Farm Credit Administration

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Farm Credit AdministrationOffice of Inspector GeneralAudit ReportFarm Credit Administration’sEmployee Separation ProcessA-20-01February 9, 2021

February 9, 2021The Honorable Glen R. Smith, Board ChairmanThe Honorable Jeffery S. Hall, Board MemberFarm Credit Administration1501 Farm Credit DriveMcLean, Virginia 22102-5090Dear Chairman Smith and Board Member Hall:The Office of Inspector General (OIG) completed an audit on the Farm Credit Administration’s(FCA or Agency) employee separation process. The objective of this audit was to determinewhether FCA has an efficient and effective process for separating employees. In order to addressthe objective, we analyzed the efficiency and effectiveness of the separation processes currentlyin place, such as the notification and checkout processes, and also reviewed the number, type,and other details of separating employees, to understand the impact of such data on the Agency.Our audit found that the Agency had made enhancements to the separation process, includingestablishing policies and procedures and improving the checkout record form. There were alsomore employees completing the exit survey questionnaire than in previous years. However, weidentified certain areas that will improve the overall effectiveness and efficiency of the separatingprocess, including: improvements to the Personnel Action Report process, clarifications on the exitsurvey and interview process, and a more consistent application of the checkout documentationand retention of checkout records requirements.We made six recommendations in our audit. Management agreed with the first recommendation.Although management only partially agreed with recommendations 2, 3, 4, 5, and 6, the actionscompleted or planned address the weaknesses found in our report and the correspondingrecommendations. Due to the corrective actions implemented over the course of our audit, weconsider recommendations 1, 2, 3, and 5 closed.We appreciate the courtesies and professionalism extended by FCA to our staff during the audit,especially given the COVID-19 pandemic. If you have any questions about this audit, we would bepleased to meet with you at your convenience.Respectfully,Sonya K. CerneAssistant Inspector General for Audits, Inspections, and Evaluations1501 Farm Credit Drive, McLean, VA al

EXECUTIVE SUMMARYFarm Credit Administration’s Employee SeparationProcessReport No. A-20-01ObjectiveThe objective of this audit was to determine whetherthe Farm Credit Administration (FCA or Agency) hasan efficient and effective process for separatingemployees.RecommendationsBased on our review, we made six recommendationsto improve the separation and data collectionprocess:1.The Office of Inspector General recommendsthe Office of Agency Services update Policiesand Procedures Manual 834 to reflect thePersonnel Action Report process, updateresponsibilities and references, and documentthe exit interview process.2.The Office of Inspector General recommendsthe Office of Agency Services update the Officeof Agency Services Directive 007 to reflectcurrent processes in the separation process.3.The Office of Inspector General recommendsthe Office of Agency Services implementadditional controls over the Personnel ActionReport entries and the employee checkoutforms. This may include annual reviews,inclusion in the internal control review cycle,supervisory review, or other controls deemednecessary by the Office of Agency Services.4.The Office of Inspector General recommendsthe Office of Agency Services determinerecords retention practices for informationkept on exiting personnel including, but notlimited to, checkout forms, exit surveys, andinterview documentation, and update recordretention policies and procedures as needed.5.The Office of Inspector General recommendsthe Office of Agency Services evaluate the exitsurvey and interview process to assess theefficacy of the questions and the feedback.6.The Office of Inspector General recommendsthe Office of Agency Services implement a planon how the Agency will use the exit survey andinterview data to include analyzing andcomparing trends in employee separations andreporting or briefing the information to keyAgency officials at a designated interval.February 9, 2021FCA is an independent federal agency responsible for regulating,examining, and supervising the Farm Credit System (System) andthe Federal Agricultural Mortgage Corporation (Farmer Mac).The Agency’s mission is to ensure that System institutions andFarmer Mac are safe, sound, and dependable sources of creditand related services for all creditworthy and eligible persons inagriculture and rural America. The most important part toachieving the mission is the FCA employees. Hiring andmaintaining a workforce is imperative to fulfilling the mission.FCA generally has about 312 employees. Each year, the Agencyloses employees to separations for a variety of reasons such asretirements, transfers, and resignations. During this audit, wefound the Agency had established policies and procedures forthe separation process. The Agency also made improvements tothe checkout record form and more people were completing theexit survey questionnaire than in previous years. The Agency alsoestablished access controls for the exit questionnaire data andperformed an analysis in 2019 using exit survey data.While the Agency has made certain enhancements, there areopportunities to improve the overall effectiveness and efficiencyof the separating process. We identified improvements that needto be made to the Personnel Action Report process. We alsofound clarification is needed on the exit survey and interviewprocess and that there is an inconsistent approach to properlyseparating employees. Therefore, we made six recommendationsto improve documentation, enhance controls, and clearlydocument the Agency’s use of the exit survey and interview data.Strengthening the process can reduce the amount of errorsrelating to the out-processing of employees. Enhancing the datacollection and analysis efforts can allow the Agency tounderstand potential strengths and weaknesses of the workenvironment.

