Export Promotion: Personnel Management Issues in the U.S. and Foreign Commercial Service

Published by the Government Accountability Office on 1990-03-16.

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

      C’nited   States   General   Accounting   Office   J

      Report to the Chairman, Subcommittee               ‘-
      on Oversight and Investigations,
      Committee on Energy and Commerce,
      House of Representatives

       Personnel Management
  29 ‘$Issues in the U.S. and
       Foreign Commercial
.g”    &mice           ,,, ” ”
                   United States
                   General Accounting    Office
                   Washington,   D.C. 20548

                   National Security and
                   International  Affairs Division


                   March 16, 1990

                   The Honorable #JohnD. Dingell
                   Chairman, Subcommittee on Oversight
                     and Investigations
                   Committee on Energy and Commerce
                   House of Representatives

                   Dear Mr. Chairman:

                   This report responds to your request that we (1) update our 1987
                   review of personnel management issues in the U.S. and Foreign Com-
                   mercial Service’ (UZGWX),the export arm of the International Trade
                   Administration; and (2) identify any new personnel management issues
                   affecting the provision of service to the U. S. business community.

                   Since our 1987 review, the USMCS has taken several steps to improve the
Results in Brief   administration of its personnel system. Assignment, selection, and
                   appraisal policies have been clarified or revised, and more documenta-
                   tion is now being required to support personnel decisions. We did not
                   find evidence of widespread morale problems as was the case in our
                   1987 review. In addition, senior officials we interviewed were optimistic
                   about the prospects for further improvements in the management of the
                   personnel system under the current Director General, who assumed her
                   position in June 1989.

                   However, some assignment and selection practices are questionable and
                   continue to diminish the credibility of the U%WCSpersonnel manage-
                   ment system. In addition, the commercial staff levels in Taiwan are not
                   in compliance with the requirements of the Omnibus Trade and Compet-
                   itiveness Act of 1988.

                   Improvements made to the us&~& time-in-class and commissioning and
                   tenure policy, and efforts to improve its performance appraisal process
                   are addressed in appendix I.

                   The Foreign Commercial Service was created in April 1980 to revitalize
Background         the U.S. trade promotion program in order to help U.S. firms meet

                   ’ PersonnelManagementIs.wesm the ForeignCommercialService(GAO/T-NSL4DR7- I 1 H.u I I

                   Page 1                                               GAO/NSIADI)(Ml Export Pnwwtion

    Increasing competition in world markets. In 1982, the Foreign Corn!
    cial Service was combined with Commerce Department district offif
    form the LXFCS. The foreign operation, the subject of this report, h;
    about 150 commercial officers in 123 foreign posts in ti5 countries.
    Officers are typically assigned to 3- or 4-year tours of duty at foreit:
    posts. The officer corps is augmented by about 460 foreign service

    The US&FCSis headed by an Assistant Secretary level Director Gene!.
    The foreign service component of the USWZS,along with the foreign
    vices of seven other executive agencies and departments, is governe
    the Foreign Service Act of 1980, as amended. The US&FCSis a career .
    vice, similar to the Department of State’s Foreign Service and, under
    specific conditions, non-career limited appointments can be made to
    certain positions.

    In 1987, we found that

e agency practices were not always followed in choosing people for OL.~
  seas assignments;
l selection decisions involving the use of limited appointees ivere not ac
  quately documented;
l irregularities in the performance appraisal process occurred; and
l potential problems in the management of the “up or out” or so-called
  time-in-class system existed.

    We concluded that, in aggregate, these problems had given the impre?
    sion of a breakdown in the management of the personnel system. low
    ered the morale of the officer corps, and diverted energy and attentio,
    away from the goal of assisting U.S. businesses to expand exports.

    We further concluded that the problems stemmed, in large measure,
    from the concentration of authority in the office of the Director Gener#
    rather than in a personnel system with real checks and balances. and
    from the lack of departmental oversight.

