Securities and Exchange Commission:

Improving Personnel Management Is Critical for Agency's Effectiveness

GAO-13-621: Published: Jul 18, 2013. Publicly Released: Jul 18, 2013.

Additional Materials:

Contact:

Angela N. Clowers
(202) 512-8678
clowersa@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

Based on analysis of views from Securities and Exchange Commission (SEC) employees and previous studies from GAO, SEC, and third parties, GAO determined that SEC’s organizational culture is not constructive and could hinder its ability to effectively fulfill its mission. Organizations with constructive cultures are more effective and employees also exhibit a stronger commitment to mission focus. In describing SEC’s culture, many current and former SEC employees cited low morale, distrust of management, and the compartmentalized, hierarchical, and risk-averse nature of the organization. According to an Office of Personnel Management (OPM) survey of federal employees, SEC currently ranks 19th

SEC has not consistently or fully implemented effective personnel management. SEC has taken some steps, but most of its efforts were in the early stages and could be enhanced. GAO identified four key areas where continued improvement is needed: of 22 similarly sized federal agencies based on employee satisfaction and commitment. GAO’s past work on managing for results indicates that an effective personnel management system will be critical for transforming SEC’s organizational culture.

  • Workforce planning. SEC has not yet developed a comprehensive workforce plan, including how it identifies its future leaders. Although SEC has taken some steps, such as identifying competency gaps and conducting leadership training, these efforts do not reflect all elements of effective workforce planning outlined in OPM guidance. OPM guidance calls on agencies to develop and implement plans to identify workforce needs and develop future leaders. Without fully implementing such practices, SEC will not be able to make well-informed decisions on how to best meet current and future agency needs.
  • Performance management. SEC’s implementation of its performance management system could be improved. SEC staff expressed many concerns about the system, such as an unclear link between their performance and ratings. SEC provided training to supervisors on how to use the system and obtained staff input on aspects of the system. However, SEC has not fully validated the system with its staff. Also, SEC does not have mechanisms in place to monitor supervisors’ use of the system. By not validating all aspects of the system and establishing mechanisms to hold supervisors accountable for appropriately using it, SEC is missing opportunities to enhance the credibility and effectiveness of its performance management system.
  • Communication and collaboration. SEC has made efforts to improve communication and collaboration (such as creating new subunits to facilitate joint work), but has not yet fully addressed barriers. Moreover, these efforts have not yet addressed all of the problems that the Inspector General found contributed to past enforcement failures. GAO has reported on leading practices that SEC could explore, including sustained management attention. Improving communication and collaboration within SEC is critical to its effectiveness.
  • Personnel management assessment. SEC has not implemented an accountability system to monitor and evaluate its personnel management. According to OPM guidance, such a system helps agencies assess whether personnel policies are effective. SEC officials explained that efforts were under way to develop a system. Until such an accountability system is implemented, it will be difficult for SEC to make necessary improvements and help ensure that its personnel management policies and programs align with its mission.

Why GAO Did This Study

Personnel management is important to the mission of federal agencies. Several high-profile enforcement failures have raised concerns about SEC’s personnel management. Section 962 of the Dodd-Frank Wall Street Reform and Consumer Protection Act mandates GAO to report on SEC's personnel management. This report examines (1) SEC’s organizational culture and (2) its personnel management challenges and efforts to address these challenges.

GAO assessed SEC’s personnel management systems against OPM guidance and other criteria related to workforce planning and performance management (which includes appraisals and feedback); reviewed relevant reports; surveyed SEC employees and senior management (with 78 and 74 percent response rates, respectively) to gather their views on SEC’s organizational culture and personnel management practices; and spoke with former employees, the SEC Inspector General, representatives of the employees’ union, financial industry associations, consulting firms, and academics.

What GAO Recommends

GAO makes seven recommendations to improve SEC’s personnel management, including developing comprehensive workforce plans, implementing mechanisms to monitor how supervisors use the performance management system, conducting periodic validations of the system, exploring collaboration practices of leading organizations, and regularly assessing these efforts. SEC agreed with GAO’s recommendations.

