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United States Government Accountability Office: 
GAO: 

Human Capital: 

OPM Needs to Better Analyze and Manage Dual Compensation Waiver Data: 

Human Capital: 

Report to the Ranking Member, Committee on Homeland Security and 
Governmental Affairs, U.S. Senate: 

December 2014: 

GAO-15-252: 

GAO Highlights: 

Highlights of GAO-15-252, a report to the Ranking Member, Committee on 
Homeland Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

The federal workforce has a large number of retirement-eligible 
employees that could potentially result in a loss of skills hindering 
federal agencies' ability to meet their missions. Agencies can 
mitigate this challenge by hiring uniformed and civil service 
retirees. Generally, when an agency reemploys a retired civil service 
employee, their salary rate is subject to offset by the amount of the 
annuity received. Upon request, OPM has authority to waive offsets, 
allowing dual compensation (annuity and full salary). Dual 
compensation is also permitted under other authorities not 
administered by OPM, such as the authority provided to Defense. 

GAO was asked to provide information on the use of rehired annuitants 
and OPM's dual compensation waiver authority. This report: (1) 
describes the trends in rehired annuitants for fiscal years 2004 to 
2013; (2) identifies the extent to which OPM analyzes trends in the 
reasons for waiver requests, and provides guidance to agencies, and 
(3) evaluates the extent to which OPM ensures agencies' compliance 
with the conditions under which the waivers were granted. GAO analyzed 
OPM data, reviewed OPM documentation, and interviewed OPM officials. 

What GAO Found: 

Agencies' use of reemployed annuitants has increased, with the number 
of on-board retired uniformed and civil service annuitants increasing 
from over 95,000 in fiscal year 2004 to around 171,000 in fiscal year 
2013 (from about 5 percent to 8 percent of the federal workforce). 
This is inclusive of reemployed annuitants with and without dual 
compensation waivers. The Department of Defense (DOD) accounted for 
about 80 percent of rehired annuitants in 2013; ninety-eight percent 
of which were retired uniformed service members whose retirement pay 
is not subject to reduction. More than half of the total reemployed 
civilian annuitants in 2013, including DOD's civil service reemployed 
annuitants, would not be covered under the Office of Personnel 
Management's (OPM) dual compensation waiver authority. 

Figure: Civilian and Uniformed Service Annuitants in the Federal 
Workforce from 2004 to 2013: 

[Refer to PDF for image: 2 vertical bar graphs] 

Uniformed service annuitants: 

Year: 2004; 
Defense: 71,134; 
Homeland Security: 5,114; 
Veterans Affairs: 6,622; 
Other Chief Financial Officers agencies: 8,449. 

Year: 2005; 
Defense: 79,145; 
Homeland Security: 5,435; 
Veterans Affairs: 6,805; 
Other Chief Financial Officers agencies: 8,471. 

Year: 2006; 
Defense: 84,895; 
Homeland Security: 5,602; 
Veterans Affairs: 7,224; 
Other Chief Financial Officers agencies: 8,309. 

Year: 2007; 
Defense: 89,918; 
Homeland Security: 5,867; 
Veterans Affairs: 7,859; 
Other Chief Financial Officers agencies: 8,386. 

Year: 2008; 
Defense: 97,470; 
Homeland Security: 6,286; 
Veterans Affairs: 8,917; 
Other Chief Financial Officers agencies: 8,581. 

Year: 2009; 
Defense: 108,874; 
Homeland Security: 6,699; 
Veterans Affairs: 10,014; 
Other Chief Financial Officers agencies: 9,046. 

Year: 2010; 
Defense: 121,400; 
Homeland Security: 7,108; 
Veterans Affairs: 10,719; 
Other Chief Financial Officers agencies: 9,416. 

Year: 2011; 
Defense: 130,623; 
Homeland Security: 7,620; 
Veterans Affairs: 11,553; 
Other Chief Financial Officers agencies: 9,786. 

Year: 2012; 
Defense: 133,103; 
Homeland Security: 7,946; 
Veterans Affairs: 12,316; 
Other Chief Financial Officers agencies: 9,987. 

Year: 2013; 
Defense: 132,006; 
Homeland Security: 8,092; 
Veterans Affairs: 13,230; 
Other Chief Financial Officers agencies: 10,232. 

Civilian annuitants: 

Year: 2004; 
Defense: 862; 
Homeland Security: 865; 
Veterans Affairs: 443; 
Other Chief Financial Officers agencies: 1,737. 

Year: 2005; 
Defense: 1,267; 
Homeland Security: 766; 
Veterans Affairs: 451; 
Other Chief Financial Officers agencies: 1,635. 

Year: 2006; 
Defense: 1,683; 
Homeland Security: 835; 
Veterans Affairs: 471; 
Other Chief Financial Officers agencies: 1,411. 

Year: 2007; 
Defense: 2,180; 
Homeland Security: 1,067; 
Veterans Affairs: 611; 
Other Chief Financial Officers agencies: 1,538. 

Year: 2008; 
Defense: 3,061; 
Homeland Security: 1,225; 
Veterans Affairs: 741; 
Other Chief Financial Officers agencies: 1,840. 

Year: 2009; 
Defense: 3,893; 
Homeland Security: 1,340; 
Veterans Affairs: 812; 
Other Chief Financial Officers agencies: 2,477. 

Year: 2010; 
Defense: 4,274; 
Homeland Security: 1,119; 
Veterans Affairs: 784; 
Other Chief Financial Officers agencies: 3,460. 

Year: 2011; 
Defense: 3,993; 
Homeland Security: 1,065; 
Veterans Affairs: 751; 
Other Chief Financial Officers agencies: 2,871. 

Year: 2012; 
Defense: 3,602; 
Homeland Security: 884; 
Veterans Affairs: 747; 
Other Chief Financial Officers agencies: 2,813. 

Year: 2013; 
Defense: 2,891; 
Homeland Security: 617; 
Veterans Affairs: 738; 
Other Chief Financial Officers agencies: 2,779. 

Source: GAO analysis of OPM's Enterprise Human Resource Integration 
(EHRI) and agencies' data. GAO-15-252. 

[End of figure] 

OPM officials said that they do not conduct trend analysis of dual 
compensation waiver requests and they provide related guidance only as 
needed. While OPM is not required to conduct trend analysis, given the 
increasing number of retirement-eligible federal employees, without 
such analysis OPM may be missing opportunities to analyze information 
that can inform decisions about the human capital management tools it 
develops and provides for agencies government-wide. OPM's ability to 
conduct trend analysis is limited by its lack of a systematic and 
reliable process for maintaining dual compensation waiver 
documentation. The lack of policies and procedures is inconsistent 
with federal internal control standards and made OPM unable to timely 
retrieve the documentation for GAO's review. 

OPM is not required by statute to monitor agencies' implementation of 
individual dual compensation waivers to determine whether relevant 
requirements are followed. OPM regulations provide for limited 
oversight in delegated situations, where waiver authority is delegated 
to agencies without a time limit. 