    In response to our findings, the Under Secretary for International Tra(:
    in an October 9, 1987, letter, provided a list of actions that had been
    taken to make U~&FCSpersonnel policies more transparent. consistent.
    and effective. In this report, we assess the impact of these changes on
    the US&FCSpersonnel management practices.


    Page 2                                          GAO/NSLUMO-51 Expm Prom

                      During our 198i review we received many complaints and allegations
,omeQuestionable      regarding abusive assignment practices at the US&FCS.In examining
assignmentPractices   these complaints and allegations. we identified questionable practices.
pound                 such as accepting bids from officers for new assignments scheduled to
                      begin before their current tours were completed, routinely assigning
                      officers to posts above and below their personal rank, and filling vacan-
                      cies without advertising them. We also found evidence that some assign-
                      ments may have been punitive in nature and were made outside of the
                      formal paneling process. We concluded that changes in the assignments
                      process were needed to improve officer morale and add credibility to
                      this process.

                      In response to our criticisms, the U~MCSissued a detailed assignments
                      policy in December 1987 to help all officers better understand the over-
                      seas assignment process. The CT= also established a system for
                      appealing assignments. These steps were aimed at making the assign-
                      ment process more systematic and transparent.

                      However, these actions did not address one of the specific assignment
                      practices that we had previously questioned-the     acceptance of bids
                      from officers for assignments scheduled to begin before their current
                      tours were completed. This practice has resulted in tour curtailments
                      and, coupled with the practice of granting tour extensions, continues to
                      diminish the credibility of the assignment process. Some USkFcS officers
                      told us that these two practices are used to manipulate the assignment

Questionable Tour     The ustwcs operations manual explicitly states that tour curtailments
                      are not conducive to efficient management. In addition, in its written
Curtailments          comments to the House Government Operations Committee concerning
                      our 1987 review, Commerce stated that curtailments are rarely given,
                      and when they are, the reasons are required to be fully documented in
                      the assignment panel minutes. USSYYS   officials also told us that curtail-
                      ments are mostly given to officers for medical or compassionate reasons,
                      or for language training in advance of their arrival at new assignments.

                      We found that tours had been curtailed in 25 of the 193 assignments
                      that took place between April 1987 and July 1989, the period covered
                      by our review. Eleven of the curtailments were made for documented
                      medical or language training reasons and 10, as a USMCSofficial
                      explained, although undocumented, were made for the “needs of the

                      Pqc 3                                         GAO/NSLUMO-61 Export fhmotion

                    However. 4 of these 25 curtailments did not appear to meet the start
                    requirements because they were neither (1) granted for medical or (
                    passionate reasons. nor (2) justified in the assignment panel mmute<
                    the official record for these decisions. In addition, other officers of
                    equivalent rank were available to fill the new positions.

                    Two of the four curtailed assignments were made in 1988 and invo[L
                    the highly visible curtailments of 1 year for Senior Foreign Service
                    officers in New Delhi, India, and Seoul, Korea, to enable them to ass\,
                    senior commercial officer positions in Paris, France. and Ottawa, Cat
                    ada, respectively. The records indicated that the officer in Sew Delh
                    submitted his bid for a new post within weeks of his arrival in Seu
                    Delhi for a 3-year assignment.

                    The other two cases involved l-year curtailments of an Fo- 1 (GS- 15
                    equivalent) and an Fe2 (GS-14 equivalent) officer assigned to Stock-
                    holm, Sweden, and Montreal, Canada, respectively, to fill positions 111
                    IMoscow, U.S.S.R., and Rome, Italy, respectively.

                    Although there was no justification for these curtailments In the assig
                    ment panel minutes, in subsequent discussions with CS&FCSofficials N
                    were told that three of the four curtailments were made because of the
                    officers’ unique language skills. We were offered no explanation for t h
                    reassignment of the commercial officer from New Delhi to Pans.
                    Although these curtailments could be a consequence of the small size I
                    the service and the critical role played by language qualifications. the
                    use of unjustified curtailments raises questions among other career
                    officers about their possible misuse.