For more information, contact A. Nicole Clowers at (202) 512-8678 or clowersa@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: In July 2016, SEC created a workforce and succession plan consistent with Office of Personnel Management (OPM) guidance, but they do not include some key components of strategic workforce and succession planning identified by OPM and our previous work. For example, the plan lacks a comprehensive skills gap analysis, does not inform decision making about the structure of the workforce, and is not clearly linkd to its budget formulation.

    Recommendation: To help SEC address identified personnel management challenges, and to enhance SEC's ability to strategically hire and retain the appropriate number of staff with the requisite skill sets for today and in the future, the Chairman of SEC should direct the Office of the Chief Operating Officer (COO) and Office of Human Resources (OHR) to prioritize efforts to expeditiously develop a comprehensive workforce plan, including a succession plan, and establish time frames for implementation and mechanisms to help ensure that the plans are regularly updated.

    Agency Affected: United States Securities and Exchange Commission

  2. Status: Open

    Comments: SEC's workforce and succession plan finalized in July 2016 is consistent with some Office of Personnel Management (OPM) guidance, but lacks some key components of strategic workforce and succession planning. SEC's workforce plan is aligned with its strategic plans, references the goals outlined in those plans, and includes performance measures to monitor and evaluate SEC's progress towards its goals. SEC's workforce planing also involves relevant stakeholders, including division and office leadership, SEC University (SEC's lead office for training), and focus groups of SEC employees. However, SEC's workforce plan lacks a comprehensive skills gap analysis. For example, SEC's workforce plan did not include an assessment of the competency of 33 percent of its workforce, including mission-support staff, such as staff in the Office of Human Resources, and supervisors. Further, SEC's workforce plan does not inform decision making about the structure of the workforce and is not clearly linked to budget formulation. For example, the workforce plan does not identify the personnel costs of the current workforce, nor does it identify the number of employees SEC intends to hire and their associated costs. Finally, SEC's succession planning lacks information on workforce attrition and lacks a process for identifying future leaders.

    Recommendation: To help SEC address identified personnel management challenges, and to enhance SEC's ability to strategically hire and retain the appropriate number of staff with the requisite skill sets for today and in the future, the Chairman of SEC should direct the Office of the COO and OHR to incorporate OPM guidance as it develops its workforce and succession plans, by developing a formal action plan to identify and close competency gaps, and fill supervisory positions; and institute a fair and transparent process for identifying high-potential leaders from within the agency.

    Agency Affected: United States Securities and Exchange Commission

  3. Status: Closed - Implemented

    Comments: In December 2016, we found that SEC had implemented mechanisms to monitor how supervisors use the performance management system. First, SEC took steps to monitor the performance feedback supervisors provide to employees. Consistent with OPM guidance, SEC now monitors whether supervisors are providing the required feedback by reviewing a random sample of 5 percent of performance work plans each fiscal year; these work plans contain documentation that the supervisor provided the interim and final performance feedback to the employee. Second, SEC implemented mechanisms to monitor how supervisors recognize and reward performance. SEC's accountability group in the Office of Human Resources took steps to monitor how awards were being distributed to SEC employees, which were consistent with OPM guidance. Third, SEC implemented mechanisms to monitor supervisor practices to address unacceptable performance. Consistent with OPM guidance and federal regulations, SEC supervisors are now required to gather relevant information regarding unacceptable performance of employees they supervise. SEC's Office of General Counsel is responsible for ensuring that supervisors are taking the required steps to address performance issues.

    Recommendation: To help SEC address identified personnel management challenges, and to help enhance the credibility of its performance management system, the Chairman of SEC should direct the COO and OHR to create mechanisms to monitor how supervisors use the performance management system to recognize and reward performance, provide meaningful feedback to staff, and effectively address poor performance; for example, by requiring ongoing feedback discussions with higher-level supervisors.

    Agency Affected: United States Securities and Exchange Commission

  4. Status: Open

    Comments: In 2014, SEC decided to redesign its performance management system without formally assessing it. While SEC's policies state that the Office of Human Resources (OHR) is to perform an assessment of the system on an annual basis, OHR officials told us that SEC has not conducted a formal assessment of the performance management system because the agency is in the process of developing a new system. Since our 2013 report (GAO-13-621), SEC has not reviewed the effectiveness of its existing system and has had limited stakeholder involvement in the development of the new performance management system. In developing this new system, SEC did not assess the existing system to understand if the issues raised by employees were related to the system's design or its implementation.

