Federal Recruiting and Hiring:

Authority for Higher Starting Pay Useful but Guidance Needs Improvement

GGD-91-22: Published: Sep 10, 1991. Publicly Released: Oct 15, 1991.

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Pursuant to a congressional request, GAO reviewed agencies' use of selected personnel authorities delegated by the Office of Personnel Management (OPM), focusing on whether: (1) agencies used the advance in-hire authority in accordance with legal and regulatory requirements; and (2) OPM and agencies had adequately overseen the authority's use.

GAO found that: (1) personnel officials reported that the advance in-hire authority had enhanced their ability to attract highly qualified people and increased the timeliness of personnel actions; (2) adequate controls were necessary to avoid charges of abuse or favoritism, since the advance in-hire authority enables agencies to pay employees holding the same position different starting salaries; (3) during fiscal year 1990, the 10 civilian installations reviewed made 2,324 appointments to GS-11 and above positions, and of those appointments, the agencies made 25 percent using the advance in-hire authority; (4) the advance in-hire salary for 97 of the 99 appointments reviewed was within the governing pay ceiling, and none of the 99 exceeded the highest step of the related grade; (5) because candidates for positions below GS-11 may lack work experience, proving that a candidate possesses superior qualifications or meets a special need may be more difficult than doing so for GS-11 or above positions; (6) written explanations of why candidates qualified for advance in-hire salaries were available for 99 of the 100 appointments, but those explanations lacked the kinds of comparative data necessary for judging whether appointees' qualifications were superior or unique; and (7) at the 10 installations, only limited monitoring occurred.

Recommendations for Executive Action

  1. Status: Closed - Not Implemented

    Comments: OPM's regulations require agencies to develop their own guidelines for approval of advanced hiring rates and to document the reasons for approval in each case. As recommended by the National Performance Review, OPM is abolishing the Federal Personnel Manual. GAO does not believe government-wide guidance is needed beyond the regulatory requirements.

    Recommendation: In order to enhance the agencies' ability to appropriately apply the advance in-hire authority, the Director, OPM, should improve the guidance that agencies must follow in deciding whether to provide advance in-hire salaries. The improvements should include information on the: (1) conditions that define special need; (2) use of comparisons with current employees and who would constitute a group of comparable current employees; (3) need for comparisons when making direct hire appointments; (4) need for adequate documentation to support appointments; and (5) use of the authority in making advance in-hire appointments to GS-1 through GS-10 positions.

    Agency Affected: Office of Personnel Management

  2. Status: Closed - Implemented

    Comments: The agency does not agree that its guidance should be in regulations. The agency is, however, providing more detailed guidance, definitions, and examples of superior qualifications, special need, and existing pay through the Federal Personnel Manual or other issuances.

    Recommendation: In order to enhance the agencies' ability to appropriately apply the advance in-hire authority, the Director, OPM, should place all key elements of the instructions in regulation. This should include how agencies are to determine whether a candidate possesses superior or unique qualifications.

    Agency Affected: Office of Personnel Management

  3. Status: Closed - Implemented

    Comments: Agency use of FEPCA authorities, including the expanded authority for advance in-hire, is now a continuing area of coverage during OPM on-site evaluations.

    Recommendation: In order to enhance the agencies' ability to appropriately apply the advance in-hire authority, the Director, OPM, should more actively monitor, through personnel management evaluations, agencies' use of the authority.

    Agency Affected: Office of Personnel Management

  4. Status: Closed - Implemented

    Comments: Final regulations published October 22, 1991, direct agencies to establish internal guidelines and evaluation procedures and to establish documentation and recordkeepting procedures that allow reconstruction of each case, but do not direct officials to increase personnel management evaluations of the authority's use.

    Recommendation: In order to enhance the agencies' ability to appropriately apply the advance in-hire authority, the Director, OPM, should direct personnel officials of agencies that are major users of the authority to write guidance for installations to follow when using the authority. Such guidance should be predicated on the OPM, guidance but tailored to the respective agency. The Director, OPM, should also direct the officials to more actively make personnel management evaluations of the authority's use.

    Agency Affected: Office of Personnel Management

 

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