What GAO Recommends: 

GAO recommends that OPM analyze trends in agencies' use of dual 
compensation waivers and establish policies and procedures for 
maintaining waiver documentation. OPM did not concur with the first 
and partially concurred with the second recommendation. GAO maintains 
that OPM should implement these actions as discussed in the report. 

View [hyperlink, http://www.gao.gov/products/GAO-15-252]. For more 
information, contact Yvonne D. Jones at (202) 512-2717 or 
jonesy@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Use of Reemployed Annuitants Increased Between 2004 and 2013 with Most 
Concentrated in the Department of Defense: 

OPM Does Not Conduct Trend Analysis of Dual Compensation Waiver 
Requests and Has Not Developed Policies and Procedures to Manage 
Waiver Documentation: 

OPM Limits Duration of Waivers Approved In Lieu of Monitoring Agency 
Compliance: 

Conclusions: 

Recommendations for Executive Action: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Office of Personnel Management: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Authorized Purposes and Required Evidence for Dual 
Compensation Waiver Applications Submitted to the Office of Personnel 
Management: 

Figures: 

Figure 1: Civilian and Uniformed Service Annuitants in the Federal 
Workforce from 2004 to 2013: 

Figure 2: Aggregate Annualized Salary Rates for Annuitants as a 
Percentage of Agencies' Aggregate Annualized Salary Rates from 2004 to 
2013: 

Abbreviations: 

CFO Act: Chief Financial Officers Act: 

CSRS: Civil Service Retirement System: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

EHRI: Enterprise Human Resources Integration: 

FERS: Federal Employees' Retirement System: 

NDAA: National Defense Authorization Act: 

OPM: Office of Personnel Management: 

PATCO: Professional, Administrative, Technical, Clerical, Blue Collar, 
and Other white-collar: 

VA: Veterans Affairs: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

December 29, 2014: 

The Honorable Tom Coburn, M.D.
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Dear Dr. Coburn: 

The federal workforce is aging. This has created a large number of 
retirement-eligible employees and a potential loss of skills and 
experience that could hinder agencies' ability to meet their missions. 
By September 2017, nearly 31 percent of the federal workforce that was 
on board in 2012 is projected to be eligible for retirement.[Footnote 
1] Increased federal retirements can pose both human capital 
challenges and opportunities to improve workforce planning. Strategic 
workforce planning that is integrated with broader organizational 
strategic planning is essential for ensuring that agencies have the 
mix of talent, skill, and experience they need to execute their 
missions cost-effectively and to achieve program goals, especially as 
agencies face long-term fiscal constraints. 

One tool federal agencies can use to help mitigate this challenge is 
to rehire retired employees with critical skills and talent. When an 
employee retires, assuming he or she qualifies under the federal 
retirement system statutes administered by the Office of Personnel 
Management (OPM), that retiree receives an annuity. Generally, when an 
agency rehires a retired civil service employee who receives an 
annuity (an annuitant), his or her salary rate is subject to a 
reduction (offset) by the amount of the annuity. By law, agencies may 
request a waiver of the salary offset from OPM for specific purposes. 
[Footnote 2] If such a waiver is granted, the result is sometimes 
described as "dual compensation" (the annuity plus the full salary). 
Dual compensation may also be permitted under other authorities not 
administered by OPM (e.g., the Department of Defense authority under 5 
U.S.C. § 9902(g)). 

You asked us to provide information on reemployed annuitants in the 
federal workforce and OPM's management of its dual compensation waiver 
authority. This report: (1) describes the trends in all reemployed 
annuitants for fiscal years 2004 to 2013; (2) identifies the extent to 
which OPM analyzes trends in the reasons for dual compensation waiver 
requests under its authority, and provides guidance to agencies, as 
appropriate; and (3) evaluates the extent to which OPM ensures 
agencies' compliance with the conditions under which the waivers were 
granted. 

To describe the trends in agencies' use of all reemployed annuitants--
both individuals who did and did not receive dual compensation, 
including retired uniformed service members whose retirement or 
retainer pay is not subject to reduction[Footnote 3]--we analyzed data 
from OPM's database, the Enterprise Human Resources Integration (EHRI) 
Statistical Data Mart, for fiscal years 2004 to 2013.[Footnote 4] We 
compared data on the number of annuitants and their types of 
occupations to all federal employees. In addition, we conducted 
interviews with OPM officials and reviewed our prior reports on 
workforce issues. To evaluate the extent to which OPM analyzes trends 
in the reasons for waiver requests under its authority and provides 
related guidance, we reviewed OPM's policies and procedures for 
evaluating waiver requests, analyzed documentation from OPM, and 
interviewed officials. To evaluate the extent to which OPM ensures 
compliance with conditions under which the waivers were granted, we 
reviewed relevant statutes, regulations, and OPM's policies and 
procedures for reviewing waiver requests, and we interviewed OPM 
officials. We also reviewed the 16 waiver decision letters that OPM 
was able to provide. According to OPM officials, the waivers were 
selected to represent examples of the different purposes for which 
waivers may be authorized. We were unable to assess whether the 
examples OPM provided were representative of the universe of waiver 
requests because of the conditions in which OPM maintains the files. 
We compared information gathered from reviewing these letters as well 
as interviews with OPM officials to the statutory and regulatory 
provisions, OPM's policies and procedures, and internal controls 
standards for the federal government.[Footnote 5] For more information 
on our scope and methodology, see appendix I. 

For the purposes of this review, we determined that the data used in 
our analyses were reliable. We determined that EHRI was sufficiently 
reliable to report on trends for all reemployed annuitants, but was 
not reliable enough to describe trends among reemployed annuitants 
authorized to receive dual compensation compared to those with salary 
offsets or annuity reductions. Our data reliability assessment 
included reviewing relevant documentation, conducting interviews with 
knowledgeable OPM officials, and conducting electronic testing of the 
data to identify obvious errors or outliers. 

We conducted this performance audit from April 2014 to December 2014 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

OPM may waive application of the salary offset requirement for 
reemployed annuitants--thereby permitting dual compensation--pursuant 
to 5 U.S.C. § 8344(i) and § 8468(f).[Footnote 6] Under these 
authorities, agencies may request that OPM waive the offset 
requirement for individuals on a case-by-case basis, or, that OPM 
delegate to the agency head the authority to waive the offset 
requirement for individuals on a case-by-case basis. The statutes 
provide OPM the authority to consider and approve agencies' waiver 
requests. OPM evaluates and may approve agency requests for waivers on 
a case-by-case basis for four authorized purposes: 

* emergency hiring, 

* severe recruiting difficulty, 

* need to retain an individual, and: 

* other unusual circumstances. 

OPM evaluates and may approve agency requests for delegation of 
authority to waive salary offsets on a case-by-case basis for two 
authorized purposes: 

* emergency hiring and: 

* other unusual circumstances. 