    Recommendation: To help SEC address identified personnel management challenges, and to help enhance the credibility of its performance management system, the Chairman of SEC should direct the COO and OHR to conduct periodic validations (with staff input) of the performance management system and make changes, as appropriate, based on these validations.

    Agency Affected: United States Securities and Exchange Commission

  5. Status: Open

    Comments: While SEC has created some incentives to support communication and collaboration across divisions, as of December 2016, barriers to cross-divisional communication and collaboration still remain. For example, SEC has implemented some incentives and procedures for staff to communicate and collaborate, such as an annual agency-wide awards program that recognizes outstanding teams and a tracking system that facilitates collaboration on interdivisional memorandums. In addition, one division (the Division of Economic and Risk Analysis) created an electronic system that allows other divisions to request data it collects and another division (the Division of Enforcement) created formal liaisons that other divisions and offices can contact. However, incentives for staff to support an environment of open communication and collaboration are not present for all staff across SEC. SEC has added performance expectations for 53 percent of supervisors to encourage communication and collaboration, including promoting and maintaining an environment of cooperation and proactively sharing relevant information. But these expectations were not present for the remaining 47 percent of supervisors across divisions and occupations.

    Recommendation: To help SEC address identified personnel management challenges, and to build on SEC's efforts to enhance intra-agency communication and collaboration, the Chairman should direct the COO to identify and implement incentives for all staff to support an environment of open communication and collaboration, such as setting formal expectations for its supervisors to foster such an environment, and recognizing and awarding exceptional teamwork efforts.

    Agency Affected: United States Securities and Exchange Commission

  6. Status: Open

    Comments: As of December 2016, SEC has not demonstrated the use of best practices to improve communication and collaboration within and across SEC divisions and offices. SEC officials told us that they reached out to officials at the Federal Deposit Insurance Corporation (FDIC) to discuss how FDIC had obtained high survey scores related to communication and collaboration. This outreach resulted in the creation of SEC's "All Invested" initiative, which SEC described as an initiative to encourage collaboration and communication to help the agency achieve its mission and make SEC the best place in government to work. However, many of the supervisors and staff we spoke with told us that the "All Invested" initiative was more of a marketing campaign than a substantive change. In addition, SEC has established a number of working groups to improve communication and collaboration, but these working groups are often focused on specific topics and do not provide a means for divisions and offices to collaborate on the full range of their day-to-day work activities.

    Recommendation: To help SEC address identified personnel management challenges, and to build on SEC's efforts to enhance intra-agency communication and collaboration, the Chairman should direct the COO to explore communication and collaboration best practices and implement those that could benefit SEC.

    Agency Affected: United States Securities and Exchange Commission

  7. Status: Closed - Implemented

    Comments: In December 2016, we found that SEC had designed and implemented a human capital accountability system, including an underlying plan and standard operating procedures. The system is designed to facilitate regular assessments of SEC's personnel management program. SEC's accountability system requires that staff in the Office of Human Resources review programs, recommend corrective actions, and provide an annual assessment of the progress, consistent with the Office of Personnel Management's (OPM) Human Capital Assessment and Accountability Framework (HCAAF). In addition, the results of SEC's human capital accountability system have informed agency human capital goals and spending priorities, consistent with OPM's HCAAF.

    Recommendation: To help SEC address identified personnel management challenges, and to increase accountability of SEC's personnel management system, the Chairman of SEC should direct the COO and OHR to prioritize and expedite efforts to develop and implement a system to monitor and evaluate personnel management activities, policies, and programs, including establishing and documenting the steps necessary to ensure completion of the system.

    Agency Affected: United States Securities and Exchange Commission

 

Explore the full database of GAO's Open Recommendations »

May 24, 2017

May 18, 2017

Apr 27, 2017

Dec 29, 2016

Sep 1, 2016

Aug 19, 2016

Jun 8, 2016

Mar 24, 2016

Jan 11, 2016

Looking for more? Browse all our products here