ML20006E871
| ML20006E871 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1990 |
| From: | David Williams NRC OFFICE OF THE INSPECTOR GENERAL (OIG) |
| To: | |
| References | |
| OIG-89A-019, OIG-89A-19, NUDOCS 9002260463 | |
| Download: ML20006E871 (15) | |
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I OFFICE OF THE INSPECTOR GENERAL U.S. NUCLEAR REGULATORY COMMISSION E
Review of the Non-SES Performance Appraisal System r
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CFFICE OF THE INSPECTOR GENERAL g
MEMORANDUM FOR:
Chairman Carr Commissioner Roberts Commissioner Rogers Commissioner Curtiss commission:r Remick FROM:
David C. Williams Inspector General Office of the Inspector General
SUBJECT:
REVIEW OF THE NON-SES PERFORMANCE APPRAISAL SYSTEM The Office of the Inspector General (OIG) has completed a review of the Nuclear Regulatory Commission's (NRC) performance appraisal system for Washington area non-Senior Executive Service (SES)-employees.
The objectives of the audit were to review (1) the internal controls in place to ensure that eligible employees are rated in accordance with NRC Manual Chapter 4151, and (2) the office of l
Personnel's ' (OP) role in the performance appraisal (PA) system.
Specifically, we wanted to verify th_,t NRC employees are raceiving their pas and their perforeance elements and standards in a timely manner and in accordance with NRC Manual Chapter 4151.
Our review was conducted in accordance with generally accepted Government auditing standards.
The review was performed at NRC
-Headquarters from June 1989 to October 1989.
Conclusions and Recommendations l
While'our review did not identify major. deficiencies in NRC's non-SES performance appraisal system, we did find that improvements are needed.
Our report contains four recommendations addressed to the Director, OP.
The recommendations are intended to (1) improve OP oversight of the l.
non-SES performance appraisal system, (2) develop a follow-up
-system to ensure that office directors are certifying that o
appraisals have been issued, and (3) require office directors to certify that performance plans are in place for all employees.
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3 JAM 30 %M Aaency Comments In his memorandum of January 18, 1990, the Executive Director for Operations agreed with our recommendations and indicated the l actions that would be taken to implement them.
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hMC. W 'M David C. Williams Inspector General Office of the Inspector General l
Attachment As stated 1
cc w/ attachment:
J. Taylor, EDO S. Chilk, SECY W. Parler, OGC.
P. Bird, OP J. Blaha, EDO L. Hiller, ICC i
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l REVIEW OF THE NON-SES PERFORMANCE APPRAISAL SYSTEM L
INTRODUCTION The Office of the Inspector General (OIG) has completed a review of the Nuclear Regulatory Commission's (NRC) performance appraisal system for Washington area non-Senior Executive Service (SES) employees.
The review was initiated to determine what improvements have been made since an October 1982 audit by NRC's Office of Inspector and Auditor, entitled, " Review of the Division of Organization and Personnel," indicated that only 71 percent of NRC employees in our sample who were eligible for performance appraisals (PA) in 1981 received such an appraisal in accordance with Manual Chapter (MC) 4151, "Non-SES Performance Appraisal System."
MC 4151 implements the Office of Personnel Management's (OPM) regulations relating to non-SES performance appraisals.
Our overall objectives were to review (1) the internal controls in place to ensure that eligible employees are rated in accordance with MC 4151, and (2) the Office of Personnel's (OP) role in the PA system.
Specifically, we wanter to verify that NRC employees are receiving their pas and their performance elements and standards in a timely manner and in accordance with MC 4151.
BACKGROUND OD's function is to plan and implement NRC policies, programs and services to provide for the effective organization, utilization and development of the agency's human resources.
In addition, OP is responsible for assuring procedural compliance with MC 4151.
The PA system is important because it is used to determine eligibility for incentive awards, noncompetitive career promotions, within-grade increases, and High Quality Increases, i
and for granting extra credit during reductions-in-force.
- Also, l
under NRC's agreement with the National Treasury Employees Union, L
pas are assigned a weight of 20 percent towards a bargaining unit employee's final rating for merit promotion.
Each employee should normally receive a PA at the end of each fiscal year (FY).
