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Testimony: 

Before the Subcommittee on Oversight and Investigations, House 
Committee on Veterans' Affairs, House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 2:00 p.m. EDT: 

Tuesday, June 12, 2007: 

Human Capital: 

Bonuses to Senior Executives at the Department of Veterans Affairs: 

Statement of J. Christopher Mihm: 
Managing Director, Strategic Issues: 

GAO-07-985T: 

GAO Highlights: 

Highlights of GAO-07-985T, testimony before Subcommittee on Oversight 
and Investigations, Committee on Veterans Affairs, House of 
Representatives 

Why GAO Did This Study: 

Key practices of effective performance management for the Senior 
Executive Service (SES) include the linkage or “line of sight” between 
individual performance and organizational success, the importance of 
linking pay to individual and organizational performance, and the need 
to make meaningful distinctions in performance. GAO identified certain 
principles for executive pay plans that should be considered to attract 
and retain the quality and quantity of executive leadership necessary 
to address 21st century challenges, including that they be sensitive to 
hiring and retention trends; reflect knowledge, skills, and 
contributions; and be competitive. This testimony focuses on the 
Department of Veterans Affairs’ (VA) process for awarding bonuses to 
SES members, the amount and percentage of bonuses awarded for fiscal 
years 2004 through 2006 based on data reported by VA, and the Office of 
Personnel Management’s (OPM) and the Office of Management and Budget’s 
(OMB) roles in certifying federal agencies SES performance appraisal 
systems. 

GAO analyzed VA’s policies and procedures for awarding bonuses and data 
provided by VA on the amount and percentages of bonuses and interviewed 
knowledgeable VA officials. Information on OPM’s and OMB’s 
certification process was based on our 2007 report on OPM’s capacity to 
lead and implement reform. 

What GAO Found: 

VA requires that each senior executive have an executive performance 
plan or contract in place for the appraisal year that reflects measures 
that balance organization results with customer satisfaction, employee 
perspectives, and other appropriate measures. VA uses four performance 
review boards (PRB) to review and make recommendations on SES ratings, 
awards, and pay adjustments based on these performance plans. VA’s 
Secretary appoints members of three of the four boards on the basis of 
the position held within the agency, and consideration is given to 
those positions where the holder would have knowledge about the 
broadest group of executives. Members of the fourth board are appointed 
by VA’s Inspector General. VA’s PRBs vary in size, composition, and 
number of SES members considered for bonuses, and each PRB, within the 
scope of VA’s policies, develops its own procedures and criteria for 
making bonus recommendations. According to VA policy, bonuses are 
generally awarded only to those rated outstanding or excellent and who 
have demonstrated significant individual and organizational 
achievements during the appraisal period. 

As for bonuses awarded, the table below shows VA SES member bonus 
amounts for fiscal years 2004 through 2006. 

Table: Average Bonus Amount and Percentage Receiving Bonuses at VA 
among Career SES Members and by Headquarters and Field Locations, 2004-
2006: 

All; 
2004: Average amount: $16,371; 
2004: Percentage receiving: 85.4%; 
2005: Average amount: $16,713; 
2005: Percentage receiving: $79.7%; 
2006: Average amount: $16,606; 
2006: Percentage receiving: 87.2%. 

Headquarters; 
2004: Average amount: $19,195; 
2004: Percentage receiving: 82.1%; 
2005: Average amount: $18,629; 
2005: Percentage receiving: 80.2%; 
2006: Average amount: $19,439; 
2006: Percentage receiving: 81.9%. 

Field; 
2004: Average amount: $15,089; 
2004: Percentage receiving: 87.0%; 
2005: Average amount: $15,761; 
2005: Percentage receiving: 79.4%; 
2006: Average amount: $15,268; 
2006: Percentage receiving: 90.0%. 

Source: GAO analysis of VA data. 

[End of figure] 

According to data reported by OPM, in fiscal year 2005, VA awarded 
higher bonus amounts to its career SES than any other cabinet-level 
department; however, according to OPM’s data, six other cabinet-level 
departments awarded bonuses to a higher percentage of their career SES. 

