OPM shouldn't delegate screening

The Office of Personnel Management recently issued proposed rules that would delegate to agencies the responsibility of determining whether individuals are suitable for federal employment (Federal Register, Jan. 28, 1999, Vol. 64, No. 18, Pages 4,336 to 4,342). Such determinations are intended to weed out individuals who lack the necessary integrity to represent the government.

Currently, OPM performs these evaluations itself by appraising an individual's character and past actions. The agency then makes a determination based on such variables as age, health, knowledge and ability for the employment sought.

When the new regulations become final after a 60-day comment period, agencies will take over this responsibility. According to OPM, some agencies will need additional staffing to train employees to conduct suitability determinations. Consequently, several agencies—perhaps not too eager to carry out this new responsibility—have stated that they would like to contract out their new suitability adjudication responsibility.

In response to agency concerns about the staffing impact of this delegation, OPM has said "the staffing implications for agencies will be negligible," although it acknowledged that additional training may be needed. That is ridiculous. Suitability determinations are important, and fully trained personnel should perform them. I'll bet OPM in the past has asked for a ton of staff to perform this function. I'll also wager that OPM's next budget submission will not reflect this reduction in workload.

OPM does offer some guidelines to make certain that agencies carry out their new mission in a proper fashion. According to OPM, agencies should ensure fairness by ascertaining that the records they use when making decisions are as accurate and complete as possible. Agencies also should observe "all applicable administrative procedural requirements provided by law, the regulations and OPM," the guidance said.Isn't that a big help? If you were the head of your agency's personnel function, would you be comforted by these instructions?

The new regulations require that agency heads categorize every competitive job within their agencies at a high-, moderate- or low-risk level in terms of the position's potential for adversely impacting the efficiency and integrity of the government. OPM said it will provide an example of a risk designation system for agency use.

Jobs at the high- or moderate-risk levels are normally designated as "public trust" positions. Such positions generally involve the following functions: policy-making, major program responsibility, public safety and health, law enforcement duties or fiduciary responsibilities. Public trust positions also may involve access to or control of sensitive but unclassified information or financial records, where there is a significant risk for causing damage or realizing personal gain.

Individual agencies will take on the responsibility of conducting background investigations for all applicants for public trust positions—which casts even more doubt on OPM's assertion that this change will not create a need for additional resources within agencies.

OPM identified some characteristics of an employee who should not occupy a position of public trust. Agencies are instructed not to hire anyone who drinks, is a criminal, makes false statements, is on drugs, beats his wife or dog, or advocates the overthrow of the government.

Thank you, OPM! All an agency has to do is ask job applicants to complete a form that asks whether they do any of those nasty things. Taxpayers can then rest easy knowing that only individuals of the highest integrity will henceforth be offered employment by the federal government.

This change may make it easier for job applicants to qualify for agency positions, but it seems a potentially problematic decision. Standards for federal positions should be uniformly adjudicated. It should not be possible for someone who wants to be a government engineer to be able to qualify with one agency but not with another.

It's fine for OPM officials to delegate more authority to agencies to give them more latitude to administer their own programs. But job certification is a central agency function that should be retained by OPM.

--Bureaucratus is a retired federal employee who contributes regularly to Federal Computer Week.


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