Human Capital:

OPM Needs to Better Analyze and Manage Dual Compensation Waiver Data

GAO-15-252: Published: Dec 29, 2014. Publicly Released: Jan 5, 2015.

Additional Materials:


Yvonne D. Jones
(202) 512-2717


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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. 

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

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

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. 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.

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.

For more information, contact Yvonne D. Jones at (202) 512-2717 or

Recommendations for Executive Action

  1. Status: Open

    Comments: As of August 2018, OPM reiterated its disagreement with this recommendation and does not plan to take any steps to address it. However, we maintain that the recommendation has merit, because 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.

    Recommendation: To improve OPM's assistance to agencies and management of its dual compensation waiver program, the Director of OPM should analyze dual compensation waivers to identify trends that can inform OPM's human capital management tools.

    Agency Affected: Office of Personnel Management

  2. Status: Closed - Implemented

    Comments: OPM partially concurs with this recommendation. According to an OPM official, the agency has established and implemented a standard method for captioning dual compensation files. In addition, according to this official, OPM has provided training to staff who routinely create and access these case files within the agency's document management system. We discussed OPM's efforts on this issue several times during 2016 and will continue to monitor whether OPM will use the new captioning procedures. As of August 2018, OPM provided documentation that it has taken steps to meet the spirit of the recommendation, including (1) establishing procedures for documenting the dual compensation waiver review process; (2) devising a standardized captioning system for labeling all new DCW cases, be they individual waivers or requests for delegation of authority from OPM; and (3) providing training on captioning dual compensation waiver packages in its document management system in February 2015 and again in April 2015. This training included standardized captioning, as well as search, identification, and retrieval capabilities of the DMS system. Due to these actions we consider this recommendation closed.

    Recommendation: To improve OPM's assistance to agencies and management of its dual compensation waiver program, the Director of OPM should establish policies and procedures for documenting the dual compensation waiver review process.

    Agency Affected: Office of Personnel Management


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