oversight

Personnel Practices: Improper Personnel Actions on Selected CPSC Appointments

Published by the Government Accountability Office on 1997-06-27.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Chairman, Subcommittee
                 on Civil Service, Committee on
                 Government Reform and Oversight
                 House of Representatives

June 1997
                 PERSONNEL
                 PRACTICES
                 Improper Personnel
                 Actions on Selected
                 CPSC Appointments




GAO/GGD-97-131
                   United States
GAO                General Accounting Office
                   Washington, D.C. 20548

                   General Government Division

                   B-276748

                   June 27, 1997

                   The Honorable John L. Mica
                   Chairman, Subcommittee on Civil Service
                   Committee on Government Reform and Oversight
                   House of Representatives

                   Dear Mr. Chairman:

                   Your July 23, 1996, letter requested that we investigate alleged improper
                   personnel activities at the Pension Benefit Guaranty Corporation (PBGC)
                   and the Consumer Product Safety Commission (CPSC). More specifically,
                   you were concerned about alleged improper hirings of former Internal
                   Revenue Service (IRS) employees by PBGC and alleged improper personnel
                   actions and “burrowing in” by political appointees at CPSC.1 We reported on
                   the results of our work at PBGC in October 1996.2 This report provides the
                   results of our work at CPSC.

                   The original objective of our work at CPSC was to determine whether the
                   appointments of six individuals who were the subjects of the allegations
                   received by your office were made in accordance with merit system
                   principles and applicable rules and regulations. As we conducted our audit
                   work and at your request, we added an objective to identify the number of
                   appointments that CPSC had made at advanced rates of pay (pay at a level
                   higher than the minimum for the position’s grade) during the period
                   beginning in March 1994 when the current CPSC Chairman assumed office,
                   and ending in March 1997; and to determine whether the justification for
                   those rates was documented as required by federal regulations.


                   The allegations concerning the six appointments proved to be partially
Results in Brief   true. The appointments did not, as alleged, constitute burrowing in
                   because the individuals did not convert from noncareer political
                   appointments to career appointments in the competitive service.3 Each of
                   the appointments was beset, however, by one or more irregular or
                   improper personnel actions. These included (1) three instances in which
                   proper candidate examination and selection procedures were not

                   1
                    “Burrowing in” is a term generally used to refer to the conversion of former political appointees to
                   career status in the competitive service.
                   2
                    Hiring of Former IRS Employees by PBGC (GAO/GGD-97-9R, Oct. 2, 1996).
                   3
                    The six allegations involved one noncareer, Schedule C political appointment; one career
                   appointment based on the individual’s eligibility due to prior service in the legislative branch; three
                   noncareer, term appointments lasting up to 2 years; and one noncareer, temporary appointment.



                   Page 1                                                          GAO/GGD-97-131 Personnel Practices
B-276748




followed, causing, in two cases, veterans with veterans preference
eligibility to be denied proper consideration in the selection process;
(2) three instances in which advanced rates of pay based on superior
qualifications were set without the required documentation to justify such
rates; and (3) two instances in which the proper use of term appointment
authority was questionable.

In December 1996, we asked the Office of Personnel Management (OPM),
which is responsible for overseeing the federal personnel system, to
review our findings for the six appointments and, if those findings were
accurate, to tell us what corrective actions it would instruct CPSC to take.
OPM generally agreed with our findings and directed CPSC to take certain
actions, such as to notify the veterans that they are to receive priority
consideration for the next positions that become available that are similar
to those for which they had applied. CPSC took the instructed steps and
reported to OPM in April 1997. OPM subsequently notified CPSC on May 28,
1997, that it was satisfied with the actions taken.