Agencies requesting waivers or waiver authority must provide purpose-
specific information about the circumstances for which the waiver or 
authority is requested, as summarized in table 1. 

Table 1: Authorized Purposes and Required Evidence for Dual 
Compensation Waiver Applications Submitted to the Office of Personnel 
Management: 

Authorized purpose: Severe recruiting difficulty; 
Required evidence: This authority is used to bring back a former 
federal employee who is now an annuitant. Agencies must provide a 
description of the length, breadth and results of the agency 
recruitment efforts for the position, including details of the 
agency's recruiting efforts and an explanation for why it did not make 
a selection. Agencies are also required to describe the extent to 
which they used recruitment incentives to help fill this position and 
justify the exceptional difficulty in recruiting a qualified 
candidate. Agencies may use other factors to demonstrate that a 
legitimate recruiting need cannot be met without the requested waiver, 
including unusual qualification requirements or working conditions, 
possibility of job reengineering or contracting, or a need to fill the 
position without further delay. 

Authorized purpose: Need to retain a particular individual; 
Required evidence: This authority is used to retain an employee who is 
currently working for the agency and has indicated that he or she is 
going to retire. It is intended to permit the employee to complete 
ongoing work. Agencies must describe the critical nature of the 
project for which the individual is needed and how it relates to the 
agency's mission. Agencies must also describe the potential costs of 
the project failure or delay, any legislative or presidential 
deadlines, and any other factors which demonstrate how the project is 
unusually critical. The agency must also describe how the individual 
is uniquely qualified and the essential knowledge, skills, and 
abilities of the individual and show that these abilities could not be 
acquired by another appointee within a reasonable amount of time. 
While an agency in this situation is not required to conduct outside 
recruiting, the request for exception must address why the work could 
not be assigned to other employees involved with the same project. The 
agency must show that it will lose the individual's services unless 
the waiver is granted. 

Authorized purpose: Emergency hiring; 
Required evidence: This authority is used to bring back a former 
federal employee who is now an annuitant. Agencies must describe the 
military threat, natural disaster, or other unforeseen occurrence 
(e.g., an outbreak of pandemic influenza) for which the individual's 
services are needed, or for which the delegation is needed. Agencies 
must describe how the emergency poses a direct threat to life or 
property. For individual waivers, agencies must describe how the 
individual is uniquely qualified for the emergency response work or 
explain how the number of positions to be filled or the urgency of 
response justifies the necessity of the appointment of the individual 
without further delay. 

Authorized purpose: Other unusual circumstance; 
Required evidence: This authority is used to bring back a former 
federal employee who is now an annuitant. Agencies must describe the 
unusual circumstance, when it first occurred, the length of time the 
agency expects the unusual circumstance to last, and its impact on the 
agency's ability to meet mission requirements. OPM also asks agencies 
to explain how or why the unusual circumstance could not have been 
avoided, anticipated, or addressed prior to submitting the waiver 
request. For individual waivers, agencies must describe the unique 
knowledge, skills, and abilities possessed by the individual that are 
essential and could not be acquired by another appointee within a 
reasonable amount of time. 

Source: GAO summary of OPM guidance. GAO-15-252. 

[End of table] 

In order to obtain delegated authority to waive salary offsets, an 
agency must describe an emergency or other unusual circumstance 
comparable to the third and fourth categories above. In addition to 
the purpose-specific information, agencies must identify the 
occupations, grades, and locations of positions that might be filled 
under the delegated authority and provide a statement of expected 
duration of reemployment to be approved under the requested authority. 
For individual requests, agencies must identify the individual for 
whom the exception is requested, the appointing authority to be used, 
and the position to which he or she will be appointed. In addition, 
the agency must demonstrate that the annuitant will not agree to 
reemployment without the waiver. Agencies may also seek to extend 
previously granted delegated authority. 

Under 5 C.F.R. 553.201(g), agencies may also request extensions for 
previously granted individual waivers. Agencies must show that the 
conditions justifying the original waiver still exist. During this 
process, OPM asks the agency for the reason why an extension is needed 
and why other staffing options were unavailable. 

Should the delegated agreement between OPM and the agency permit the 
agency to renew individual waivers granted by the agency, the agency 
may grant an extension of individual waivers. 

There are other authorities permitting dual compensation for which OPM 
does not exercise approval authority or otherwise regulate. For 
example, government-wide waiver authority was contained in the 
National Defense Authorization Act (NDAA) for Fiscal Year 2010 and 
allows agencies to waive offset requirements on a temporary basis. 
[Footnote 7] Although that authority was set to expire in October 
2014, Congress recently passed an extension of that authority through 
December 2019. In 2012, we reported on the use of the NDAA authority 
and a few examples of other waiver authorities which OPM does not 
manage, including waiver authorities unique to Foreign Service 
annuitants and the Nuclear Regulatory Commission.[Footnote 8] 
Additionally, the Department of Defense (DOD) does not seek waiver 
approval from OPM because DOD has its own authority which permits the 
reemployment of annuitants without subjecting salaries to offset. 
[Footnote 9] 

Use of Reemployed Annuitants Increased Between 2004 and 2013 with Most 
Concentrated in the Department of Defense: 

Our analysis of OPM's data indicate that agencies' use of reemployed 
annuitants has increased, with the number of on-board uniformed and 
civil service annuitants rising from over 95,000 in September 2004 to 
around 171,000 in September 2013 (from about 5 percent to 8 percent of 
the federal workforce).[Footnote 10] This is inclusive of reemployed 
annuitants with and without dual compensation waivers, as well as 
retired uniformed service members whose retirement or retainer pay is 
not subject to reduction.[Footnote 11] More than half of these 
reemployed civilian annuitants, specifically DOD's civil service 
reemployed annuitants, would not be covered under OPM's waiver 
authority. DOD accounted for 83 percent of the increase in annuitants 
from 2004 to 2013--of this increase, approximately 3 percent were 
civil service annuitants and about 98 percent were uniformed service 
annuitants. In comparison, our analysis of OPM's data found that the 
overall size of the permanent career federal workforce, as reflected 
in the number of employees in the 24 Chief Financial Officers (CFO) 
Act agencies, increased about 11 percent over the same period and that 
DOD accounted for about 40 percent of this increase.[Footnote 12] The 
increase in reemployed annuitants reflects agencies' greater reliance 
on all types of annuitants, including former uniformed service members 
covered by military pension systems as well as retirees from federal 
civilian service covered by the Federal Employees' Retirement System 
(FERS) and the Civil Service Retirement System (CSRS). Use of 
annuitants was concentrated in the three largest agencies--DOD, 
Veterans Affairs (VA), and Homeland Security (DHS)--which collectively 
employed about 92 percent of annuitants in 2013, with nearly 80 
percent employed at DOD alone. Most of the increased reliance on 
annuitants in DOD is tied to reemployment of uniformed service 
members: 98 percent of DOD's annuitants were retired uniformed service 
members. 

