current standards for all of the jobs is that there are too many of them.

GAO also points out that the stovepiping of jobs into narrow series may hamper career growth. So, if we have too many series, we cannot maintain the classification standards because of that, and the number limits agency flexibility on reassigning staff. It also makes for an arduous and overly complex hiring process for applicants from outside government.

If the number of job series is reduced to a more manageable number (I suggest no more than 100), we could achieve most of the objectives of GAO’s eight attributes of a modern classification system. Even some of the apparently conflicting attributes can be addressed.

For example, on the surface it appears we cannot have a system that includes both rank-in-person and rank-in-position attributes. But we can.

Take a look at the Research Grade Evaluation Guide (RGEG) published by OPM. The RGEG includes 4 classification factors:

• Research Assignment
• Supervisory Controls
• Guidelines and Originality, and
• Contributions, Impact, and Stature.

The RGEG recognizes that “work commonly expands commensurate with the researcher’s motivation, capability and creativity.” Evaluation of factor 4 is based upon the researcher’s accomplishments rather than a rigid standard based upon the job itself. The RGEG recognizes that it is difficult to separate the person from the work the person does. OPM could use a similar approach to incorporate both rank-in-person and rank-in-position into new classification standards.

The RGEG also covers research in many fields — there is not an RGEG for physics, one for chemistry, one for medicine, etc. OPM could use a similar approach with multi-series standards to dramatically reduce the number of classification standards it has to write and maintain. For example, a STEM Grade Evaluation Guide could cover many STEM positions. An Administrative Grade Evaluation Guide could cover financial management, human resources, procurement and other administrative positions.

Benefits of Administrative Reform

Administrative reform is faster, more achievable and less likely to veer off into fed bashing than a statutory solution might be. It maintains stability in the legal framework of the Civil Service, yet addresses the Adaptability feature in GAO’s eight attributes. It achieves Simplicity, adopts both Rank- in- Person and Rank-in-Position attributes and should also improve Internal Equity. It certainly demonstrates Flexibility as well.

While we may not be able to get to a completely modern classification system without congressional action, we can certainly improve on what we have today. By pursuing an administrative rather than statutory solution, OPM can begin to rapidly address many of the shortcomings of the existing system. The points of view of key stakeholders, such as unions and the Senior Executives Association, can be taken into account, as can those of good government advocates such as the Partnership for Public Service and the National Academy of Public Administration. The CHCO Council can drive the process, ensuring the resulting changes are implementable and consistent with accomplishing agency missions.

Rather than waiting for the day when Civil Service reform might be achievable in Congress, we can act now. Why wait?

MORE COMMENTARY FROM JEFF NEAL:

A tale of two agencies

Tele- goofing off?

They picked Who? Selecting people to be supervisors

Anything worth buying once is worth buying 10 times?

Jeff Neal is a senior vice president for ICF International and founder of the blog, ChiefHRO.com. Before coming to ICF, Neal was the chief human capital officer at the Department of Homeland Security and the chief human resources officer at the Defense Logistics Agency.

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