TABLE OF CONTENTSAcronyms . 1Background . 1Prior Reviews . 2Audit Results . 3Employee Separation Process . 3FCA Employee Data. 5PAR Data . 6Exit Surveys and Interviews . 12Checkout Records . 17Contributing Factors. 18Conclusion . 19Recommendations 1-6 . 19Management Comments . 22Objective, Scope, and Methodology . 24Appendix A: Exit Survey Questions . 26Appendix B: One-on-One Interview Questions . 39

ACRONYMSAgency or FCAFarm Credit AdministrationFarmer MacFederal Agricultural Mortgage CorporationFYFiscal YearHRHuman ResourcesMCPManagement Control PlanOASOffice of Agency ServicesOCFOOffice of the Chief Financial OfficerOEOffice of ExaminationOGCOffice of General CounselOITOffice of Information TechnologyOIGOffice of Inspector GeneralPARPersonnel Action ReportPPMPolicies and Procedures ManualSystemFarm Credit SystemBACKGROUNDThe Farm Credit Administration (FCA or Agency) is an independent federal agency responsible forregulating, examining, and supervising the Farm Credit System (System) and the FederalAgricultural Mortgage Corporation (Farmer Mac). The Agency’s mission is to ensure that Systeminstitutions and Farmer Mac are safe, sound, and dependable sources of credit and related servicesfor all creditworthy and eligible persons in agriculture and rural America.The most important part to achieving the mission is the FCA employees, and hiring andmaintaining a workforce is imperative to fulfilling the mission. FCA generally has about 312employees. Each year, the Agency loses employees for a variety of reasons such as retirements,transfers, and resignations. In its Strategic Plan for 2018-2023, the Agency states that humancapital challenges, including the need to recruit and retain a diverse, talented workforce, willcontinue. The Strategic Plan also states that FCA may lose many seasoned, knowledgeableemployees because of retirements and attrition over the planning horizon.1

The Office of Agency Services (OAS) manages and delivers human capital and administrativeservices for FCA through three teams: Human Resources (HR) Division, Operations Division, andLearning and Organizational Change Team. Services provided by OAS include staffing andplacement services for the Agency. For employee separations, OAS also completes personnelactions and enters information into the Personnel Action Report (PAR) to initiate the overallseparation process. OAS also provides information to employees when leaving the Agency andmaintains most separation documentation.FCA documents the process for separating employees in three primary documents: Policies and Procedures Manual (PPM) 834, Exit Procedures, March 7, 2003. PPM 834outlines responsibilities for supervisors, employees, and OAS 1 during the employeeseparation process. OAS Directive 007, Separating Employees Clearance Process, April 21, 2009. The directiveoutlines internal responsibilities within OAS for the checkout process. FCA Form 302, Employee Checkout Form, December 2019. The form outlines the checkoutprocess and instructs employees, and others with a checkout role within the Agency, onproper steps to take relating to Agency separations.Prior ReviewsIn February 2016, the Office of Inspector General (OIG) completed a related audit, Human CapitalPlanning at the Farm Credit Administration. The objectives of this audit were to assess theadequacy of the Agency’s human capital planning and the effectiveness of its implementation.The audit focused on three areas of human capital planning: key person dependencies andsuccession planning, employee hiring and separation, and workplace diversity and inclusion.Our report made the 11 recommendations listed below that the Agency agreed to, implemented,and closed by September 2016.1. Formalize the human capital planning process.2. Track data on succession planning efforts. Document the strategies to mitigate the risks.Monitor and follow-up to capture and utilize results.3. Assess organizational leadership and development programs and modify to promote,enhance, and improve initiatives within the Agency.4. Coordinate and revise the network distribution list for FCA job announcements.5. Increase coordination between the Office of Management Services and the Office of EqualEmployment Opportunity and Inclusion on special emphasis programs and outreach.PPM 834 references the Office of Management Services, which existed prior to the Office Agency Servicesand housed HR functions. In 2016, the Office of Management Services was reorganized into the Office ofAgency Services and Office of the Chief Financial Officer.12