Our analysis also indicates that the other 21 CFO Act agencies saw 
increases in reemployed annuitants, as well. For these agencies, the 
number of on-board annuitants increased from over 23,000 in 2004 to 
about 36,000 in 2013 (about 2 to 3 percent of these agencies' 
workforce). Although these agencies collectively relied more heavily 
on civil service annuitants than VA and DHS, reemployed uniformed 
service members still comprised nearly 79 percent of the on-board 
annuitants among these agencies in 2013. Greater reliance on 
annuitants suggests recent losses in key staff and institutional 
knowledge due to retirement. The number of voluntary retirements at 
the 24 CFO Act agencies increased in recent years, from 41,735 
employees in 2004 to 58,313 in 2013 (2.4 to 3 percent of these 
agencies' workforce). In addition, many of these agencies experienced 
hiring freezes between 2011and 2013, limiting their options for 
replacing staff who retired or separated for other reasons. In 
response to these circumstances and the increasing size of the 
retirement eligible workforce--about 30 percent eligible to retire in 
five years--agencies appear to have turned to annuitants to bridge 
potential staffing gaps.[Footnote 13] Figure 1 shows the number of 
annuitants in the federal workforce from 2004 to 2013. 

Figure 1: Civilian and Uniformed Service Annuitants in the Federal 
Workforce from 2004 to 2013: 

[Refer to PDF for image: 2 vertical bar graphs] 

Uniformed service annuitants: 

Year: 2004; 
Defense: 71,134; 
Homeland Security: 5,114; 
Veterans Affairs: 6,622; 
Other Chief Financial Officers agencies: 8,449. 

Year: 2005; 
Defense: 79,145; 
Homeland Security: 5,435; 
Veterans Affairs: 6,805; 
Other Chief Financial Officers agencies: 8,471. 

Year: 2006; 
Defense: 84,895; 
Homeland Security: 5,602; 
Veterans Affairs: 7,224; 
Other Chief Financial Officers agencies: 8,309. 

Year: 2007; 
Defense: 89,918; 
Homeland Security: 5,867; 
Veterans Affairs: 7,859; 
Other Chief Financial Officers agencies: 8,386. 

Year: 2008; 
Defense: 97,470; 
Homeland Security: 6,286; 
Veterans Affairs: 8,917; 
Other Chief Financial Officers agencies: 8,581. 

Year: 2009; 
Defense: 108,874; 
Homeland Security: 6,699; 
Veterans Affairs: 10,014; 
Other Chief Financial Officers agencies: 9,046. 

Year: 2010; 
Defense: 121,400; 
Homeland Security: 7,108; 
Veterans Affairs: 10,719; 
Other Chief Financial Officers agencies: 9,416. 

Year: 2011; 
Defense: 130,623; 
Homeland Security: 7,620; 
Veterans Affairs: 11,553; 
Other Chief Financial Officers agencies: 9,786. 

Year: 2012; 
Defense: 133,103; 
Homeland Security: 7,946; 
Veterans Affairs: 12,316; 
Other Chief Financial Officers agencies: 9,987. 

Year: 2013; 
Defense: 132,006; 
Homeland Security: 8,092; 
Veterans Affairs: 13,230; 
Other Chief Financial Officers agencies: 10,232. 

Civilian annuitants: 

Year: 2004; 
Defense: 862; 
Homeland Security: 865; 
Veterans Affairs: 443; 
Other Chief Financial Officers agencies: 1,737. 

Year: 2005; 
Defense: 1,267; 
Homeland Security: 766; 
Veterans Affairs: 451; 
Other Chief Financial Officers agencies: 1,635. 

Year: 2006; 
Defense: 1,683; 
Homeland Security: 835; 
Veterans Affairs: 471; 
Other Chief Financial Officers agencies: 1,411. 

Year: 2007; 
Defense: 2,180; 
Homeland Security: 1,067; 
Veterans Affairs: 611; 
Other Chief Financial Officers agencies: 1,538. 

Year: 2008; 
Defense: 3,061; 
Homeland Security: 1,225; 
Veterans Affairs: 741; 
Other Chief Financial Officers agencies: 1,840. 

Year: 2009; 
Defense: 3,893; 
Homeland Security: 1,340; 
Veterans Affairs: 812; 
Other Chief Financial Officers agencies: 2,477. 

Year: 2010; 
Defense: 4,274; 
Homeland Security: 1,119; 
Veterans Affairs: 784; 
Other Chief Financial Officers agencies: 3,460. 

Year: 2011; 
Defense: 3,993; 
Homeland Security: 1,065; 
Veterans Affairs: 751; 
Other Chief Financial Officers agencies: 2,871. 

Year: 2012; 
Defense: 3,602; 
Homeland Security: 884; 
Veterans Affairs: 747; 
Other Chief Financial Officers agencies: 2,813. 

Year: 2013; 
Defense: 2,891; 
Homeland Security: 617; 
Veterans Affairs: 738; 
Other Chief Financial Officers agencies: 2,779. 

Source: GAO analysis of OPM's Enterprise Human Resource Integration 
(EHRI) and agencies' data. GAO-15-252. 

Note: Data reflect all types of on-board annuitants as of September 
30th of each fiscal year, including annuitants covered by civilian or 
military retirement systems. 

[End of figure] 

Our analysis of OPM data shows that in 2013, 83 percent of on-board 
annuitants were in administrative, technical, or professional 
occupations, which include positions related to administration and 
management, information technology, and engineering, among others. 
Among civil service annuitants on-board in 2013, aggregate annualized 
salaries were highest in DOD, at $113.4 million (0.2 percent of DOD 
employees' aggregate salaries) compared to $246.6 million among the 
other CFO act agencies collectively (or 0.2 percent of employees' 
aggregate salaries). Among uniformed service annuitants on-board in 
2013, aggregate annualized salaries were also highest in DOD, at $10.2 
billion (18.9 percent of DOD employees' aggregate salaries) compared 
to $2.3 billion among the other CFO Act agencies collectively (2.3 
percent of employees' aggregate salaries). Similar to career 
employees, reemployed annuitants generally had full-time schedules. 
However, most civil service annuitants were also on term limited 
appointments, generally serving from one to five years after 
retirement. Figure 2 shows the salary costs of annuitants as a 
percentage of agencies aggregate annualized salary rates. 

Figure 2: Aggregate Annualized Salary Rates for Annuitants as a 
Percentage of Agencies' Aggregate Annualized Salary Rates from 2004 to 
2013: 

[Refer to PDF for image: 2 vertical bar graphs] 

Uniformed service annuitants: 

Percentage of aggregate annualized salary rates: 

Year: 2004; 
Defense: 10.7%; 
Other Chief Financial Officers agencies: 1.6%. 