CPSC  made 20 additional appointments between March 1994 and
March 1997 in which, according to CPSC data, the appointees received
advanced rates of pay. In 2 of the 20 cases the individuals had resigned
from CPSC, and their official personnel folders (OPFs) were not readily
available. Of the remaining 18 appointments, 9 were based on the superior
qualifications of the appointees and 8 were based on previous salary levels
of the appointees. In the one remaining case, the basis for the advanced
rate of pay could not be determined. Supporting documentation for five of
the nine superior qualification appointments was in the appointees’ OPFs.
Supporting documentation for the other four was not present. CPSC
officials said that they have since prepared, or are preparing, supporting
justification for these four. Supporting documentation existed in the OPFs
of the eight appointees whose salary was set based on their highest
previous salary levels.

CPSC officials attributed the irregular or improper personnel actions to
administrative error and misunderstandings by its personnel staff and said
that the agency has taken steps to improve its personnel operations.
According to CPSC’s personnel director, additional training is being
provided to personnel staff, internal controls are being enhanced, and
guidelines are being written to help ensure that future personnel actions
are conducted properly.




Page 2                                       GAO/GGD-97-131 Personnel Practices
              B-276748




              In February 1996, OPM delegated to CPSC the authority to conduct open,
              competitive examinations for entry to various CPSC positions and from the
              results of those entry examinations, develop lists of qualified applicants.
              Given the problems CPSC has had in properly carrying out personnel
              actions, it is important that CPSC is successful in improving its personnel
              operations and is able to competently handle its delegated authority. OPM
              is responsible for ensuring that CPSC exercises its delegated authority in
              full compliance with merit system principles, rules, and regulations. The
              primary way OPM ensures such compliance is by conducting oversight
              reviews. An OPM official told us that the agency plans to conduct such a
              review of CPSC in 1998.4


              CPSC is an independent federal agency established by the Consumer
Background    Product Safety Act (P.L. 92-573) with the mission to reduce unreasonable
              risks of injury and deaths associated with consumer products. As an injury
              prevention agency, CPSC is to research product hazards, participate with
              industry in developing voluntary standards for products, issue and enforce
              mandatory standards, and inform the public of potential product hazards.
              CPSC also is to direct the recall of dangerous products and enforce its
              statutes in administrative and federal court proceedings.

              The authorizing legislation provides for the appointment of five
              commissioners by the President for staggered 7-year terms. As of
              June 1997, CPSC had three commissioners, one of whom was designated
              CPSC Chairman. The Chairman is the principal executive officer of CPSC,
              with authority to exercise all executive and administrative functions of the
              agency. Personnel operations are to be conducted by a staff of nine
              employees. During fiscal year 1997, CPSC has hired approximately 40
              individuals.

              CPSC received appropriations of approximately $42.5 million for fiscal
              years 1994 and 1995 and about $40 million for fiscal year 1996. Its
              personnel ceiling was 511 full-time equivalent (FTE) positions in fiscal year
              1994 and 487 FTE positions in fiscal years 1995 and 1996.


              To determine whether the six appointments that were the subject of
Scope and     allegations were made in accordance with merit system principles and
Methodology   applicable rules and regulations, we (1) identified the appointment

              4
               A CPSC official told us that the agency plans to contract with OPM by July 1997 for an independent
              audit of CPSC’s use of delegated examining authority. Such an audit would be in addition to the
              planned oversight review by OPM in 1998.



              Page 3                                                      GAO/GGD-97-131 Personnel Practices
B-276748




procedures followed, as documented in the OPFs and in CPSC’s merit
staffing case files5 for each appointment, and (2) reviewed the procedures
in light of merit system principles and applicable federal personnel rules
and regulations. We interviewed CPSC personnel and management officials
to discuss questions we developed on each case. We also provided our
case summaries, including the problems we identified, to OPM and asked
whether it agreed with our findings and, if so, what corrective actions OPM
intended to instruct CPSC to take. We discussed and clarified OPM’s
response, where necessary, with officials from that agency.