OPM and OMB evaluate agencies’ SES performance appraisal systems 
against nine certification criteria jointly developed by the two 
agencies and determine that agencies merit full, provisional, or no 
certification. VA has been granted provisional certification in each of 
the years 2004 through 2006. Our review of VA’s requirements for SES 
performance plans as represented in both its 2006 submission and 2007 
draft submission to OPM show that VA made changes to the requirements 
for its performance plans to reflect greater emphasis on measurable 
results. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-985T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact J. Christopher Mihm at 
(202) 512-6806 or mihmj@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to provide the Subcommittee with 
information on the Department of Veterans Affairs' (VA) process for 
providing Senior Executive Service (SES) performance awards 
(bonuses).[Footnote 1] VA's mission is to serve America's veterans and 
their families. Through its three primary components, in fiscal year 
2006, VA operated one of the largest health care systems that provided 
services to about 5 million patients, paid cash disability benefits to 
more than 3.5 million veterans and their survivors, and operated 125 
national cemeteries in the United States.[Footnote 2] 

In our body of work on senior executive performance management, we have 
discussed how high-performing organizations understand that they need 
senior leaders who are accountable for results, drive continuous 
improvement, and stimulate and support efforts to integrate human 
capital approaches with organizational goals and related transformation 
issues. We have also identified key practices of effective performance 
management for the SES, which include the linkage or "line of sight" 
between individual performance and organizational success, the 
importance of linking pay to individual and organizational performance, 
and the need to make meaningful distinctions in performance.[Footnote 
3] In 2006, we identified certain principles for executive pay plans 
that should be considered to attract and retain the quality and 
quantity of executive leadership necessary to address 21st century 
challenges, including that they be sensitive to hiring and retention 
trends; reflect responsibilities, knowledge, skills, and contributions; 
and be competitive.[Footnote 4] 

My comments today will focus on (1) VA's policies, procedures, and 
guidelines for evaluating and awarding SES member bonuses, including 
the composition and responsibility of VA's performance review boards 
(PRB), which recommend SES bonuses; (2) the number and amount of 
bonuses awarded for fiscal years 2004 through 2006 by VA headquarters 
and field locations and compared to the amount of bonuses given to SES 
members at other major cabinet-level departments; and (3) the Office of 
Personnel Management's (OPM) and the Office of Management and Budget's 
(OMB) roles in certifying VA's and other agencies' SES performance 
appraisal system. We analyzed VA's policies and procedures related to 
the awarding of SES member bonuses for 2005 through 2007 that were 
included in VA's 2005 and 2006 submissions and 2007 draft submission to 
OPM concerning VA's SES and senior-level employee performance appraisal 
system. We also interviewed knowledgeable officials in VA's Office of 
Human Resources and Administration. We analyzed data provided to us by 
VA on the amount and number of SES member bonuses for fiscal years 2004 
through 2006 and comparable data from other cabinet-level departments 
as reported by OPM for fiscal years 2004 and 2005. The numbers we are 
presenting today are limited to SES member bonuses and do not include 
other types of SES member compensation. Information on OPM's and OMB's 
roles is based on our review of VA's senior performance appraisal 
system certification submissions and related correspondence and our 
prior work reviewing OPM's capacity to lead and implement 
reform.[Footnote 5] We conducted our work in May and June 2007 in 
accordance with generally accepted government auditing standards. 

In summary, VA requires that each SES member have an executive 
performance plan or contract in place for the appraisal year that 
reflects measures that balance organization results with customer 
satisfaction, employee perspectives, and other appropriate measures. VA 
uses four PRBs that review and make recommendations on SES members' 
ratings, awards, and pay adjustments based on these performance plans. 
Members are appointed to the boards on the basis of the positions held, 
and consideration is given to those positions where the holder would 
have knowledge about the broadest group of executives. VA's PRBs vary 
in size, composition, and the number of SES members considered for 
bonuses, and each PRB, within the scope of VA's policies, develops its 
own procedures and criteria for making recommendations. According to VA 
policy, bonuses are generally awarded only to those rated outstanding 
or excellent and who have demonstrated significant individual and 
organizational achievements during the appraisal period. In fiscal year 
2006, VA awarded an average of $16,606 in bonuses to 87 percent of its 
career SES members.[Footnote 6] At headquarters, 82 percent of career 
SES members received bonuses and 90 percent received bonuses in the 
field. Additionally, those in headquarters were awarded an average of 
about $4,000 more in bonuses than the career SES members in its field 
locations. OPM and OMB evaluate agencies' SES and senior-level employee 
performance appraisal systems against nine certification criteria 
jointly developed by the two agencies. OPM also issues guidance to help 
agencies improve their systems and reviews submissions to ensure that 
they meet the criteria. In providing concurrence, OMB primarily 
considers measures of overall agency performance, such as agency 
President's Management Agenda results. Our review of VA's requirements 
for SES performance plans as represented in both its 2006 submission 
and 2007 draft submission to OPM shows that VA made changes to the 
requirements for its performance plans to reflect greater emphasis on 
measurable results. 