                    In response to employee complaints about assignment practices. the CI:
                    rent Director General sent a memo on August 1, 1989. to members of tl
                    assignment panel stating that she was disturbed to hear reports that
                    some assignments had already been “promised” to certain indlLVlduals
                    prior to their consideration and decision by the assignment panel. She
                    reminded assignment panel members to avoid any appearance that son
                    assignments are predetermined.

Questionable Tour   A lack of consistency in implementing the assignment process c-an be
                    demonstrated by the decision to extend the tour of the Semor (‘I jmmer-
Extension           cial Officer in Bonn to 9 years. At the time of this extension ’ ( )c.rober
                    1988), USB~FCS  policy on tour lengths stated that the maximum r( )llr-s ar

                    Page 4                                         GAO/NSLAD9&51 Expm Promr

                     overseas posts would be .5 years, except in “rare” cases. While the regu-
                     lations recognize that on occasion tours may need to be extended. the
                     granting of a fixed 4-year extension was unprecedented. Some officers
                     told us that this extension was an example of how the assignments pro-
                     cess is sometimes manipulated.

                     Based on our review of pertinent documentation concerning the Bonn
                     assignment, we question the reasons cited in granting this extension.
                     The minutes of the assignment panel meeting justifying this decision
                     stated that the officer was given a 4-year extension because of the need
                     to provide continuity in an important market prior to European Commu-
                     nity integration in 1992. However, the records also showed that three
                     other qualified Senior Foreign Service officers were available to fill the
                     position- including one proficient in German and assigned to another
                     European Community post.

                     We found nothing in the files to indicate the assignment panel analyzed
                     the possible implications of this decision and its future impact on the
                     assignment process. Our analysis also indicated that the LS&FCS did not
                     announce that special consideration would be given to officers stationed
                     in Europe.

                     In response to the widespread criticism regarding the extension of the
                     Bonn Senior Commercial Officer’s tour to 9 years, which occurred prior
                     to her tenure, the Director General approved a new policy on tour length
                     in October 1989. The new policy allows extensions of tours of duty that
                     go beyond 5 years only in unusual circumstances and only in l-year
                     increments. Because this new policy does not allow for multiyear exten-
                     sions, the current Director General believes the assignment process is
                     now more predictable. We agree that this revised policy is an improve-
                     ment over the prior policy.

Selection Process    raise questions about the credibility and transparency of the overall
Needs Improvements   selection process. Our review showed that (1) established guidelines con-
                     cerning the appointment of non-Foreign Service officers to certain posi-
                     tions were not always followed, (2) no guidelines have been established
                     for an exchange program with other International Trade Administration
                     units, and (3) a questionable selection process was used by a prior Direc-
                     tor General in his last days in office.


                     Page 5                                        GAO/NSLUHM361Export Promotion

C’seof Limited          In certain situations. mdividuals who are not career Foreign Senice
                        officers may be appointed to fill a specific position for a limited peric
Appointments Does Not   of time. These are called non-career limited appointments. The I.S~Y~FC:
Always Comply With      authorizing legislation restricts the use of non-career limited appoint
Guidelines              ments to fill Senior Foreign Service positions to situations where no
                        career officer with the necessary qualifications is available and the
                        applicant is uniquely qualified for the position. In addition. Commerc
                        Department guidelines require that career officers and career candid:
                        be given preference over these appointees in filling vacancies. In our
                        1987 review we found that non-career limited appointees were selectt
                        to fill four of the seven Senior Foreign Service positions for which bot
                        career and non-career appointees had competed. In most cases, there
                        was no documentation explaining why limited non-career individuals
                        were selected in lieu of career officers.

                        In addition, there was one assignment of a non-career appointee to a
                        Senior Foreign Service position for which only his name and no others
                        were submitted to the assignment panel for consideration. Career
                        officers told us that these practices illustrate how the personnel syster
                        was manipulated to fill positions with preselected candidates.