In general, all employees who have worked
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l under a current performance plan for at least 120 calendar' days should receive a PA by October 31 for the rating period ending September 30.
According to MC 4151, beginning in FY 1987 all performance plans should include at least three but no more than six critical elements.
Non-critical elements should not be used.
OP defines l'
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2 a critical element as "a component of a position consisting of one or more duties and responsibilitics which contributes toward accomplishing organizational goals and objectives and which is of such importance that unacceptable performance on the element would result in unacceptable performance in the position."
Employee's can be given one of the five following ratings:
(1) Outstanding (2) Excellent, (3) Fully Successful, (4) Minimally Successful, and (5) Unacceptable.
These ratings are documented on NRC Form 412, Non-SES Performance Appraisal System Summary Rating.
To ensure that employees and supervisors have a common understanding of what is expected of employees, the employees should be told early in the appraisal period and in writing, through their elements and standards, what is expected from them.
Generally, all supervisors should provide each of their employees with a performance plan (documented on NRC Form 412A, Non-SES Performance Appraisal System, Performance Plan) within 30 calendar days after the beginning of the new appraisal period (October 1) or no later than 30 calendar days after the effective entry date when an employee is: (1) newly hired, (2) promoted, (3) reassigned, (4) detailed or temporarily promoted for at least 120 calendar days, or (5) changed to a lower grade.
Employees have five working days to review and sign the plan.
While OP is responsible for monitoring the PA system, the OP representatives in OP's satellite offices are responsible for revicwing pas for procedural accuracy.
Any PA that does not meet the criteria set forth in MC 4151 in supposed to be returned to the supervisor for correction.
A13 managers and supervisors are accountable under their critical element for managemont supervisory effectiveness for preparing pas on subordinates.
SCOPE OF REVIEW Our review was performed in accordance with generally accepted Government auditing standards.
The principal objectives were to review: (1) the internal controls in place to ensure that eligible employees are rated in accordance with MC 4151, and (2) OP's role in the PA system.
The audit period we initially expected to cover was FY 1986 to FY 1988.
However, it appeared that significant problems with the non-SES performance appraisal system in FY 1987 resulted largely from a major reorganization in NRC in April 1987.
Thus, this report does not discuss the 1987 findings because they may have skewed our conclusions.
As a result, our audit findings are based only on an analysis of FY 1988 data.
Our audit was performed from June 1989 to October 1989.
With the assistance of an NRC statistician, we randomly celected a sample of 200 Headquarters employees.
We reviewed the Employee Performance Files (EPF) of each employee included in our sample.
The EPF contains the employees' pas for the last three years.
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According to MC 4151, each document in the EPF will usually be retained by OP for three years from its effective date.
In many cases, our review of EPFs resulted in questions which j
necessitated a review of the employee's Official Personnel Folder (OPF).
The OPP contains the employee's personnel history as an NRC employee.
Included in the OPF are all the Notices of Personnel Action (Standard Form 50) and other vital information on the employee.
Where documents, including pas, were missing from both the EPF and OPF files, we interviewed the employees to obtain the documents and discuss the PA system.
Based on the results of our document reviews and interviews, we prepared some statistical analyses for each of the offices within NRC.
Of the 2,048 Washington area non-SES NRC employees for FY 1988, 1,671 employees (81.6 percent) received a PA for FY88 (see Appendix I).
Our sample of 200 employees was selected from the 1,671 employees receiving pas based on the weighted-average method to ensure that all the offices in NRC were proportion-ately represented.
The sample size was for a 95 percent confidence level and an expected 20 percent error rate plus or minus 5 percent.
An NRC statistician assisted us in determining the appropriate sample size.
We excluded five employees from the cample in our analysis of the timeliness with which employees received their performance plans because we were unsure as to the start of their appraisal periods.
We excluded two employees from the sample in our analysis of the timeliness with which employees received their pas because one employee never received a PA and the other refused to sign the PA.
During the audit, we reviewed MC 4151 and other documentation relating to the PA system.
We also interviewed responsible OP officials regarding the implementation of the PA system in NRC.
FINDINGS As we noted earlier, our review showed significant problems with the non-SES performance appraisal system in FY 1987.