To identify the number of appointments that CPSC had made at advanced
rates of pay during the period March 1994 through March 1997, and to
determine whether the justification for those rates was documented as
required by federal regulations, we obtained a listing from CPSC of
appointments made during this period with advanced salary rates. The
listing contained the names of three individuals who were part of the six
appointments that were the subjects of allegations of improper personnel
actions and burrowing in, and whose advanced pay rates we had already
reviewed. After subtracting those 3 from the listing, 20 others remained.
We reviewed the OPFs of 18 of the 20 to determine whether the required
documentation to justify the advanced rates was present. The other two
appointees had resigned from CPSC, and their OPFs had been sent to the
Federal Records Center and were not readily available.

We did not verify the completeness of CPSC’s listing of those appointments
involving advanced salary rates. We also did not attempt to reach
conclusions about the quality or sufficiency of the written justifications in
those cases in which written justifications were present.

During our review, CPSC obtained OPM’s assistance in reviewing
appointments and promotion actions taken by CPSC during the period
March 10, 1994, through October 31, 1996. OPM also reviewed the
appointments of senior executive and Schedule C employees on board at
the time OPM provided the assistance. We discussed this work with OPM and
CPSC officials, reviewed a summary of observations made by OPM on the
results of its review, and discussed with CPSC’s personnel director actions
planned and taken to improve personnel operations.



5
 Merit staffing case files contain information related to the competitive examining process used in
filling a position. The kind of information generally contained includes a copy of the vacancy
announcement, the application packages of each applicant, the results of the entry examinations and
the rating panel, the listing of qualified applicants, and documentation showing which applicant was
selected for the position.



Page 4                                                       GAO/GGD-97-131 Personnel Practices
                             B-276748




                             We did our work in Washington, D.C., from August 1996 to June 1997 in
                             accordance with generally accepted government auditing standards. We
                             requested comments on a draft of this report from the Chairman of CPSC
                             and the Director of OPM. CPSC provided written comments, and OPM
                             provided comments orally. Their comments are discussed at the end of
                             this letter, and CPSC’s written comments are reprinted in appendix III.


                             Each of the six appointments we reviewed and that were the subject of
Problems Identified          allegations—while not involving burrowing in—involved one or more
With Appointments            irregular or improper personnel actions. OPM generally agreed with our
Made by CPSC                 findings. Also, our review of an additional 18 appointments showed that in
                             9 cases, advanced salaries were provided due to the superior qualifications
                             of the individuals. However, written justification to support the superior
                             qualifications—as required by regulations—did not exist in four of the
                             nine cases. CPSC officials told us that corrective actions have been, or are
                             being, taken in each of the cases in which we found problems.


Six Appointments             The nature of the irregular or improper actions in the six appointments is
Involving Irregular or       summarized below and fully described in appendix I. We have redacted
Improper Actions             personal identifiers of the appointees in appendix I for privacy protection
                             purposes.

                         •   For three appointments, CPSC used improper candidate examination and
                             selection procedures. In two of those cases, it failed to follow veterans
                             preference rules. As a result, military veterans who were among the
                             candidates for the two positions were not provided the preference
                             consideration they were entitled to under veterans preference laws. In the
                             third case, CPSC failed to process the applications for appointment in
                             conformance with OPM instructions. As a result, CPSC made an invalid
                             appointment.
                         •   Three of the six appointments were made with advanced rates of pay
                             based on the superior qualifications of the candidate, but we found no
                             written documentation to justify such rates. As required by federal
                             personnel regulations, agencies need to document the superior
                             qualifications that justify an advanced rate of pay.
                         •   Two appointments were made using term appointment authority in which,
                             under justifiable circumstances, an agency can hire an individual for a
                             specific period of time, generally not exceeding 4 years. We questioned
                             whether the term appointment authority was properly used in these cases.
                             According to information in the employees’ personnel folders, the



                             Page 5                                       GAO/GGD-97-131 Personnel Practices
B-276748




justification cited for the term appointments was to provide expertise on
special projects. However, the selecting official told us there were no
special projects in her office.