Year: 2005; 
Defense: 11.7%; 
Other Chief Financial Officers agencies: 1.7%. 

Year: 2006; 
Defense: 12.6%; 
Other Chief Financial Officers agencies: 1.7%. 

Year: 2007; 
Defense: 13.6%; 
Other Chief Financial Officers agencies: 1.8%. 

Year: 2008; 
Defense: 14.6%; 
Other Chief Financial Officers agencies: 1.8%. 

Year: 2009; 
Defense: 15.5%; 
Other Chief Financial Officers agencies: 1.9%. 

Year: 2010; 
Defense: 16.6%; 
Other Chief Financial Officers agencies: 2.0%. 

Year: 2011; 
Defense: 17.6%; 
Other Chief Financial Officers agencies: 2.1%. 

Year: 2012; 
Defense: 18.4%; 
Other Chief Financial Officers agencies: 2.2%. 

Year: 2013; 
Defense: 18.9%; 
Other Chief Financial Officers agencies: 2.3%. 

Civilian annuitants: 

Percentage of aggregate annualized salary rates: 

Year: 2004; 
Defense: 0.1%; 
Other Chief Financial Officers agencies: 0.2%. 

Year: 2005; 
Defense: 0.2%; 
Other Chief Financial Officers agencies: 0.2%. 

Year: 2006; 
Defense: 0.2%; 
Other Chief Financial Officers agencies: 0.2%. 

Year: 2007; 
Defense: 0.3%; 
Other Chief Financial Officers agencies: 0.2%. 

Year: 2008; 
Defense: 0.3%; 
Other Chief Financial Officers agencies: 0.2%. 

Year: 2009; 
Defense: 0.4%; 
Other Chief Financial Officers agencies: 0.3%. 

Year: 2010; 
Defense: 0.4%; 
Other Chief Financial Officers agencies: 0.4%. 

Year: 2011; 
Defense: 0.4%; 
Other Chief Financial Officers agencies: 0.3%. 

Year: 2012; 
Defense: 0.3%; 
Other Chief Financial Officers agencies: 0.3%. 

Year: 2013; 
Defense: 0.2%; 
Other Chief Financial Officers agencies: 0.2%. 

Source: GAO analysis of OPM's Enterprise Human Resource Integration 
(EHRI) and agencies' data. GAO-15-252. 

Note: Data reflect all types of on-board annuitants as of September 
30th of each fiscal year, including annuitants covered by civilian or 
military retirement systems. Percentages are based on the sum of 
annualized salary rates of on-board annuitants compared to those of 
non-annuitants. 

[End of figure] 

OPM Does Not Conduct Trend Analysis of Dual Compensation Waiver 
Requests and Has Not Developed Policies and Procedures to Manage 
Waiver Documentation: 

OPM officials said that they do not conduct trend analysis of dual 
compensation waiver requests because each waiver is so unique that 
there is no trend or pattern to analyze. However, in our review of the 
small sample of 16 waiver request submissions provided by OPM, we 
found that "other unusual circumstance" was among the most often cited 
reasons for requesting a waiver and agencies were requesting waivers 
for individuals in administrative or professional occupations. An 
example of an unusual circumstance cited by agencies requesting a 
delegation is an urgent need to rehire annuitants to support the 
hiring of critical staff. For example, DHS cited a need to rehire 
investigative program specialists to support the hiring of law 
enforcement officers to meet a Congressional mandate. In another 
example, OPM cited a need to hire retired judges to help review 
applications for administrative law judge vacancies. This suggests 
that there may be some benefit to conducting analysis of these waivers 
because there may be trends that OPM is currently not aware of. While 
there is no specific statutory requirement for OPM to conduct trend 
analysis, without such analysis, OPM may be missing opportunities to 
analyze this information that can help guide the human capital 
management tools and guidance it develops and provides to agencies 
government-wide. Ensuring OPM is identifying challenges and assisting 
agencies as issues emerge is especially important given the increasing 
number of retirement-eligible employees across the federal government. 
As we have previously reported, unanticipated retirements could cause 
skills gaps to further widen and adversely impact the ability of 
agencies' to carry out their diverse responsibilities.[Footnote 14] 

With regard to guidance provided to agencies, OPM officials said that 
they occasionally identify or provide other tools or resources for 
human capital workforce management to agencies requesting waivers, but 
they do not do so routinely. For example, OPM may provide information 
on advertising tools or other resources to agencies experiencing 
difficulty hiring qualified candidates. OPM officials said that agency 
officials submitting waiver requests are generally familiar with OPM's 
tools or guidance. However, we have previously found that agencies' 
chief human capital officers were either unfamiliar with some OPM 
tools or guidance, or found the tools or guidance fell short of their 
agencies' needs.[Footnote 15] OPM officials said that on infrequent 
occasions they refer agencies that make repeated requests to extend 
dual compensation waivers to OPM's workforce planning division for 
consultation on how to use its workforce management tools more 
strategically. As we have recently reported, in an era of limited 
fiscal resources, it is critical that OPM and agencies are developing 
and using the most cost-effective tools to ensure agencies can meet 
their missions.[Footnote 16] 

OPM Has Not Developed Effective Policies and Procedures for Managing 
Waiver Request Documentation: 

We found that OPM lacks effective policies and procedures for 
documenting waiver requests which may hamper its ability to conduct 
trend analysis. OPM officials said that they do not have a systematic 
and reliable process for maintaining dual compensation waiver 
documentation. Specifically, OPM officials said they do not have a 
standard policy for how dual compensation waivers are labeled or saved 
and, therefore must individually review thousands of electronic 
documents in their document management system database to identify the 
waiver records. Officials said the waiver requests and supporting 
materials are submitted to OPM and assigned to individuals for 
preliminary review and analysis. OPM staff save these in the document 
management system, but save documents inconsistently, sometimes 
merging the request and documentation and saving the evidence 
separately, without any standard labeling. Officials said that staff 
create a routing slip, called an executive decision summary, for each 
file. OPM staff use the routing slip to record the names of officials 
and dates of their review to recommend approval or denial. However the 
routing slip may or may not be saved with the corresponding waiver 
materials and does not include summary information about the waiver 
request. 

Federal internal control standards state that agencies should clearly 
document significant transactions and events and the documentation 
should be readily available for examination. These actions help 
organizations run their operations efficiently and effectively, report 
reliable information about their operations, and comply with 
applicable laws and regulations. [Footnote 17] Agencies can achieve 
this by developing and implementing policies ensuring accountability 
for records, appropriate documentation of transactions, and sufficient 
information and communication about programs. However, OPM does not 
have such a policy to guide its management of the dual compensation 
waiver files. As a result, OPM was unable to retrieve these files in a 
timely manner for our review. 