However, it appeared these problems resulted largely from a major j
reorganization in NRC in April 1987.
In FY 1988, compliance with MC 4151 improved sharply although we still noted problems with l
some employees' performance plans and the timely issuance of some appraisals.
l Based on our analysis we found that in FY 1988 (see Appendix II):
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o 121 of 195 employees in our sample (62.1 percent) did not receive their Elements and Standards (Performance Plans) within 35 days of the start of the appraisal period.
o 42 out of 198 employees in our sample (21.2 percent) did not receive their pas within 35 days after the appraisal period ended.
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l We also found problems in OP's receipt of certifications from
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office directors that all required performance appraisals had been given.
In addition, no similar certification is required by office directors to assure that employees' performance plans are in place.
Each of these issues is discussed in the following sections of this report.
j PERFORMANCE PIANS Our review of the performance plans for the 196 employees in our sample that received pas showed that, for the nost part, i
employees' performance standards were appropriate.
However, for 12 of the 198 employees in our sample (6 porcent), we believe the elements and standards were not in compliance with MC 4151 r
because the standards appeared to be vague and subjective.
For example, some employees had a critical element entitled " Service l
Excellence."
One standard under this element stated that the employee " reflects a positive 'can do' attitude and an adherence to timeliness in response to both routine and exceptional work assignments."
Another standard under this, element said that the employee " conveys (a) courteous and professional manner in communication."
i MC 4151, Part II, paragraph B.8 states in part that:
Performance standards should be as objective as possible...
c.
Genert;l traits of behavior and personal characteristics (such as " intelligence," " judgement," " dependability,"
and " cooperativeness," etc...) do not provide an adequate basis for making an objective appraisal of the employee's performance.
d.
Insure that standards can be attained and exceeded....
We believe that standards such as the above examples are not objective, cannot be exceeded, and represent traits of behavior; all of which are not consistent with MC 4151.
According to a Personnel Management Analyst in OP, OP does not review the elements and standards for compliance with MC 4151 because of a lack of staff.
Based on our sample, we found that 121 out of 195 employees (62.1 percent) did not receive their elements and standards within 35 days (employees have five working days to review and sign the plan) of the start of the appraisal period.
Of the 121 cases, 29 employees received their FY 1988 elements and standards between 36 and 60 days after the start of the performance period; 47 employees received their elements and standards between 61 and 90 days after the appraisal period had started; 25 employees received their elements and standards between 91 and 120 days after the start of the period; and the remaining 20 received
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their' elements and standards more-than 120 days after the appraisaliperiod had started.
- One reason why some employees receive their elements and-
. standards late 11s because supervisors forget to issue new elements-and standards following promotions'and reassignments.
During our' review, we noted that when NRC hires a new employee, OP reminds the employee's office to develop elements and 3;
standards within-30 days.
However, a Personnel Management i
Analyst in OP told us that NRC offices do not receive a similar reminder to. issue elements and_ standards to employees recently
. promoted _or. reassigned.
The Analyst said that it was easier to
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- send'a' reminder for new employees because OP could track the employee-based on'the Entrance on Duty list.
The Analyst also, added'that it would take more manpower to send reminders for-promoted or: reassigned employees.
In the meantime, it is up to individual offices to remember to develop performance plans for newly promoted or reassigned employees.
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PERFORMANCE. APPRAISALS T
Based on our sample, we found that 42 out of 198 employees (21.2
. percent)'did not receive their pas within 35 days (employees have-l five working days to review, comment on and sign the PA) after the appraisal period ended.- Of the 42 cases, 22 employees
' received their FY'1988 pas between 3G and 49 days after the Jraisal-period ended,^13 employees received-pas between 50 and days after.the period ended, and the remaining seven received
.eir FY 1988 pas more than 70 days after the period ended, aly'one employee in our sample did not' receive anLFY 1988 PA; towever, our sample was taken from an OP list of employees who had supposedly received pas.-
Statistics compiled by OP for FY
- 1988 show that 182 (8.9 percent) of 2,048 Headquarters non-SES employees'did not receive FY 1988 appraisals for unknown reasons.
-An OP official told us OP does not have a system to' follow up on employees'not-receiving pas.