We brought our findings to OPM’s attention in December 1996 and asked
OPM, in its oversight capacity for ensuring agencies’ compliance with
personnel laws and regulations, whether it agreed with our assessment
and, if so, what corrective actions it would instruct CPSC to take. OPM
responded to us in March 1997 and, in general, agreed with our findings. In
regard to the two term appointments that did not appear to be justified,
OPM officials said that CPSC informed them that because the agency’s
funding level was uncertain, it decided to use term rather than permanent
appointments to meet staffing needs. The use of term appointments is
authorized under such conditions and therefore OPM did not consider these
appointments inappropriate. We agree that uncertain funding levels is a
bona fide justification for using term appointments, but the documentation
we reviewed did not indicate this rationale for these two term
appointments.

After receiving OPM’s response, we went back to CPSC and asked agency
officials the basis for providing OPM with a new justification for the term
appointments. CPSC officials said that the information in the two
appointees’ personnel folders citing special projects as the justification for
the term appointments was incorrect. CPSC officials told us that when the
two individuals were hired—in January 1995—the agency had already
received its fiscal year 1995 appropriation. But the agency felt
considerable uncertainty about the level of its 1996 funding due to the
possibility of changed political priorities in Congress. Officials said that
CPSC was concerned about committing permanent positions to the office in
question because an overcommitment of resources could require a later
reorganization. The officials acknowledged that they did not have any
documentation contemporaneous with the two appointments to support
the uncertain funding justification.

On one of the three superior qualification appointments, OPM determined
that the individual was eligible for the advanced pay rate based on his
previous highest salary and CPSC did not need to base the advanced pay
rate on superior qualifications. OPM instructed CPSC to correct the
personnel folder by deleting reference to superior qualifications.

OPM agreed with our remaining concerns and instructed CPSC to take
certain actions. For example, in the two instances in which CPSC did not



Page 6                                        GAO/GGD-97-131 Personnel Practices
                          B-276748




                          follow veterans preference rules, CPSC was instructed to notify the
                          veterans that they will receive priority consideration for the next available
                          similar positions. OPM also instructed CPSC to fully document the superior
                          qualifications of and justify an advanced rate of pay for the two remaining
                          appointments made using the superior qualifications provision. CPSC
                          reported to OPM in April 1997 that it took the instructed corrective actions,
                          and OPM subsequently notified CPSC on May 28, 1997, that it was satisfied
                          with the actions taken. We verified that the actions were taken. OPM’s
                          position on each of the six cases is detailed in appendix II. We have
                          redacted personal identifiers of the appointees in appendix II for privacy
                          protection purposes.


Additional Appointments   CPSC, at our request, identified all appointments made between March 1994
Reviewed                  and March 1997 in which advanced pay rates had been set. Excluding 3
                          advanced pay rate appointments that were part of our original review of
                          the 6 allegations, CPSC identified 20 cases. In 2 of the 20 cases, the
                          individuals had resigned from CPSC, their OPFs were not readily available
                          for review, and CPSC officials were unable to recall the details of the cases.
                          Of the remaining 18 cases, our review of the OPFs and discussions with
                          CPSC officials showed that the advanced rates of pay were based on the
                          superior qualifications of the individuals in 9 instances and on the highest
                          previous salaries of the individuals in 8 instances. In one instance, the
                          basis for the advanced rate of pay could not be determined from the
                          employee’s OPF.

                          Of the nine cases involving superior qualifications, five were justified at
                          the time of appointment by written documentation as required by
                          regulations. CPSC officials have since taken, or are currently taking, actions
                          to correct the other four cases. In the eight cases involving highest
                          previous salaries, supporting documentation was in the OPFs. In the
                          remaining case where the basis for the advanced rate could not be
                          determined, the CPSC personnel director told us that CPSC has since
                          determined that the employee’s pay was improperly set and that the
                          correction would be to reset the pay at a lower rate. However, because
                          this would result in a decreased salary level, and the error was made
                          through no fault of the employee, CPSC has requested a variance (or
                          exception) on this matter from OPM. According to the CPSC personnel
                          director, at the time this report was prepared OPM had not responded to
                          CPSC’s request.




