Accountability Resources

Most Frequently Observed Problem Areas

The following list briefly discusses areas most frequently observed during our on-site audits within the last year that need improvement.  The list is by no means all-inclusive nor does it indicate that every agency needs improvement in these areas.  Some, but not all items, involve Civil Service Rule or directive violations; all will involve improving the human resources programs at agencies.  The list is provided as an aid to agencies in improving their human resources programs as well as in preparing for audits.

1. Written justification required by Rule or directive.

For such actions as Job Appointments and Restricted Appointments, we have often found that written justification for the need of the temporary appointment has not been noted or kept for some or all of the sampled actions of this type we reviewed. 

2. Checking that an appointee/promotee meets the minimum qualifications for the job OR failing to document who made that determination.

The name or initials of the person who determines that an appointee/promotee meets the minimum qualifications for the job must be maintained on each filled job title for which the agency is the sole determiner of the minimum qualification requirements.This would certainly involve shortage jobs, noncompetitive jobs, reallocations, noncompetitive promotions and reemployments, to name a few.

3. Adequate applicant flow records OR production of these records.

The issue of what “applicant flow” means in the decentralized setting is still in the process of being clarified by Civil Service to the agencies.  We realize this has presented problems to the agencies during the audit process, and Civil Service has recently issued General Circular #1519 to advise agencies of the HR Handbook update of this area and to provide agencies with the answers to some Frequently Asked Questions.  We all understand that this will be an ongoing process of change for some agencies as they work to collect the needed information, but we will expect agencies to tell us what steps they are taking to improve applicant flow records if this area still is in need of improvement when we audit.

If agencies choose to keep some applicant flow records in divisions rather than in the HR Office, this will be their choice.  But agencies should understand that some of these records will have to be provided to consultants at the time of the on-site audit.  This could require records or copies of records to be sent to the HR Office at the time of the on-site audit.

4. Not completing all requirements for use of Rule 6.5g (pay above minimum for extraordinary qualifications).

The following bulleted items are listed in the order of the most frequent problems encountered first.

·        Failure to verify (the HR Office calls or writes to ensure the qualifications are legitimate) the extraordinary qualifications of the individual.

·        Failure to list the initials or the signature of the person who verified the extraordinary qualifications.

·        Indication of which qualifications were viewed as extraordinary and why they were considered “extraordinary” if not easily discernible.

·        Failure to have a written 6.5g policy although using it to pay above the minimum OR failure to post it as required by the Rules.

5. Lack of documentation of appointing authority approval for attainment of permanent status and/or merit increases.

Because an agency’s forms frequently center around filling positions, the agency may fail to get the approving signature of the appointing authority (or his official designee) for these two actions, which may be only authorized by supervisors/managers signing a tickler form of some sort.

Reallocations in a training series is another action for which this omission can easily occur.

6. ISIS or other HR software entry errors.

Because the reports Civil Service consultants pull to audit an agency’s activities come from the records that agency has entered into the ISISHR system or from the electronic records the agency has sent to Civil Service from its own HR system, accurate entry into those software systems is essential for proper determination of the action itself and its possible compliance with Civil Service Rules.  As a part of the audit procedure, consultants will note the occurrence of entry errors that come to their attention in the review of their reports. 

Although we realize that training in the area of HR software entry and the Guidelines have been posted on the Civil Service website only since mid 2002, we will be expecting agencies to refer to the website in an effort to ensure accurate entry.

Note:  Agencies for which Civil Service performs the ISISHR entry would only be cited for entry errors if incorrect information upon which the entry was based was supplied by the agency or not supplied when it should have been.

7. Weaknesses/deficiencies in the agency’s Performance Planning and Review program.

The following bulleted items are listed in the order of the most frequent problems encountered first.

·        Failure to perform timely planning sessions,  no record of planning session at all, or no date by signature of planning session (cannot determine if it is timely).

·        No consideration of OR no documents to support claim of consideration of PPR rating in the decision-making processes for merit increases, attainment of permanent status, promotions, and/or reallocations in a training series.

·        Several years of reported “Un-rated” PPR rates above 10%.

·        No evidence of procedures in place and carried out (consequences) for supervisors/managers who fail to rate their employees timely.

·        No evidence of procedures in place and carried out (consequences) for supervisors/managers who do not timely conduct the PPR planning session with their employees.

·        Failure to plan (or no performance expectations written) and/or rate employees on all required factors on PPR form.

·        “Un-rated” rate in sampled PPR ratings reviewed does not support annual “Un-rated” rate reported by agency to Civil Service.  This discrepancy could indicate an agency does not fully understand what constitutes an “Un-rated” rating or could result from an inability of the agency to produce the needed ratings for review at the time of the on-site audit.

* * * * Recent Issue Requiring Agency’s Attention * * * *

8.      Proof of certification for compliance with Civil Service Rules and law for each personnel transaction.

Each agency should establish in writing where the responsibility for certification for compliance of each personnel transaction with Civil Service Rules and law in accordance with Rule 15.3(b) lies and how that certification process will be carried out.  Please refer to General Circular #1522, issued March 5, 2003, and the Civil Service website link HR Handbook for further information on and explanation of this issue. Each agency should review how this certification for compliance process, or making sure that every action is done in compliance with Civil Service Rules and law, is occurring in its organization. This responsibility lies with the appointing authority, and he may wish to delegate this authority and should do so in writing. For some agencies, this may involve a memorandum, directive, regulation, or policy be written or revised.  Beyond the delegation, an agency needs to be sure it can explain and prove how the certification process flows and who is responsible for the steps.