We provided VA officials the opportunity to review the information 
contained in my statement. VA officials agreed that the facts presented 
accurately reflect VA's SES bonus process and results. 

Background: 

In recent years, Congress has passed legislation designed to strengthen 
the linkage between SES performance and pay. Congress established a new 
performance-based pay system for the SES and permitted agencies with 
SES appraisal systems, which have been certified as making meaningful 
distinctions based on relative performance, to apply a higher maximum 
SES pay rate and a higher annual cap on total SES 
compensation.[Footnote 7] We have testified that such SES and senior- 
level employee performance-based pay systems serve as an important step 
for agencies in creating alignment or "line of sight" between 
executives' performance and organizational results.[Footnote 8] By 
2004, an agency could apply a higher cap on SES pay and total 
compensation if OPM certifies and OMB concurs that the agency's 
performance management system, as designed and applied, aligns 
individual performance expectations with the mission and goals of the 
organization and makes meaningful distinctions in performance. Since 
2004, VA has received approval to increase the cap on SES pay and total 
compensation, which includes bonuses. 

By law, only career SES appointees are eligible for SES 
bonuses.[Footnote 9] As stated previously, agencies with certified 
senior performance appraisal systems are permitted higher caps on SES 
base pay and total compensation. With a certified system, for 2006, an 
agency was authorized to increase SES base pay to $165,200 (Level II of 
the Executive Schedule) and total compensation to $212,100 (the total 
annual compensation payable to the Vice President). Those agencies 
without certified systems for 2006 were limited to a cap of $152,000 
for base pay (Level III of the Executive Schedule) and $183,500 (Level 
I of the Executive Schedule) for total compensation.[Footnote 10] SES 
performance bonuses are included in SES aggregate total compensation. 
Agencies are permitted to award bonuses from 5 to 20 percent of an 
executive's rate of basic pay from a pool that cannot exceed the 
greater of 10 percent of the aggregate rate of basic pay for the 
agency's career SES appointees for the year preceding, or 20 percent of 
the average annual rates of basic pay to career SES members for the 
year preceding. 

VA's SES Performance Appraisal Process: 

VA requires that each SES member have an executive performance plan or 
contract in place for the appraisal year. According to VA's policy, the 
plan must reflect measures that balance organizational results with 
customer satisfaction, employee perspectives, and other appropriate 
measures. The plan is to be based on the duties and responsibilities 
established for the position and also reflect responsibility for 
accomplishment of agency goals and objectives, specifying the 
individual and organizational performance or results to be achieved for 
each element. Toward the end of the appraisal period, each executive is 
to prepare a self-assessment relative to the job requirements in the 
approved performance plan, and his or her supervisor then rates the 
executive on each element and provides a summary rating. Specifically, 
according to VA's policy on the rating process, the rater is to assess 
the accomplishment of each established performance requirement, 
consider the impact of the individual requirement on overall 
performance of the element, and assign one achievement level for each 
element. The VA rating is a written record of the appraisal of each 
critical and other performance element and the assignment of a summary 
rating level by the rater. The summary of each SES member rating passes 
to the appropriate reviewing official (if applicable) and PRBs for 
consideration. 