We also found the following discrepancies in our sample:
Five (2.5 percent) employees.were incorrectly given an FY 1988 PA early.because they received promotions near the end of FY 1988.
Two of these five employees were. listed on their office directors' certification letters, however, indicating dates when pas would be given at their higher j
grade.- According to MC 4151, these five employees should have_ received an interim rating due to a change in position and then served 120 days at the higher grade to receive their~ rating of record.
In addition to the five employees that received FY 1988 pas
.early due to promotions, we found 13 other cases in which the performance period ended on dates other than September 30, 1988.
In 10 of the 13 cases, it appears i
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l un that'the employees' appraisal periods were extended because their performance periods were not a full 120 days..That is, the employees received their elements and standards so late in FY 1988 that the performance period had to be extended into FY 1989.
The performance period for.another two employees ended after
' September 30, 1988, even though they had received their elements and standards early enough to be rated with 120 i
days performance on September 30.
One employee's appraisal period was extended to November.4, 1998, simply because the employee's supervisor changed and the new supervisor wanted 120 days to appraise the employee.
An OP Personnel Management Analyst stated that the supervisor does not have to be supervising for 120 days to give a PA.
We were unable to determine-the beginning of the appraisal period of five employees because the PA was never given, the beginning date was left blank, or the PA contained an
'1 obvious error.
We also found situations where there were obvious errors in the appraisal period when the employee received a promotion, a reassignment, or other personnel action.
The PersonnelLManagement Analyst in OP who was responsible for the non-SES PA system at the time of our audit stated that OP 1
does not have the time to read the narrative comments in pas.
However, OP_does check for minimum requirements and for signatures and dates on the forms.
OP also ensures that the summary-rating is mathematically correct and the blocks. checked on the PA match the summary rating.
If employees are not provided with performance appraisals as required, the process becomes ineffective in measuring, tracking, and improving individual employee productivity.
DIRECTOR'S CERTIFICATIONS In general, NRC supervisors annually rate the performance of their employees during October.
In accordance with MC 4151, the Office Directors are to certify in writing to the Director, Office of Personnel, by November 1, that their employees have been appraised and given a copy of the PA.
OP telephones delinquent offices to request they submit their certification letters.
Often the Office Directors will attach to their certifications a list of employees who were not given pas for the L
fiscal year just ended and a date by which these pas will be done..There is no follow-up system in OP to ensure that the pas are done as noted.
4 For FY 1988, OP informed the various Office Directors that the Certification would be due to OP by November 15, 1988.
When reviewing OP's Certification Files for FY 1988 we found that only 13 out of 29 offices sent their certifications to OP by a
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i November 15,.while another eight offices sent in their certifications after the deadlines.
One office's certification letter was undated.
We were unable to find certification letters for seven offices.
Although directors are not normally required to file a certification that performance plans are in place, they were required to do so in FY 1988.. An OP memorandum dated July 18, 1989, _ required office directors to certify to OP by August 1,
'1989, that all non-SES employees in their offices / regions have i
performance plans in place for FY 1989.
We believe the certification of the existence of performance plans.is good; however, the certification for FY 1989 performance plans should l
have been in place by November 1, 1988, when the FY 1989 plans-
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were required to be in place.
CONCLUSIONS 4
While our review did not identify major deficiencies in NRC's I'
.non-SES performance appraisal system, we did find that L
improvements are needed.
We believe OP needs to improve its l
oversight.of the non-SES PA system to assure that elements and L
standards and performance appraisals are issued as required by MC 4151.
Also, OP requires office directors to certify that performance appraisals have been issued but does not follow up i
with offices not providing certifications, or to assure pas are L
eventually issued as directors' certify.
Office directors are not currently required to certify at the beginning of each fiscal year that performance plans are in place for all employees.
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RECOMMENDATIONS' j
l We recommend that'the Director, OP:
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Require the Director of each office / region to certify at the beginning of each annual performance period that all L
employees have elements and standards in place.
2.
Institute a system to follow-up with office directors' who have not issued required certifications regarding pas, and to ensure that employees scheduled to receive their pas p
after the end of the rating period actually receive the pas.
3.
Establish a procedure similar to the one for new employees to remind offices of the need to give elements and standards
.to-newly promoted or reassigned employees.