                          Page 7                                        GAO/GGD-97-131 Personnel Practices
                      B-276748




                      During a 2-week period beginning in September 1996, an OPM official—at
                      the request of CPSC—reviewed the appointments of all senior executives
                      and Schedule C employees employed at CPSC as of that time, as well as all
                      appointment and promotion actions taken on CPSC employees since
                      March 10, 1994. In total, the OPM official reviewed actions involving 167
                      employees and raised a variety of issues. Some were of an administrative
                      nature, such as filing employees’ security forms and fingerprint charts in
                      OPFs when such forms should be part of the employees’ security
                      investigation files. Other issues were of a more significant nature. For
                      example, OPM also identified, as we did, the four cases of advanced pay
                      rates based on superior qualifications where supporting documentation
                      did not exist. OPM also identified another case, not included in the scope of
                      our review, in which an employee had improperly received a quality step
                      increase (an increase in salary within the same pay grade based on quality
                      performance.) OPM determined that the increase was improper because it
                      was provided 8 weeks earlier than allowed by regulation. Federal
                      regulations provide that such an increase cannot be given an employee
                      who has received a quality step increase within the preceding 52 weeks.
                      CPSC waived the 8 weeks of overpayment and is correcting the OPF.


                      According to CPSC officials, all of the personnel problems we and OPM
                      identified were due to administrative errors or misunderstandings on the
                      part of the personnel office staff. The CPSC personnel director told us that
                      CPSC has taken numerous steps during our review to improve its personnel
                      operations and ensure compliance with all applicable federal laws and
                      regulations in the future. These include (1) providing additional training to
                      all personnel staff, (2) developing a checklist to ensure that personnel
                      actions are processed correctly, (3) developing written guidelines on
                      processing and documenting appointments with advanced rates of pay,
                      and (4) holding weekly staff meetings for personnel staff to discuss
                      current regulations.


                      In February 1996, OPM delegated examining authority to CPSC. Under
CPSC Was Delegated    delegated examining authority, agencies typically recruit, accept
Examining Authority   applications, score applicants on the basis of a review of education and
                      experience, maintain registers of qualified applicants, create certificates
                      listing the top-ranked candidates from the registers, and hire employees
                      from those certificates. Thus, CPSC now has greater responsibility for
                      personnel matters. While the problems CPSC had in the appointments we
                      reviewed occurred before the delegation of examining authority, the




                      Page 8                                        GAO/GGD-97-131 Personnel Practices
                      B-276748




                      greater responsibility provided to CPSC by that authority makes it more
                      important now that OPM carefully watch over CPSC personnel activities.

                      According to OPM, it uses oversight reviews of agencies’ personnel
                      activities to gauge and ensure their compliance with merit system
                      principles, rules, and regulations. OPM annually selects and schedules
                      agencies for these reviews. An OPM official said OPM is planning to review
                      CPSC in 1998.



                      Irregular and improper personnel appointments have been made at CPSC
Conclusions           over the past several years. CPSC has recognized the existence of such
                      problems and began to take actions during the course of our review to
                      correct previous improprieties and improve its personnel operations. Such
                      actions were both necessary and appropriate, as the integrity of the civil
                      service system rests on the consistent adherence to merit system
                      principles, rules, and regulations. Also, CPSC now has greater responsibility
                      for personnel actions under the examining authority delegated by OPM.
                      Because of this, and because of the past problems, we believe it important
                      for OPM to closely monitor CPSC’s personnel operations to ensure that the
                      agency is successful in its efforts to improve personnel operations.


                      To help ensure that CPSC’s efforts to improve personnel operations are
Recommendation to     successful and result in adherence to merit system principles, rules, and
the Director of OPM   regulations, we recommend that the Director of OPM include CPSC on OPM’s
                      next annual schedule of oversight reviews of agencies’ personnel actions.
                      CPSC should remain on OPM’s schedule until OPM is satisfied that CPSC is
                      maintaining personnel operations at a satisfactory level.