VA uses four PRBs to review and prepare recommendations on SES member 
ratings, awards, and pay adjustments: Veterans Affairs, Veterans Health 
Administration, Veterans Benefits Administration, and Office of 
Inspector General. The Veterans Affairs PRB has a dual role in VA in 
that it functions as a PRB for SES members who work for VA's central 
offices, such as the Office of the Assistant Secretary for Management 
and the Office of the Assistant Secretary for Policy and Planning, and 
those employed by the National Cemetery Administration. It also reviews 
the policies, procedures, and recommendations from the Veterans Health 
Administration and Veterans Benefits Administration PRBs. 

The Secretary appoints members of three of the four PRBs on an annual 
basis; members of the Office of Inspector General PRB are appointed by 
the VA Inspector General. VA's PRBs must have three or more members 
appointed by the agency head or Inspector General for the Office of 
Inspector General PRB and can include all types of federal executives 
from within and outside the agency. As required by OPM, when appraising 
career appointees or recommending performance awards for career 
appointees, more than one-half of the PRB membership must be career SES 
appointees. Federal law prohibits PRB members from taking part in any 
PRB deliberations involving their own appraisals. Appointments to PRBs 
must also be published in the Federal Register.[Footnote 11] According 
to a VA official in the Office of Human Resources and Administration, 
appointments are made on basis of the position held, and consideration 
is given to those positions where the holder would have knowledge about 
the broadest group of executives. Typically, the same VA positions are 
represented on the PRB each year, and there is no limit on the number 
of times a person can be appointed to a PRB. 

VA's PRBs vary in size, composition, and number of SES members 
considered for bonuses. For example, in 2006, VA's Veterans Health 
Administration PRB was composed of 18 members and made recommendations 
on 139 SES members while its Veterans Benefits Administration PRB was 
composed of 7 members and made recommendations on 50 SES members. In 
2006, six PRB members sat on multiple PRBs, and 1 member, the Deputy 
Chief of Staff, sat on three PRBs--the Veterans Affairs, Veterans 
Health Administration, and Veterans Benefits Administration PRBs. With 
the exception of the Office of Inspector General PBR, members of PRBs 
are all departmental employees, a practice that is generally consistent 
across cabinet-level departments. The Office of Inspector General PRB 
is composed of 3 external members--officials from other federal 
agencies' offices of inspector generals--which is generally consistent 
with PRBs for other federal offices of inspector general. 

Under VA's policy, each PRB develops its own operating procedures for 
reviewing ratings and preparing recommendations. The Veterans Health 
Administration and Veterans Benefits Administration PRBs are to submit 
their procedures to the chairperson of the Veterans Affairs PRB for 
approval and are to include a summary of procedures used to ensure that 
PRB members do not participate in recommending performance ratings for 
themselves or their supervisors. 

VA policy requires any SES member who wishes to be considered for a 
bonus to submit a two-page justification based on his or her 
performance plan addressing how individual accomplishments contribute 
towards organizational and departmental goals, as well as appropriate 
equal employment opportunity and President's Management Agenda 
accomplishments. While federal law and OPM regulations permit career 
SES members rated fully successful or higher to be awarded bonuses, 
VA's policy calls for bonuses to generally be awarded to only those 
rated outstanding or excellent and who have demonstrated significant 
individual and organizational achievements during the appraisal period. 
Beyond these policies, each PRB determines how it will make its 
recommendations. For example, a VA official from its Office of Human 
Resources and Administration told us that the Veterans Affairs PRB 
bases it's bonus recommendations on an array of the numerical scores 
assigned based on the executive core qualifications. The information 
that each PRB receives from its component units also varies. For 
example, the Veterans Benefits Administration PRB members receive 
ratings and recommended pay adjustments and bonus amounts from Veterans 
Benefits Administration units. VA policy requires formal minutes of all 
PRB meetings that are to be maintained for 5 years. The official from 
the Office of Human Resources and Administration told us that the 
minutes are limited to decisions made, such as the recommended bonus 
amount for each SES member considered, and generally do not capture the 
deliberative process leading to such decisions. Data provided by VA on 
one VA component--the Veterans Integrated Services Network--showed that 
of the bonuses proposed for fiscal year 2006, the Veterans Health 
Administration PRB decreased 45 and increased 9 of the bonuses 
initially proposed to that PRB and left the amounts of 64 unchanged. 