OPM Limits Duration of Waivers Approved In Lieu of Monitoring Agency 
Compliance: 

According to OPM officials, OPM does not monitor the agency's 
implementation of an individual dual compensation waiver once a waiver 
is granted. The officials said OPM may require agencies to submit 
documentation before approving delegated waiver authority in order to 
determine whether the agency is complying with relevant requirements. 
OPM officials said OPM's role is limited to application review and 
approval of dual compensation waiver requests and extensions, and that 
it does not have a role in their implementation or oversight. OPM 
officials also said individual and delegated waiver requests may be 
approved, pending specific actions first taken by the requesting 
agency. However, OPM officials said it is the requesting agency's 
responsibility to ensure that it meets the conditions outlined in the 
dual compensation waiver approval letter. Officials said there was one 
exception--OPM requires and reviews evidence from agencies requesting 
approval to extend a previously granted waiver beyond the original 
term to determine if the circumstances justifying the waiver still 
exist. 

The statutory provisions authorizing OPM to grant individual and 
delegated waiver requests do not specifically require OPM to conduct 
oversight or monitoring of how agencies implement the authority 
granted by OPM. However, OPM is generally required to maintain 
oversight over delegated activities under 5 U.S.C. § 1104(b)(2). 
Accordingly, OPM regulations recognize the need for some oversight 
where OPM delegates waiver authority to an agency with no time limit 
on that grant of authority. In those instances, OPM regulations state 
that it may terminate an agency's delegated authority if it determines 
that the circumstances justifying the delegation have changed 
substantially, or if the agency has failed to manage the authority in 
accordance with the law, regulations, or the terms of the agreement. 
[Footnote 18] OPM officials stated that they do establish time limits 
on delegation agreements and, in the one delegated waiver example OPM 
provided for our review, the waiver was authorized for a specific 
period. Given OPM's document management challenges, as previously 
discussed, OPM was unable to provide us with a representative sample 
of waiver approval letters to determine whether OPM consistently 
established time limits on the delegation of waiver authority provided 
to agencies and, if not, whether there were instances where monitoring 
or oversight was necessary. 

Conclusions: 

Given the budgetary and long-term fiscal challenges facing the nation, 
agencies must identify options to meet their missions with fewer 
resources. While federal agencies shoulder this responsibility, OPM, 
through its authority to review and approve dual compensation waivers, 
as well as its responsibility to assist agencies with all aspects of 
human capital management, should identify trends in waiver use and 
develop cost-effective human capital tools and resources, where 
appropriate. These objectives cannot be achieved without analysis of 
dual compensation waiver information. However, OPM has not developed 
adequate policies and procedures for the management of dual 
compensation waiver documentation. Given the increasing use of 
reemployed annuitants and the impending wave of retirements, OPM is 
missing an opportunity to leverage the information gained through the 
review and approval of dual compensation waivers to inform and improve 
upon the assistance it provides federal agencies in their management 
of human capital. 

Recommendations for Executive Action: 

To improve OPM's assistance to agencies and management of its dual 
compensation waiver program, we recommend that the Director of OPM 
take the following two actions: 

1. Analyze dual compensation waivers to identify trends that can 
inform OPM's human capital management tools. 

2. Establish policies and procedures for documenting the dual 
compensation waiver review process. 

Agency Comments and Our Evaluation: 

We provided a draft of this product to OPM for review and comment. In 
written comments, which are reprinted in appendix II, OPM did not 
concur with one recommendation and partially concurred with one. OPM 
also provided technical comments, which we incorporated as appropriate. 

OPM stated that it did not concur with our recommendation to analyze 
dual compensation waivers to identify trends that can inform OPM's 
human capital management tools. OPM noted that the waivers are 
authorized for specific purposes and that the statue does not require 
OPM to conduct any trend analysis. OPM also noted that it does not 
grant a large number of waivers and that those patterns are identified 
when particular circumstances, like natural disasters prompt agencies 
to seek waivers for similar issues. As noted in the report, we agree 
that there are clearly defined purposes and that there is no statutory 
requirement for OPM to conduct a trend analysis. While our analysis 
did find that most of rehired annuitants were likely hired under an 
authority maintained by the Department of Defense, OPM was unable to 
provide evidence of the number of individual or delegated waivers that 
it had approved in any year, including currently active waivers. 
Further, given the likelihood of future agency requests for dual 
compensation waivers for natural disasters, the patterns OPM 
identified after Hurricane Katrina and potential lessons learned are 
evidence of the kind of insight that could be informing OPM's other 
human capital management tools or resources. We continue to believe 
that OPM should analyze waivers and identify trends that could improve 
its other tools. 

OPM stated that it partially concurred with our recommendation to 
establish policies and procedures for documenting the dual 
compensation waiver review process. OPM noted that it has policies and 
procedures for adjudicating waivers and that it is in compliance with 
the National Archives and Records Administration policies. However, 
OPM was unable to provide evidence of any such policies and 
procedures. In fact, OPM could not demonstrate adherence to federal 
internal control standards stating agencies should clearly document 
significant transactions and events and the documentation should be 
readily available for examination. Further, while OPM was able to 
ultimately produce 16 waiver decision letters, it was unable to 
provide a single complete, agency waiver application along with the 
supporting documentation and corresponding OPM decision letter. OPM 
also could not identify the total number of waivers for any given time 
period, meaning that even if OPM individually reviewed the thousands 
of documents in its document management system, it would not know if 
all materials were maintained appropriately. We continue to believe 
that OPM should take action to fully address this recommendation and 
comply with federal internal control standards. 

We are sending copies of this report to the appropriate congressional 
committees and to the Director of the Office of Personnel Management. 
In addition, the report will be available at no charge on the GAO 
website at [hyperlink, http://www.gao.gov]. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 7 days 
from the report date. At that time, we will send copies to the 
Committee on Homeland Security and Government Affairs. In addition, 
the report will be available at no charge on the GAO website at 
[hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report please 
contact me at (202) 512-2717 or jonesy@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made key contributions to 
this report are listed in appendix III. 

Sincerely yours, 

Signed by: 

Yvonne D. Jones: 
Director: 

[End of section] 

Appendix I: Scope and Methodology: 

To analyze reemployed annuitant trends, we used the Office of 
Personnel Management's (OPM) Enterprise Human Resources Integration 
(EHRI) Statistical Data Mart,[Footnote 19] which contains personnel 
action and on board data for most federal civilian employees. We 
analyzed agency-level EHRI data for the 24 Chief Financial Officers 
(CFO) Act agencies, which represent the major departments (such as the 
Department of Defense) and most of the executive branch 
workforce.[Footnote 20] We analyzed EHRI data starting with fiscal 
year 2004 because personnel data for the Department of Homeland 
Security (which was formed in 2003) had stabilized by 2004. We 
selected 2013 as the endpoint because it was the most recent, complete 
fiscal year of data available during most of our review. 