                        In response to our findings, the US&FCSintroduced a new documentation
                        requirement, a “Certificate of Need,” to support the need for and quali
                        fications of each limited appointee.

                        Since our last review, USB~M=Shas substantially reduced its use of non-
                        career limited appointment to fill overseas positions. During our last
                        review, 40 non-career limited appointees were serving overseas. As of
                        September 1989, that number had been reduced to nine.

                        Although most of these non-career appointments and excenswns we
                        examined were made in accordance with existing agency procedures,
                        three appointments and two tour extensions were not. In one appoint-
                        ment, w&FCS records indicated that other career officers or career candi
                        dates were available to fill the positions without the curtailment of prio
                        assignments. In a second case, no certificate of need was completed to
                        document the reasons for hiring the limited appointee. In the third case.
                        the appointee did not meet the minimum language requirement for the

                        In addition, we also noted that two non-career limited appointrus were
                        extended even though the records indicated that qualified c.artr*r

                        Page 6                                         GAO/NSlAD-W-61 Expwt   Promo

                          officers at equivalent rank were available and had bid to fill the

 Jidelines Needed for     The primary source of limited appointees for u%Fcs positions is the
                          Internatio      Trade Administration-c’sm       Exchange Program. Fourteen
 rcgram Used to Hire      of the 33 Liibkcs non-career limited appointees employed during the time
 .mited Appointees From   frame covered b-y our review were selected from the exchange program
 ther ITA Units           between US&FCSand domestic ITA units. According to L’WFCSofficials,
                          this program was designed to allow civil service employees of ITA domes-
                          tic offices to work in U%FCSoverseas assignments and to allow US&FCS
   ..                     Foreign Service officers to work in assignments within the United
   q%ik                   States. However, no policy or guidelines have been developed to define
  .<’                     the purpose,   scope, or eligibility requirements for the rr~-us&m
          $f              Exchange Program, even though it isused as a major avenue of entry of
                          limited appointments into the Foreign Commercial Service.

                          We believe the Fisk of guidelines for the exchange program has contrib-
                          uted to questions being raised         other career officers about the
                          vali&ty of the selection process.        lieve a written policy would
                          enhance the credibility of this program.

&estionable Selection                                     g the selection of Qp individuals serving
                                                       ere about to expire raises questions about
  **;                                                  ihty of t$ selection process.
                                                                                          tor General
                                                             to career~t&e          status at the FP- 1
                                                                            res. In mid-1988, the
                                                                        ts for an unspecified
                                                                         process, seven candidates
                          were. considered qualified for the positions. The two candidates hired
                          were%nked third and%xth among the seven candidates competing for
                          the positions. The rankings are based on a comprehensive assessment of
                          applicant qualifications given by the us&~cs testing center. Selections are
                          usually based on rank order.

                          On April 4, 1988, before hiring the two candidates, the Director of the
                          USB~FCS’ personnel office sent a letter to all qualified candidates compet-
                          ing for the positions. The letter encouraged them to compete for lower
                          FP-2 (GS-14 equivalent) positions, and said that budget constraints
                          made it.?unlikely that U%FCSwould hire career candidates at the FP- 1

                          Page7                   I                      GAO/NSUKMM1Export     Promotion

                       level in the foreseeable future.” The letter further stated that “It C;LI
                       be guaranteed that even the highest-ranking FP- 1 level candidates
                       would receive an offer of appointment.”

                       Four candidates accepted this advice and agreed to eliminate themstl.
                       from competition at the higher level. After these four ranked candid<
                       removed themselves from competition, FP-1 jobs were offered to the
                       lower-ranked candidates who were serving limited appointments. Th,
                       two candidates accepted offers at the FP-1 level. Another candidate ~3
                       was also offered a position at this level declined the offer.