At the conclusion of their deliberations, the Veterans Health 
Administration and Veterans Benefits Administration PRBs send their 
recommendations to the Under Secretary for Health and Under Secretary 
for Benefits, respectively, who, at their sole discretion, may modify 
the recommendations for SES members under their authority. No 
documentation of the rationale for modifications is required. The 
recommendations, as modified, are then forwarded to the chairperson of 
the Veterans Affairs PRB, who reviews the decisions for apparent 
anomalies, such as awarding bonuses that exceed maximum amounts. The 
chairperson of the Veterans Affairs PRB then forwards the 
recommendations from the Veterans Health Administration, Veterans 
Benefits Administration, and Veterans Affairs PRBs to the Secretary for 
approval. 

The Secretary makes final determinations for SES member performance 
bonuses, with the exception of SES members in VA's Office of Inspector 
General. Recommendations from the Office of Inspector General PRB are 
sent directly to the VA Inspector General for final decision without 
review by the Veterans Affairs PRB or approval by the 
Secretary.[Footnote 12] The Secretary has sole discretion in accepting 
or rejecting the recommendations of the PRBs. According to an official 
in the Office of Human Resources and Administration, the Secretary 
modified 1 recommendation in 2006, but a prior secretary modified over 
30 in one year. 

Recommendations for bonuses for members of the Veterans Affairs, 
Veterans Health Administration, and Veterans Benefits Administration 
PRBs are made after the PRBs conclude their work.[Footnote 13] The 
highest-level executives of each board rank the members of their 
respective PRBs and make recommendations, which are submitted to the 
Secretary. The Secretary determines any bonuses for the highest-level 
executives of the boards. 

VA SES Bonuses: 

In 2006, VA's bonus pool was $3,751,630, or 9 percent of the aggregate 
basic pay of its SES members in 2005. VA awarded an average of $16,606 
in bonuses in fiscal year 2006 to 87 percent of its career SES 
members.[Footnote 14] At headquarters, approximately 82 percent of 
career SES members received bonuses and 90 percent received bonuses in 
the field. Additionally, those in headquarters were awarded an average 
of about $4,000 more in bonuses than the career SES members in field 
locations. Table 1 shows the average bonus amount, percentage receiving 
bonuses, and total rated at VA among career SES members and by 
headquarters and field locations for 2004 through 2006.[Footnote 15] 

Table 1: Average Bonus Amount, Percentage Receiving Bonuses, and Total 
Rated at VA among Career SES Members and by Headquarters and Field 
Locations, 2004-2006: 

All; 
2004: Average amount: $16,371; 
2004: Percentage receiving: 85.4; 
2004: Number rated: 240; 
2005: Average amount: $16,713; 
2005: Percentage receiving: 79.7; 
2005: Number rated: 261; 2006: Average amount: $16,606; 
2006: Percentage receiving: 87.2; 
2006: Number rated: 243. 

Headquarters; 
2004: Average amount: 19,195; 
2004: Percentage receiving: 82.1; 
2004: Number rated: 78; 
2005: Average amount: 18,629; 
2005: Percentage receiving: 80.2; 
2005: Number rated: 86; 
2006: Average amount: 19,439; 
2006: Percentage receiving: 81.9; 2006: Number rated: 83. 

Field; 
2004: Average amount: 15,089; 
2004: Percentage receiving: 87.0; 
2004: Number rated: 162; 
2005: Average amount: 15,761; 
2005: Percentage receiving: 79.4; 
2005: Number rated: 175; 
2006: Average amount: 15,268; 
2006: Percentage receiving: 90.0; 
2006: Number rated: 160. 

Source: GAO analysis of VA data. 

Note: We excluded career SES members who received Presidential Rank 
Awards from our calculations of average bonus amount, percent receiving 
bonuses and total rated because under VA's policy, those individuals 
were not considered for bonuses. 

[End of table] 

In 2005, according to OPM's Report on Senior Executive Pay for 
Performance for Fiscal Year 2005, the most recent report available, VA 
awarded higher average bonuses to its career SES than any other cabinet-
level department. OPM data show that six other cabinet-level 
departments awarded bonuses to a higher percentage of their career SES 
members.[Footnote 16] When asked about possible reasons for VA's high 
average bonus award, a VA official in the Office of Human Resources and 
Administration cited the outstanding performance of VA's three 
organizations and the amount allocated to SES member bonuses. 