4.
Annually examine a sample of the issued elements and standards for NRC employees to ensure that they are' consistent with MC 4151.
If the sample identifies problems with specific employees' elements and standards, take steps to have them corrected.
If office-wide problems are.iden-tified, take steps to correct the problem, possibly through L
training programs for supervisors.
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AGENCY COMMENTS.
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-In his memorandum of January 18, 1990, the Executive Director for.
l Operations agreed-with our recommendations'and indicated the
- actions that would be taken to implement them.
A copy'of'the EDO's comments'is included as Appendix III to this report.-
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Appendh 1 o
'P NRC i
COMPLIANCE AhAlf$ll FYl0 C0nPLIANCE COMPLIANCE NON COMPLIANCE NON COMPLIANCE TOTAL OFFICE 4 0F RfClivtD Ntti OT DUt N0 f.65.s OR MIS $1NG NONCOMPLIANCE N
[MPL0ftts. A P. A.
0A DEFERRil NO P.A. $1vtu Ptattuin$
.........................................................................................t ACtl 20 23 2
0 3
10.71 At0D 104 le 7
0 11 10.61
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ARM 417 306 15 21 75 23.01-ASLAP 6
6 0
.0 0
0.01 r
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ASLDP 10 3
0 4
22.21
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L COMM 20 23 2
0' 3
10.71 L
C0n$
6 6
0 0
0 0.01 C8 18 13 0
1 4
27.7%
- ED0 10 16 2
0 0
0.01 SPA' 61 39 4
11 7
29.51 MSS 235 193 20 0
22 9.41
(
SR 521-455 37
.12 17 5.6%
OE 10 t
.0 0
1 10.01 OSC 90 84 4
0 2
2.21 01
- 41 31 0
8 2
24.41 01A 26 21 2
2 1
!!.51 SP -
73 65 4
0 4
5.51 OSP 85 71 1
0 3
3.51
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RES 226 192 30 3
1 1.81 SDSUCR 8
0 0
0 0
0.01 SECT 29 13 0
0 16
..............................................................................$5.21 701ALS 2,048 1,671 143 58 176 11.41 9 5 8 28 8 8 3 8 8 2 8 8 8 3 31119 3 33 8 8 8 3 3 88 38 318 88 3 8 8 8 8 218 8 5 5 818 8 8 318 8 8 8 8 8 38 8 t S 8 8 Note: Another sixteen employees either retired, resigned or left the agency and were not included in this schedule.
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1 Appendix 11 I
DC SAMPLE ANALYSIS ffB0 4
LATE 1 0F LATE 1W 40F 4126 412s 412As 412As 0FFICE EMPLOYEES pas.PAsLATE E4Si E6SsLATE OTHER COMMENTS j
Acts 3
0 0.01 0
0.01 AE00 10 2
20.01 1
10.01
- ARM 37
.10 48.71
- 20 55.61 ONE 412A IS UNIN0NN BECAUSE SHE $16NED 11 NINE MONTHS EARLY.---
- 48 LAP 1
0 0.01 0
0.01 ASLDP-1 0
0.01 1
100.01 i
b COMM 3.
3 100.01 3
100.01 1-l l
CONS 1
0 0.01 1
100.01 l
Cl 1
1 100.01 1
100.01 ll EDO
'2 0
0.01 0
0.01 ONE 412A OMliit$ INE'STARI 0F THE APPAAISAL PERIOD.
L I
- OPA.
5 0
0.01 3
75.01 INO 412s ARE UNKNOW BECAUSE ONE EMPLOYEE 010 NOT 6El A 412 4
(AND A 4124) AND THE OTHER PERSON REFUSED 10 SI6N HIS 412.---
NMS$
23 2
I.71 16 72.71 ONE 412A UNKNONN NCAUSE 11 OMil1ED THE START OF THE -
i APPRAISAL PERIOD.