                       In response to our inquiries about these selection procedures, I'SC(IFC-c:
                       officials involved in the selection process told us that there was no SIL
                       nificant change in the LBLWCSstaffing situation during the entire pro-
                       cess-from applicant assessment to final selection-that       could justif,
                       the need to use these procedures. They also said that, to their knowl-
                       edge, this was the first time that these procedures had been used in tIIf
                       selection process.

                       The Omnibus Trade and Competitiveness Act of 1988 directs the .\mer
Level of Commercial    can Institute of Taiwan (AIT), the unofficial organization that promotes
Staff in Taiwan Does   U.S. interests in Taiwan, to employ a number of commercial personnel
Not Comply With        commensurate with the number of LJSWISpersonnel permanently
                       assigned to the U.S. diplomatic mission in South Korea. AIT has only
Requirements of Law    three full-time professionals performing commercial duties. The I--..$.
                       Embassy in South Korea, by comparison, has six.

                       Because of this staffing shortfall, AIT reported that it is unable to ade-
                       quately service the large number of requests for assistance it receives
                       from the U.S. business community and to monitor important trade dev,e
                       opments in Taiwan, the United State’s fifth largest trading partner.

                       Commercial staff levels in Taiwan are not funded nor determmed by tht
                       u.%Fcs but by AIT, which receives a separate appropriation from Con-
                       gress to fund its operations. LJSLW~Scommercial officers are separated
                       from the service before filling MT positions. An official from the AIT tol(l
                       us that the Institute does not presently have the resources to hlre any
                       additional commercial staff and that Congress or the Department of
                       Commerce needs to give more money to the Institute for this purpose.

                       Page 8                                         GAO/NSIAtHO-$1 Expm Fromc,

                      To safeguard the integrity of the Foreign Commercial Service and main-
mclusion              tain a highly motivated officer corps, the CS&FCS needs more consistency
                      in its personnel management system. Substantial progress has been
                      made since our last review. However, exceptions to stated policies and
                      the lack of clear policies in some areas continue to detract from the per-
                      sonnel management system. The L'S&FCScan take additional steps to
                      make the assignment and selection processes more transparent and pre-
                      dictable. In addition, the staffing shortfall at AIT has not been ade-
                      quately addressed.

                      To improve the administration of the US&M=S  personnel management sys-
:ecommendations       tem, we recommend that the Secretary of Commerce direct the Cnder
                      Secretary of the International Trade Administration to:

                  l    revise cs&FcS assignment policies on curtailments to require a written
                      justification that explains why it is in the best interests of the service to
                       curtail an officer’s assignment when other career officers are available
                       to fill the position, and
                  l    develop guidelines outlining the purpose, scope, and selection require-
                       ments for the ITA Exchange Program.

                      In addition, the Executive Director of the American Institute of Taiwan
                      needs to:

                  l   either seek through appropriate channels additional resources from
                      Congress to ensure that commercial staff levels at the American Insti-
                      tute of Taiwan are equal with those in South Korea, as required by the
                      Omnibus Trade and Competitiveness Act of 1988, or seek legislative
                      relief from this requirement.

                      As requested, we did not obtain formal agency comments on this report;
                      however, we discussed our findings with appropriate Commerce Depart-
                      ment and American Institute of Taiwan officials and incorporated t heu-
                      comments where appropriate.

                      As arranged with your office, unless you publicly announce its contents
                      earlier, we plan no further distribution of this report until 30 days from
                      the date it is issued. At that time, we will send copies to the Secretary of
                      Commerce and appropriate congressional committees and make copies
                      available to other interested parties upon request.

                      Page 9                                          GAO/NSlAIMO-61 Export Pwmotion

This report was prepared under the direction of Man I. Slendelowitz
Director. International Trade and Finance Issues, (202) Yi5-4812. Thl
principal GAO staff members responsible for this review were Benjam
Nelson. Assistant Director, Stephen Lord, Evaluator-in-Charge. and t:
bara Wooten, Evaluator.