OPM's and OMB's Roles in the VA Certification Process: 

Both OPM and OMB play a role in the review of agency's senior 
performance appraisal systems and have jointly developed certification 
criteria.[Footnote 17] OPM issues guidance each year to help agencies 
improve the development of their SES performance appraisal systems and 
also reviews agency certification submissions to ensure they meet 
specified criteria. To make its own determination, OMB examines 
agency's performance appraisal systems against the certification 
criteria, primarily considering measures of overall agency performance, 
such as an agency's results of a Program Assessment Rating Tool review 
or President's Management Agenda results. 

Specifically, to qualify for the use of SES pay flexibilities, OPM and 
OMB evaluate agencies' senior performance appraisal systems against 
nine certification criteria. These certification criteria are broad 
principles that position agencies to use their pay systems 
strategically to support the development of a stronger performance 
culture and the attainment of the agencies' missions, goals, and 
objectives. These are alignment, consultation, results, balance, 
assessments and guidelines, oversight, accountability, performance, and 
pay differentiation. See appendix I for a description of the 
certification criteria. There are two levels of performance appraisal 
system certification available to agencies: full and provisional. To 
receive full certification, the design of the systems must meet the 
nine certification criteria, and agencies must, in the judgment of OPM 
and with concurrence from OMB, provide documentation of prior 
performance ratings to demonstrate compliance with the criteria. Full 
certification lasts for 2 calendar years. Provisionally certified 
agencies are also granted the authority to apply higher caps on SES pay 
and total compensation just as those with fully certified systems are, 
even though agencies with provisional certification do not meet all 
nine of the certification criteria. Provisional certification lasts for 
1 calendar year. According to OPM, the regulations were designed to 
cover initial implementation of the certification process. Now that all 
agencies have been under the system, all nine criteria must be met for 
an agency to be certified, even provisionally. According to OPM, for an 
agency to receive full certification in 2007, it must show that it has 
2 years of making performance differentiation in ratings, pay, and 
award; and that the agency performance plans fully met all the criteria 
without requiring extensive revision. 

After OMB concurrence, the Director of OPM certifies the agency's 
performance appraisal system and formally notifies the agency with a 
letter specifying provisional, full certification, or no 
certification.[Footnote 18] Of the 42 performance appraisal systems 
that were certified in 2006, only the Department of Labor's system 
received full certification. According to OPM's Web site, as of June 5, 
2007, four agencies had received full certification of their senior 
performance appraisal systems--the Department of Commerce for 2007 
through 2008, the Department of Labor for 2006 through 2007, the 
Federal Communications Commission for 2007 through 2008, and the 
Federal Energy Regulatory Commission for 2007 through 2008.[Footnote 
19] 

If provisional or no certification is recommended, the letter from OPM 
provides the agency with specific areas of concern identified through 
the review process. These comments may direct an agency to focus more 
on making meaningful distinctions in performance or improving the type 
of performance measures used to evaluate SES members. For example, in 
OPM's 2007 certification guidance, the OPM Director asked agencies to 
place more emphasis on achieving measurable results, noting that many 
plans often fall short of identifying the measures used to determine 
whether results are achieved. In addition, OPM asked agencies to 
highlight in their 2007 certification requests any description or 
evidence of improvements made as a result of comments from OPM or OMB 
in response to the agency's 2006 certification submission. 

VA received provisional certification for each of the years 2004 
through 2006. In 2006, the letter from OPM to VA discussing its 
decision to grant the VA provisional certification rather than full 
certification, OPM stated that while the VA "system met certification 
criteria, clear alignment and measurable results must be evident in all 
plans across the entire agency." In addition, OPM said that it expected 
to see "well over 50 percent of an executive's performance plan focused 
on business results" and that VA "needs to ensure its 2007 executive 
performance plans weight business results appropriately." VA officials 
told us that the 2007 submission is in draft and they expect to submit 
it to OPM by the June 30, 2007, deadline. 