We classified annuitants in two ways: 

1. Military only annuitants (retired uniformed service officers or 
service enlisted members who are receiving retired or retainer pay). 
[Footnote 21] 

2. Military and Federal Employees' Retirement System or Civil Service 
Retirement System annuitants (including individuals with all valid 
EHRI annuitant codes). 

We analyzed on-board trends for most of the executive branch 
workforce, including temporary and term-limited employees. However, we 
focused on career permanent employees in our analysis of separation 
trends and retirement eligibility because these employees comprise 
most of the federal workforce and become eligible to retire with a 
pension, for which temporary and term limited employees are 
ineligible. To calculate the number of federal civilian employees, we 
included all on board staff, regardless of their pay status. In 
addition, we excluded Foreign Service workers at the State Department 
since those employees were not included in OPM data for the years 
after 2004. 

We examined on-board and annuitant counts, voluntary separations, 
adjusted base pay, and retirement eligibility trends by agency, and 
occupation. Occupational categories include Professional, 
Administrative, Technical, Clerical, Blue Collar, and Other white-
collar (PATCO) groupings and are defined by the educational 
requirements of the occupation and the subject matter and level of 
difficulty or responsibility of the work assigned. Occupations within 
each category are defined by OPM. 

To calculate voluntary separation rates, we added the number of career 
permanent employees with personnel actions indicating they had 
separated from federal service with either mandatory or voluntary 
retirement personnel actions and divided that by the 2-year on board 
average. To calculate retirement eligibility for the next 5 years, we 
computed the date at which the employee would be eligible for 
voluntary retirement at an unreduced annuity, using age at hire, years 
of service, birth date, and retirement plan coverage. 

We used the EHRI adjusted base pay to examine the annualized salaries 
of on-board individuals. It is important to note that this amount does 
not necessarily reflect the actual amount annuitants were paid in the 
fiscal year, but rather, the total annualized salary of annuitants in 
the data. 

We assessed the reliability of the EHRI data through electronic 
testing to identify missing data, out of range values, and logical 
inconsistencies. We also reviewed our prior work assessing the 
reliability of these data3 and interviewed OPM officials knowledgeable 
about the data to discuss the data's accuracy and the steps OPM takes 
to ensure reliability. On the basis of this assessment, we believe the 
EHRI data we used are sufficiently reliable for the purpose of this 
report.[Footnote 22] 

To evaluate the extent to which OPM analyzes trends in the reasons for 
waiver requests and provides related guidance, we reviewed OPM's 
policies and procedures for evaluating waiver requests, analyzed 
documentation from OPM, and interviewed officials. 

To evaluate the extent to which OPM ensures compliance with conditions 
under which the waivers were granted, we reviewed relevant statutes, 
regulations, OPM's policies and procedures for reviewing waiver 
requests, and interviewed OPM officials. We also reviewed the 16 
waiver decision letters that OPM was able to provide. According to OPM 
officials, the waivers were selected to represent examples of the 
types of requests for the different authorized waiver purposes. We 
were unable to assess whether the examples OPM provided to us were 
representative of the universe of waiver requests because of the 
conditions in which the files are maintained. We compared information 
gathered from reviewing these letters as well as interviews with OPM 
officials to the statutory and regulatory provisions, OPM's policies 
and procedures, and internal controls standards for the federal 
government.[Footnote 23] 

[End of section] 

Appendix II: Comments from the Office of Personnel Management: 

United States Office of Personnel Management: 
The Director: 
Washington, DC 20415: 

December 17, 2014: 

Ms. Yvonne J. Jones: 
Director, Strategic Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington DC 20548: 

Dear Ms. Jones: 

Thank you for providing the U.S. Office of Personnel Management (OPM) 
the opportunity to comment on the Government Accountability Office 
(GAO) draft report, "GAO-15-252 OPM Needs to Better Analyze and Manage 
Dual Compensation Waiver Data." You recommended that to improve OPM's 
assistance to agencies and management of the dual compensation waiver 
program, the Director of OPM take two actions. Below please find OPM's 
responses to both of these recommendations. 

Recommendation 1: Analyze dual compensation waivers to identify trends 
that can inform OPM's human capital management tools. 

OPM does not concur with this recommendation, because it sees no need 
for such an analysis. The statutes conferring responsibility on OPM 
for certain salary offset waivers, and the regulations promulgated to 
implement those statutes, recognize that such waivers are appropriate 
only in a handful of categories of cases with which OPM is already 
intimately familiar. The statute does not require or even appear to 
contemplate that OPM should conduct any trend analysis of the requests 
we see. And OPM's waiver authority, by definition, is an exception 
from the ordinary rule, designed as a last resort when other options 
are unavailable, and was not, in our view, intended to be used as a 
human capital tool of wide applicability. The number of waivers 
granted by OPM is not large, and the circumstances that prompt 
agencies to seek them out vary from agency to agency and from instance 
to instance, in such a way that individual cases are not likely to 
yield evidence of broad trends going beyond the broad categories set 
out in the governing law. When particular circumstances do prompt 
agencies to seek waivers simultaneously for similar reasons, as 
happened during the period after Hurricane Katrina, for example, and 
again after enactment of the American Recovery and Reinvestment Act of 
2009, OPM is keenly aware. Only a handful of staff handle these 
matters and a broad pattern like this is immediately noticeable. In 
the instances referenced, for example, OPM took steps to make 
agencies' aware of the option and streamline the adjudication of their 
requests. Where we think there may be applicability to more than one 
agency, we advise other agencies accordingly through a variety of 
venues (e.g., the Chief Human Capital Officer's Council). We note as 
well that our experience with this authority guided the crafting of 
our templates and guidance (which have been disseminated to agencies 
and have been available on the OPM website for several years). 

As noted above, OPM processes a relatively small number of waiver 
requests each year. Based upon the data GAO compiled, it appears that 
the vast majority of retirees who are reemployed in the Federal 
civilian service are brought back with salary offsets or hired in 
conjunction with separate authorities not administered by OPM --e.g., 
the authority referenced at p. 6 of the report that permits the 
Department of Defense to re-employ annuitants without offsetting 
salary or the authority granted directly to agencies under the 
National Defense Authorization Act of 2010. (The draft report notes 
that 80% of all the re-employing of annuitants in fiscal year 2013 
were processed by the Department of Defense). OPM's limited role and 
lack of control over the other waiver authorities make it difficult to 
see real value to the civil service in OPM undertaking a trend 
analysis concerning how it has used its own authority. 

Recommendation 2: Establish policies and procedures for documenting 
the dual compensation waiver review process. 

OPM partially concurs with this recommendation. OPM already has 
policies and procedures for documenting the salary offset waivers we 
adjudicate; these are contained/described in our Document Management 
System (DMS). And the documents developed for each case are maintained 
in our DMS in compliance with the National Archives and Records 
Administration policies, standards, and requirements. We acknowledge, 
however, that our lack of a standard method for titling these case 
files makes it more difficult than it should be to identify and 
retrieve them promptly. Accordingly, OPM will undertake to adopt 
standard conventions for captioning salary offset waiver packages 
within its document management system. 