                      On June 17, 1997, the Executive Director of CPSC provided us written
Agency Comments       comments on the draft (see app. III); and on June 19, 1997, the Deputy
                      Chief of Staff of OPM provided us oral comments on the draft. CPSC agreed
                      with our findings that errors in personnel processing occurred during the
                      period covered by our review and noted that the agency has worked to
                      implement the necessary corrective actions. OPM officials also agreed with
                      our findings. The Deputy Chief of Staff pointed out that OPM plans to
                      conduct an oversight review of CPSC personnel operations in 1998. He also
                      said that CPSC plans to contract with OPM for an independent audit of CPSC’s
                      use of delegated authority.




                      Page 9                                        GAO/GGD-97-131 Personnel Practices
B-276748




As agreed with the Subcommittee, unless you publicly announce the
report’s contents earlier, we plan no further distribution of it until 15 days
after the date of this report. We will then send copies to the Ranking
Minority Member of the Subcommittee, the Chairman and Ranking
Minority Member of the Senate Committee on Governmental Affairs, the
Director of OPM, and the Chairman and other commissioners of CPSC. We
will also make copies available to others on request.

Please contact me at (202) 512-9039 if you or your staff have any questions.
Major contributors to this report were Richard W. Caradine, Assistant
Director; N. Scott Einhorn, Evaluator-in-Charge; and Stephen J. Kenealy,
Technical Advisor.

Sincerely yours,




Michael Brostek
Associate Director, Federal Management
and Workforce Issues




Page 10                                        GAO/GGD-97-131 Personnel Practices
Page 11   GAO/GGD-97-131 Personnel Practices
Contents



Letter                                                                                            1


Appendix I                                                                                       14

December 5, 1996,
Referral Letter to the
Director, Office of
Personnel
Management, From
GAO
Appendix II                                                                                      33

March 3, 1997,
Response From the
Director, Office of
Personnel
Management, to
GAO’S Referral Letter
Appendix III                                                                                     49

Comments From the
U.S. Consumer
Product Safety
Commission



                         Abbreviations

                         CPSC      Consumer Product Safety Commission
                         FTE       full-time equivalent
                         IRS       Internal Revenue Service
                         OPM       Office of Personnel Management
                         OPF       Official Personnel Folder
                         PBGC      Pension Benefit Guaranty Corporation


                         Page 12                                  GAO/GGD-97-131 Personnel Practices
Page 13   GAO/GGD-97-131 Personnel Practices
Appendix I

December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




               Page 14          GAO/GGD-97-131 Personnel Practices
                             Appendix I
                             December 5, 1996, Referral Letter to the
                             Director, Office of Personnel Management,
                             From GAO




Note: Personal identifiers
have been redacted.




                             Page 15                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 16                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 17                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 18                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 19                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 20                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 21                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 22                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 23                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 24                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 25                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 26                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 27                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 28                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 29                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 30                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 31                                     GAO/GGD-97-131 Personnel Practices
Appendix I
December 5, 1996, Referral Letter to the
Director, Office of Personnel Management,
From GAO




Page 32                                     GAO/GGD-97-131 Personnel Practices
Appendix II

March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




               Page 33          GAO/GGD-97-131 Personnel Practices
                             Appendix II
                             March 3, 1997, Response From the Director,
                             Office of Personnel Management, to GAO’S
                             Referral Letter




Note: Personal identifiers
have been redacted.




                             Page 34                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 35                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 36                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 37                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 38                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 39                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 40                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 41                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 42                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 43                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 44                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 45                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 46                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 47                                      GAO/GGD-97-131 Personnel Practices
Appendix II
March 3, 1997, Response From the Director,
Office of Personnel Management, to GAO’S
Referral Letter




Page 48                                      GAO/GGD-97-131 Personnel Practices
Appendix III

Comments From the U.S. Consumer Product
Safety Commission




               Page 49       GAO/GGD-97-131 Personnel Practices
           Appendix III
           Comments From the U.S. Consumer Product
           Safety Commission




(410131)   Page 50                                   GAO/GGD-97-131 Personnel Practices
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