Our preliminary review of VA's requirements for performance plans 
contained in its 2006 submission and 2007 draft submission show that VA 
made changes to the policy requirements for its performance plans to 
reflect a greater emphasis on measurable results. Specifically, the 
elements of the job requirement in the 2007 policies provides that each 
critical element and performance element will be weighted, which was 
not previously required in 2006. These performance requirements, 
according to the policy, will be described in terms of specific 
result(s) with metrics that the SES member must accomplish for the 
agency to achieve its annual performance goals and represent at least 
60 percent of the overall weight of the performance plan. The policy 
further states that the expected results should be specific, 
measurable, and aggressive yet achievable, results-oriented, and time- 
based. 

Responding to concerns expressed by members of Congress and media 
reports about SES member bonuses, VA's Secretary recently requested 
that OPM review its performance management program for senior 
executives to ensure that its processes are consistent with governing 
statutes and OPM regulations and guidance. VA officials indicated that 
while OPM's review encompasses some of the same areas as those required 
for 2007 certification, VA requested a separate report from OPM. 

We have stated that it is important for OPM to continue to carefully 
monitor the implementation of agencies' systems and the certification 
process with the goal of helping all agencies to receive full 
certification of their system. Requiring agencies with provisional 
certification to reapply annually rather than every 2 years helps to 
ensure continued progress in fully meeting congressional intent in 
authorizing the new performance-based pay system. VA has achieved 
provisional certification of its SES performance management system for 
2004 through 2006. 

Mr. Chairman and Members of the Subcommittee, this concludes my 
prepared statement. I would be pleased to respond to any questions that 
you have. 

Contacts and Acknowledgments: 

For further information regarding this statement, please contact J. 
Christopher Mihm at (202) 512-6806 or mihmj@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this testimony. Individuals making key 
contributions to this statement included George Stalcup, Director; 
Belva Martin, Assistant Director; Carole J. Cimitile; Karin Fangman; 
Tamara F. Stenzel; and Greg Wilmoth. 

[End of section] 

Appendix I: Senior Executive Service Performance Appraisal System 
Certification Criteria: 


Summary of certification criteria for senior executive appraisal 
systems: Alignment; 
Individual performance expectations must be linked to or derived from 
the agency's mission, strategic goals, program/policy objectives, 
and/or annual performance plan. 

Summary of certification criteria for senior executive appraisal 
systems: Consultation; 
Individual performance expectations are developed with senior employee 
involvement and must be communicated at the beginning of the appraisal 
cycle. 

Summary of certification criteria for senior executive appraisal 
systems: Results; 
Individual expectations describe performance that is measurable, 
demonstrable, or observable, focusing on organizational outputs and 
outcomes, policy/program objectives, milestones, and so forth. 

Summary of certification criteria for senior executive appraisal 
systems: Balance; 
Individual performance expectations must include measures of results, 
employee and customer/stakeholder satisfaction, and competencies or 
behaviors that contribute to outstanding performance. 

Summary of certification criteria for senior executive appraisal 
systems: Assessments and guidelines; 
The agency head or a designee provides assessments of the performance 
of the agency overall, as well as each of its major program and 
functional areas, such as reports of agency's goals and other program 
performance measures and indicators, and evaluation guidelines based, 
in part, upon those assessments to senior employees, and appropriate 
senior employee rating and reviewing officials. The guidance provided 
may not take the form of quantitative limitations on the number of 
ratings at any given rating level. 

Summary of certification criteria for senior executive appraisal 
systems: Oversight; 
The agency head or designee must certify that (1) the appraisal process 
makes meaningful distinctions based on relative performance; (2) 
results take into account, as appropriate, the agency's performance; 
and (3) pay adjustments and awards recognize individual/organizational 
performance. 

Summary of certification criteria for senior executive appraisal 
systems: Accountability; 
Senior employee ratings (as well as subordinate employees' performance 
expectations and ratings for those with supervisor responsibilities) 
appropriately reflect employees' performance expectations, relevant 
program performance measures, and other relevant factors. 

Summary of certification criteria for senior executive appraisal 
systems: Performance differentiation; 
Among other provisions, the agency must provide for at least one rating 
level above Fully Successful (must include an Outstanding level of 
performance), and in the application of those ratings, make meaningful 
distinctions among executives based on their relative performance. 