WR 54 0
0.01 44 13.01 DNE 412A UNKNOW MCAUSE 11 OMillED THE APPRAISAL PERIOD.
l-:
GE 1
0 0.01 1
100.01 1
i; OSC 10 0
0.01 1
10.01 p
L 01 4
0 0.01 4
100.01
\\
i-01A 3
0 0.01 2
66.71 OP 1
0 100.01 1
12.51 MANY HAD A Ff86 APPRAISAL PERIOD OV 6/30 10 10/30/88 AND NEAT STANDARDS ON THE 412A.
OSP 0
1 12.51 5
62.51 RES 23 6
26.11 15 65.21 I' a 5090CR 1
0 0.01 1
100.01 SECY 1
1 100.0X 1
100.01 TOTALS 200 42 21.21 121 62.11 8 8 8 8 3 5 3 3 3 3 3 3 3 33 3 3 3 8 3 3 3 33 4 313 E& t8 8 3 3 3 3 3 313 328 8 333 5 8183 3 33 3 531833 8 8 33 33 3 r 3 3 3 33 3 3333 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 333 3 3 3 3 3 3 3 3 3
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Appendix'!!!
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' [aucq%g UNITED STATES g-NUCLEAR REGULATORY COMMISSION
_ p, nt WASHINGT ON, D. C. 20555 k...../
JM 1B W MDORANWM FOR:
David C. Williams Inspector General FROM:
James M. Taylor Executive Director for Operations SUR7ECT:
REVIEW OF 'IHE NON-SES PEPJORMANCE APPRAISAL SYSTD4 I am respoMing to your draft audit report, " Review of the Non-SES INarformnce Appraisal System." We are pleased that your audit did not identify major deficiencies, and we support your r+,-. =dations for improving the system.
Our responses to your re-. ardations are provided below, h
--dation 1 l'
Require the Director of each office / region to certify at'the beginning of each l
annual performance period that all enployees have elements and standards in place.
BDSPowe L
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Agree. W e Director, Office of Personnel, will ask all Office
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Directors / Regional Administrators to certify in writing to him annually by i
' November 1 that all employees have a performance plan in place.
In' instances I
where delays will occur, the certification will require the dates when the plans will'be put in place. For this year the Director will issue a memoraMum i
l requiring certification by March 1.
Canpletion date: February 15, 1990.-
P -,-----dation 2 Institute a system to follow-up with Office Directors who have not issued
' required certifications regardirg performance appraisals, and ensure that employees scheduled to receive their performance appraisals after the end of the rating period actually receive them.
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Response
Agree. On November 15 of each year the Director, OP, will follow-up by memoranda to Office Directors and Regional Administrators who have not issued I
the required certifications. Office. Directors aM Regional Administrators will be asked to certify within two weeks that performance appraisals have been completed and will be remiMed of their responsibility for appraisirg their subordinates. 21s year's follow-up memoranda will be issued on February 15.
l Completion date:
February 15, 1990.
2e Director, OP, will require that all certifications identify those enployees who will receive performance appraisals after the end of the rating period and specify a date for conpletion of those perfomance appraisals.
Se Director, OP, will establish a tickler system for future perfomance
~ appraisal cycles.- OP will follow-up with the appropriate Office Directors or Regional Administrators if the coupleted appraisals are not received in OP' within 30 days of the date specified in their certification, h -----+dation 3 Establish a procedure similar to the one for new enployees to remind offices of the need to give elements and standards to newly prmoted or reassigned enployees.
Respanne Agree. We Office of Personnel will develop a system by which the supervisor and employee will be notified of this requirement when the Form 50 has been issued officially promoting or reassigning the employee. m is action will ocanmence on April 1,1990.
% --- -4 dation 4 Annually examine a sample of the issued elements and standards for NRC enployees to ensure that they are consistent with Manual Chapter 4151. If the sample identifies problems with specific enployees' elements and standards, take steps to have them corrected. If office-wide problems are identified, take steps to correct the pInblem, possibly through training programs for supervisors.
Response
Agree. mis year the Office of Personnel will examine a number of performance plans in connection with a perfomance appraisal study ' directed by the Commission. - We results of this study will be reported at the EDO Briefing to the cammission in April. At the start of each new fiscal year OP will examine a sample of perfomance plans to ensure consistency with Manual Chapter 4151.
LImproved perfomance appraisal training is now. in place for managers and supervisors.
It can be further nodified should OP identify additional problems that need correction. Completion date: Annually in November.
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or ec.ati Director for Operations W