6. Implement a plan to improve the exit interview process and disperse exit interview data togather consistent, useful information for comparison and trends.7. Consider a veterans’ representative for Agency veteran efforts.8. Provide training to all personnel involved in the recruiting and hiring process on potentialbiases and barriers to employment.9. Conduct an assessment of FCA hiring practices to identify potential barriers and areas ofimprovement.10. Establish a policy that includes the plan for requesting and analyzing applicant flow datafor FCA job announcements.11. Conduct a survey, or use other information-gathering tools, to gather additional targetedinformation on workplace diversity and inclusion.The OIG also identified human capital in the 2020 OIG Management Challenges Report as achallenge area. The OIG report noted that a significant management challenge for FCA ismaintaining a safe, well-trained, sustainable workforce while facing challenges in retirementeligibilities, succession planning and training, and diversity. The report also stated that theAgency’s success depends greatly on its ability to recruit, retain, and develop a capable workforce.AUDIT RESULTSThe objective of this audit was to determine whether FCA has an efficient and effective processfor separating employees. In order to address the objective, we analyzed the efficiency andeffectiveness of the separation processes currently in place, such as the notification and checkoutprocesses, and also reviewed the number, type, and other details on separating employees, tounderstand the impact of such data on the Agency. Overall, we found there are opportunities toimprove the efficiency and effectiveness of the process.The Agency established policies and procedures for the separation process. The Agency also madeimprovements to the checkout record form and more people were completing the exit surveyquestionnaire than in previous years. The Agency also established access controls for the exitquestionnaire data and performed an analysis in 2019 using exit survey data. While the Agencyhas made certain enhancements, there are certain steps that need to be addressed to improvethe overall effectiveness and efficiency of the separating process. We identified improvementsthat need to be made to the PAR process. We also found that clarification is needed on the exitsurvey and interview process and that the checkout documentation and retention of checkoutrecords requirements were inconsistently applied.Employee Separation ProcessThere are a variety of reasons an employee would leave the Agency. Employees may have reachedthe end of their career and elect to retire, or others may leave for a different job opportunity.When an employee elects to separate, the Agency initiates a separation action. The Agency’s3

separation actions are coded using Office of Personnel Management guidelines. The following arethe types of separations found during our review of Agency personnel actions:Death-an employeepasses away while inFederal serviceTermination ofAppointment-theemployee is leaving theAgency after a temporaryappointment or during aprobationary periodResignation-a separationinitiated by the employeewho is leaving FederalserviceRetirement-an employeeis retiring from FederalserviceTerminationAppointment In-anemployee is leaving foranother Federal agencyRemoval-a separationinitiated by the Agency,the Office of PersonnelManagement, or theMerit Systems ProtectionBoard under certainprovisions.When an employee plans to separate, OAS is notified by the employee’s office within the Agency.The office provides written notice stating an employee is leaving or provides a Standard Form-52,which is a request for personnel action, to HR. HR then completes the required documentation, ifnot provided by the office, and assesses the effective date when the employee will be leaving theAgency. An HR Specialist then enters the information into the PAR listing. 2The PAR documents certain personnel actions such as hiring, resignations, promotions,separations, and reassignments. The Agency began using an electronic version of the PAR in July2016. The information is housed internally and those with access can see all PAR actions. The PARcontains effective dates of the action, names of the employees, organizational data, titles, andother important information. Offices involved in the checkout process, such as the Office ofInformation Technology (OIT) and the ethics staff in the Office of General Counsel (OGC), use theinformation in the PAR to initiate their own actions, including interviews and account terminations.The Agency requires separating employees to complete a Form 302 as a record of the checkoutprocess. The form states that employees are responsible for obtaining the clearances in the formbefore their final day in the office. Employees in the field offices or on permanent flexiplace collectrequired signatures by circulating the checkout form via email to the appropriate offices. The formThe PAR listing is not the official separation documentation. The PAR is an internal listing specific to FCAthat provides notification of separation actions to those persons or offices in the Agency with a need toknow. The official documentation of separating employees is completed by OAS with the National FinanceCenter, which is a service provider for the Agency for finance and human resource management services.24

provides instructions for employees and supervisors and includes numerous signoffs for variousoffices, including OAS, OIT, OGC, and the Office of the Chief Financial Officer (OCFO). Theemployee signs and certifies the following on the form:“I certify I have removed all FCA owned software, documents and data from mypersonal devices (personal computer, phone, USB drive, etc.), and that I havesubmitted my completed checkout form and government ID badge to theappropriate Field Office Administrative Assistant (field offices) or the HumanResources Office (McLean).”Once the form is complete, HR personnel, or another authorized official, provides a final signatureon the form. The Payroll Officer in HR collects the form and files the hard copy in a storage cabinet.For those received electronically, the forms are printed and placed in the cabinet.During the checkout process, employees are also given two separate opportunities to providefeedback on their employment at FCA. The first is a voluntary exit survey. When an employee isleaving the Agency, an exit survey link is issued to employees with other separation information.The survey contains 25 questions and, if the employee elects to participate, the survey responsesare placed in an internal site. The site contains survey responses from March 2014 to present.Employees may also request a one-on-one interview with HR personnel to discuss theirexperiences. 3 In a compilation sent to the OIG, the document showed 14 questions were asked toemployees that requested the interview. These interviews are not entered into a system and aremaintained in hard copy form.FCA Employee DataIn order to put employee separations into perspective, it is important to understand the over

the checkout record form and more people were completing the exit survey questionnaire than in previous years. The Agency also established access controls for the exit questionnaire data and . reporting or briefing the information to key Agency officials at a designated interval.

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