Summary of certification criteria for senior executive appraisal 
systems: Pay differentiation; 
The agency should be able to demonstrate that the largest pay 
adjustments, highest pay levels (base and performance awards), or both 
are provided to its highest performers, and that, overall, the 
distribution of pay rates in the SES rate range and pay adjustments 
reflects meaningful distinctions among executives based on their 
relative performance. 

Source: GAO analysis of OPM and OMB regulations. 

[End of table] 

FOOTNOTES 

[1] For purposes of this testimony, we refer to SES performance awards 
as bonuses. Since only members of the SES with career appointments are 
eligible for bonuses, all references to bonuses apply only to SES 
members with career appointments. 

[2] VA's three primary components are the Veterans Health 
Administration, the Veterans Benefits Administration, and the National 
Cemetery Administration. 

[3] GAO, Results-Oriented Cultures: Creating a Clear Linkage between 
Individual Performance and Organizational Success, GAO-03-488 
(Washington, D.C.: Mar. 14, 2003). 

[4] GAO, Human Capital: Trends in Executive and Judicial Pay, GAO-06-
708 (Washington, D.C.: June 21, 2006). 

[5] GAO, Office of Personnel Management: Key Lessons Learned to Date 
for Strengthening Capacity to Lead and Implement Human Capital Reforms, 
GAO-07-90 (Washington, D.C.: Jan. 19, 2007). 

[6] According to VA policy, Presidential Rank Award winners are not 
eligible for VA's senior executive bonuses in the same year they 
receive the award. Agencies can nominate senior executives for these 
awards, which recognize career senior executives who have demonstrated 
exceptional performance over an extended period of time. The OPM 
Director reviews agency nominations and recommends candidates to the 
President. These awards are either 20 or 35 percent of the recipient's 
base pay. 

[7] See Section 1322 of the Chief Human Capital Officers Act of 2002, 
Title XIII of the Homeland Security Act of 2002, Pub. L. No. 107-296 
(Nov. 25, 2002) and section 1125(a)(2) of the National Defense 
Authorization Act for Fiscal Year 2004, Pub. L. No. 108-136 (Nov. 24, 
2003). 

[8] GAO, Human Capital: Aligning Senior Executives' Performance with 
Organizational Results Is an Important Step Toward Governmentwide 
Transformation, GAO-06-1125T (Washington, D.C.: Sept. 26, 2006). 

[9] 5 U.S.C. § 5384. 

[10] In 2007, senior executives at agencies with certified systems can 
receive up to $168,000 in base pay and $215,700 in total compensation, 
at agencies with noncertified systems, up to $154,600 in base pay and 
$186,600 in total compensation. 

[11] 5 U.S.C. § 4314. VA's PRB members were published in the Federal 
Register on November 2, 2006. 71 Fed. Reg. 64,609 (Nov. 2, 2006). 

[12] In accordance with section 6(d) of the Inspector General Act of 
1978, the VA Inspector General is responsible for making final bonus 
decisions for SES members within the Office of the Inspector General. 
See Pub. L. No. 95-452, codified at section 6(d) of Appendix 3 of Title 
5 of the United States Code. 

[13] The three members of the Office of Inspector General PRB are not 
eligible for bonuses from VA because they are external to VA. 

[14] According to VA policy, Presidential Rank Award winners are not 
eligible for VA's senior executive bonuses in the same year. Agencies 
can nominate senior executives for these awards, which recognize career 
senior executives who have demonstrated exceptional performance over an 
extended period of time. The OPM Director reviews agency nominations 
and recommends candidates to the President. These awards are either 20 
or 35 percent of the recipient's base pay. 

[15] For 2004 and 2005, our analysis of the average award amount and 
percentage receiving SES bonuses at VA based on data provided by VA 
differs from that reported by OPM. 

[16] In fiscal years 2004 and 2005, the Department of Defense did not 
receive certification of its SES performance appraisal system for SES 
member. 

[17] GAO-07-90. 

[18] Since congressional authorization for the new performance-based 
pay system went into effect, not all federal agencies have submitted 
their senior performance appraisal systems for review and not all 
agencies have received either full or provisional certification. 

[19] All years are calendar years.

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