Sincerely yours,

Frank C. Conahan
Assistant Comptroller General

Page 10                                      GAO/NSL4MO-6I Expan f’romc:
Page 11   GAO/NSLUMO4l Expm -ion
ChangesMade in Time-In-ClassPolicy

              One of the unique features that distinguishes the Foreign Service frc
              its Civil Service counterpart is the “up or out” principle. Its obJectKc
              to ensure continued high quality staffing in U.S. missions overseas. I
              tally, an officer must be promoted through merit selection m a certa
              length of time or else be involuntarily separated from the Foreign St,
              vice, or as commonly referred to, “TICed out,” with TIC representing

              In our last review, we said the C‘S&FCS could lose a large number of gc,
              experienced officers over a short period of time under its existing tin
              in-class policy, which is the most stringent of the Foreign Sewice agts
              ties. We concluded that the number of people hired at the upper le\,e:
              had limited the promotion opportunities for officers who began their
              career in entry- or mid-level positions, and the impact of such hiring
              practices would be most acute at the ~3-2 level. We also noted that LV~
              could find no justification for the us&M=s’TIC policy, and that LS&FCS
              management should thoroughly review this policy. Such a review. in
              response to changing needs, is envisioned in the Foreign Serv3ce Act.
              which allows for changes in time-in-class limits. US&KS officials agree
              to review the policy and make changes, if needed. Reviews of the L&U
              time-in-class policy were completed in June 1988 and October 1989.

               The June 1988 review noted that several of the most senior and expe-
               rienced Senior Foreign Service officers may be TICed out before reach
               ing mandatory retirement age. All officers at the Minister-Counselor
               level were promoted to this level after serving only three of the eight
               years allowed in the Counselor position (the rank just below Minister-
               Counselor). When promoted, they in effect “lost” 5 years of TIC that
               they would have had if they had remained at the Counselor level. Thu
               these officers’ TICS will expire before they gain the minimum years of
               service needed to earn immediate retirement benefits.

               The October 1989 review also noted that in the years 1994 through
               1996, the US&KS will lose 27 officers due to the expiration of their timt
               in class. Of these, 22-or approximately one-third of the entire class-
               are projected to be from the ~3-2 level. Also, substantial additional loss+
               are likely to occur in succeeding years. The review concluded that thest
               losses will be of significant concern to management because a large per
               centage of experienced, relatively senior US&FCS officers ~111be lost
               within a period of a few years, and many of these officers w11Inot be
               eligible for retirement when they are TICed out.


               Page12                                        GAO/NSIADSOSI Expm    Prom
                                          Appendix I
                                          Changes Made ln TlmelnClaa.9 Policy

                                          The policy was revised in ,January 1990 to correct the weaknesses iden-
                                          tified in the studies. Table I. 1 shows the new time-in-class guidelines
                                          used by the CSWCS.

ble 1.1: Maximum time-In-Class   Limits
                                                                                 Maximum Lenqth of Service Under
                                          Personal Rank          Former Policy         New Policy
                                          Career Mlntster                              4
                                          Mlnlster-Counselor     z                     13 years’ combined experience at Mlnlster-
                                          Counselor              8                     Counselor and Counselor level with no more
                                                                                       than 8 In Counselor level
                                          FS-1 and FS-2          15 years with no more 20 years’ expenence In FS-1 through FS-4
                                                                 than 8 years at the   levels, with no more than 15 years in any
                                                                 FS-2 level            class
                                          FS.3                   5
                                          FS-4                   5

                                          USMIS career candidates serve an apprenticeship period in the Foreign
ChangesMade in                            Service to demonstrate their suitability for career status as commis-
2ommissioning and                         sioned Foreign Sewice Officers. The UEMXSCommissioning and Tenure
renure Policy                             Board determines whether these officers have performed at a satisfac-
                                          tory level and demonstrated the required level of competence and
                                          growth potential.