Technical comments are also enclosed. 

Thank you for the time and effort that went into developing this 
report, and for the opportunity to provide our comments. Please 
contact Janet Barnes, Director, Internal Oversight & Compliance at 
(202) 606-3207 should your office require additional information. 

Sincerely, 

Signed by: 

Mark D. Reinhold: 
Associate Director: 

Enclosure: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Yvonne D. Jones, (202) 512-2717 or jonesy@gao.gov: 

Staff Acknowledgment: 

In addition to the individual named above, Chelsa Gurkin (Assistant 
Director), Anthony Patterson (Analyst-in-Charge), Vida Awumey, Sara 
Daleski, Karin Fangman, Kimberly McGatlin, and Rebecca Shea made major 
contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, Federal Workforce, Recent Trends in Federal Civilians 
Employment and Compensation, [hyperlink, 
http://www.gao.gov/products/GAO-14-215] (Washington, D.C., Jan. 29, 
2014). 

[2] 5 U.S.C. § 8344(i) and § 8468(f). For information on other dual 
compensation waiver authorities, see GAO, Reemployment of Retirees: 
Six Agencies' Use of Dual Compensation Waiver Authority is Limited, 
[hyperlink, http://www.gao.gov/products/GAO-12-855R] (Washington, 
D.C.: Sept. 10, 2012). 

[3] Retired uniformed service members who are employed in federal 
civilian positions are not typically or commonly described as 
"reemployed annuitants," but we refer to them as such for ease of 
reference in this report. 

[4] EHRI (formerly Central Personnel Data File--(CPDF)) is the primary 
government-wide source for information on federal employees. The EHRI 
data we analyzed cover most executive branch civilian employees, but 
do not include the U.S. Postal Service, legislative or judicial branch 
employees or intelligence agencies. OPM transitioned from CPDF to EHRI 
as of fiscal year 2010. We began our analysis with 2004 data as that 
is the first year with data from the Department of Homeland Security 
and ended with 2013, the most recent year for which data are 
available. Both civil service and uniformed service retirees are 
included among the types of annuitants we analyzed. 

[5] Internal control is defined as an integral component of an 
organization's management that provides reasonable assurance that the 
following objectives are being achieved: effectiveness and efficiency 
of operations, reliability of financial reporting, and compliance with 
applicable laws and regulations. Internal control, which is synonymous 
with management control, helps government program managers achieve 
desired results through effective stewardship of public resources. For 
more information, see GAO, Standards for Internal Control in the 
Federal Government. [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.: 
November 1999) and Office of Management and Budget, Management 
Responsibility for Internal Control, OMB Circular A-123 Revised 
(Washington, D.C.: Dec. 21, 2004). 

[6] OPM regulations implementing this authority are set forth at 5 
C.F.R. part 553. 

[7] Section 1122 of Pub. L. No. 111-84, div. A, title XI, 123 Stat. 
2190, 2505-09 (Oct. 28, 2009). 

[8] [hyperlink, http://www.gao.gov/products/GAO-12-855R]. 

[9] 5 U.S.C. § 9902(g). 

[10] OPM's EHRI status data are point in time data (as of September 
30THeach year), so annuitants whose terms were less than a year and 
did not overlap with this point in time are not reflected in these 
numbers. As a result, our analysis may understate the total number of 
rehired annuitants across the fiscal year. 

[11] Since 1999, the retirement or retainer pay of a retired member of 
the uniformed services is no longer subject to reduction upon 
employment in a federal civilian position. See, section 651 of the 
National Defense Authorization Act for Fiscal Year 2000, Pub. L. No. 
106-65 (Oct. 5, 1999). 

[12] The CFO Act agencies are the 24 executive branch agencies covered 
by the CFO Act of 1990, as amended, and listed at 31 U.S.C. § 901(b). 
The 24 CFO Act agencies are the U.S. Departments of Agriculture, 
Commerce, Defense, Education, Energy, Health and Human Services, 
Homeland Security, Housing and Urban Development, the Interior, 
Justice, Labor, State, Transportation, the Treasury, and Veterans 
Affairs, as well as the U.S. Agency for International Development, 
Environmental Protection Agency, General Services Administration, 
National Aeronautics and Space Administration, National Science 
Foundation, Nuclear Regulatory Commission, Office of Personnel 
Management, Small Business Administration, and Social Security 
Administration. These agencies account for a very high proportion of 
the total federal labor force. 

[13] [hyperlink, http://www.gao.gov/products/GAO-14-215]. 

[14] GAO, Human Capital Management: Effectively Implementing Reforms 
and Closing Critical Skills Gaps Are Key to Addressing Federal 
Workforce Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-12-1023T] (Washington, D.C.: Sept. 19, 
2012). 

[15] GAO, Human Capital: Strategies to Help Agencies Meet Their 
Mission in an Era of Highly Constrained Resources, [hyperlink, 
http://www.gao.gov/products/GAO-14-168 (Washington, D.C.: May 7, 2014). 

[16] [hyperlink, http://www.gao.gov/products/GAO-14-168]. 

[17] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[18] 5 C.F.R. § 553.202(c). 

[19] EHRI (formerly Central Personnel Data File (CPDF)) is the primary 
government-wide source for information on federal employees. The EHRI 
data we analyzed include executive branch civilian employees, and do 
not include the postal service, legislative or judicial branch 
employees, or intelligence agencies. OPM transitioned from CPDF to 
EHRI as of fiscal year 2010. 

[20] The CFO Act agencies are the executive branch agencies listed at 
31 U.S.C. § 901(b). 

[21] The uniformed services are the Army, Navy, Air Force, Marine 
Corps, Coast Guard, National Oceanic and Atmospheric Administration, 
and the Public Health Service. 

[22] We previously reported that government wide data from CPDF were 
96 percent or more accurate. See GAO, OPM's Central Personnel Data 
File: Data Appear Sufficiently Reliable to Meet Most Customer Needs, 
[hyperlink, http://www.gao.gov/products/GAO/GGD-98-199] (Washington, 
D.C.: Sept. 30, 1998). Also, in a document dated February 28, 2008, an 
OPM official confirmed that OPM continues to follow the CPDF data 
quality standards and procedures contained in our 1998 report. 

[23] Internal controls are defined as an integral component of an 
organization's management that provides reasonable assurance that the 
following objectives are being achieved: effectiveness and efficiency 
of operations, reliability of financial reporting, and compliance with 
applicable laws and regulations. Internal control, which is synonymous 
with management control, helps government program managers achieve 
desired results through effective stewardship of public resources. For 
more information about our and the U.S. Office of Management and 
Budget's (OMB) internal control frameworks, see Standards for Internal 
Control in the Federal Government. [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1] (Washington, D.C.: 
November 1999) and OMB Circular A-123 Revised. 

[End of section] 

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