                                          Under the former policy, which was changed in October 1989 in
                                          response to concerns we expressed to U~MCSmanagement, the key crite-
                                          rion for favorable judgment by the Board was the demonstrated poten-
                                          tial to perform effectively as a Foreign Service Officer in a normal range
                                          of assignments up through the FS-1level. There was, however, a conflict
                                          with this criterion: Board members were also directed not to disadvan-
                                          tage applicants for commission and tenure who served in “nontradi-
                                          tional” positions and thus were not able to demonstrate a full range of
                                          traditional duties in overseas posts. The conflicting guidance thus poten-
                                          tially allowed candidates with little or no export promotion experience
                                          to be commissioned and tenured as a Foreign Service Officer before dem-
                                          onstrating the potential to perform effectively in a normal range of
                                          usgr~csassignments. We note that the Foreign Commercial Service was
                                          created in 1980 because Congress was not satisfied with the State
                                           Department’s overseas trade promotion efforts. Specifically, a 1977
                                           investigation by the House Committee on Government Operations stated
                                           that the State Department had failed to recruit employees with strong
                                           commercial backgrounds to perform commercial functions.

                                           Page 13                                              GAO/NSIAD90-51 Export Pmnotion
                      Appendix I
                      ChangesMade in lImeIn-   Policy

                      In October 1989, the L’SUTS commissioning and tenure policy was
                      revised. Under the new policy, the Board may determine that a cart
                      candidate has demonstrated the required potential while serving m
                      nontraditional position. Thus, the candidate is not assured that serl
                      in a “nontraditional”  position is sufficient for tenure review, as wa..
                      case under the previous policy. Furthermore, the Director General 3,
                      that US&FCSmanagement is now notifying tenure candidates in nont
                      tional positions that they should seek opportunities to demonstrate
                      export promotion capabilities in traditional positions before facing I
                      ure determinations.

                      In our earlier review, we found irregularities in the performance
Changes Made in the   appraisal process and noted that the USMYS’instructions in this are;!
Performance           were inadequate in that they did not spell out the duties and respon<
Appraisal Process     ities of rating and reviewing officials and the procedures to be folloJf
                      Accordingly, we suggested that the LJ~        adopt new appraisal proct
                      dures. CS$FCSofficials agreed with our assessment. They have develc
                      new appraisal guidelines for members of Commerce’s Foreign Servict
                      better clarify and identify individual accountability in the rating pro-
                      cess. This policy guidance was issued on April 1989.

                       Page 14                                       GAO/NSL4D9O-SIExpm Prnc
  pendix II

  bbjectives,Scope,and Methodology

               Our observations on the CS&FCS' overseas assignment process are based
               on our review and analysis of the results of the 33 LBFCS assignment
               panels held between April 1987 and July 1989. Over this time period,
               the panel made about 180 assignments. Assignment panel membership
               generally includes: (1) the Director General as Chair, (2) the Assistant
               Secretary for Trade Development, (3) the Assistant Secretary for Inter-
               national Economic Policy, (4) the Deputy Assistant Secretary, Office of
               Foreign Operations, and (5) the Assignments Officer, Office of Foreign
               Service Personnel. We also examined Office of Foreign Service Personnel
               records, reports, and memoranda. Most of the personnel actions we ana-
               lyzed for this review predate the tenure of the current Director General.

                In addition, to obtain information and perspective about how the CS&FCS'
                personnel management system operates, we interviewed various us&Fcs
                officials, including senior career officers and staff in the Office of For-
                eign Service Personnel and the Office of Foreign Operations. We also
                interviewed officials from the International Trade Administration’s
                office of Trade Development and International Economic Policy and offi-
                cials from the American Institute in Taiwan, the U.S.’ representational
                office in Taiwan.

                ITA'S possible overobligation of fiscal year 1987 funds, which you also
                requested GAO to examine, is being reviewed by our General Counsel and
                will be addressed in a separate report if significant deficiencies are

                Our review was conducted in accordance with generally accepted gov-
                ernment auditing standards from May 1989 to October 1989.


(463626)        Page16                                         GAO/NSLAD9@6lExponRomotion

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