bonneville power administration human capital management...

Bonneville Power Administration Human Capital Management

“Get Well” Project Plan

February 6, 2014

Bonneville Power Administration Human Capital Management “Get Well” Project Plan

TABLE OF CONTENTS

1. Purpose and Scope 4 2. Background 4 3. Summary of Input 6 4. BPA Get Well Approach 7 5. Remediation Plan Governance 8 6. Remediation Activities 10 7. Continuity of BPA Operations 16 8. Deficient HR Functional 19 9. Audit Accountability & Reporting 20 10. Timeline, Tracking & Metrics 22 11. Project Plan Implementation and Approval 23

SUMMARY OF TABLES

Number Title Page 1 Summary of Input 6 2 Day-to-Day Operations 16

SUMMARY OF FIGURES

Number Title Page 1 BPA “Get Well” Project Plan Support Structure 10 2 Case Reconstruction Process – Merit Promotion 11 3 Case Reconstruction Process – Delegated Examining 11 4 BPA Remediation Timeline 19

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Change Control Table

Version Date Changes 1.0 10/10/2013 Inserted Appendix G and HC-20 edits 1.1 10/30/2013 Text changes added during BPA site visit 1.2 11/13/2013 Multiple changes made during workgroup

review. 1.3 11/13/2013 • Added Change Control Table

• Added section breaks and missingappendix headers

• Some formatting and minor textchanges in Appendices H and I

1.4 11/14/2013 Added HC-1.5 information to section on Remediation Plan Governance

1.5 11/18/2013 Added training bullet to page 16 (Day to Day operations)

1.6 11/21/2013 Multiple minor text changes and formatting edits throughout

1.7 1/25/2014 Multiple changes at BPA’s request 1.8 1/31/2014 Multiple changes at BPA’s request

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Bonneville Power Administration Human Capital Management “Get Well” Project Plan

1. PURPOSE AND SCOPE

Following a series of reviews and audits of the Department of Energy (DOE) Bonneville Power Administration (BPA) HR program, BPA’s HR authority has been temporarily suspended. Issues identified through these audits ranged from improper execution of HR policies and procedures, to skill gaps within the BPA HR community, and resulted in erroneous personnel actions that need to be remedied.

The purpose of this document is to establish a project plan to resolve the issues identified and to ultimately rebuild the HR function at BPA. This plan will identify the steps needed to:

o Align BPA’s HR procedures with Federal laws and regulations and DOE policies bySeptember 30, 2014;

o Build the required skills of the BPA’s human capital staff;

o Demonstrate the ability of BPA’s human capital program to execute compliant humanresources (HR) activities; and

o Reinstate BPA’s HR Authority by September 30, 2014.

This plan captures the summary of input that led to identification of the issues; an approach to conducting the corrective actions; and steps that must be taken for recovery of BPA’s human capital management program. This plan identifies required resources, roles and responsibilities; a method for tracking associated actions; and an estimated timeline.

2. BACKGROUND

BPA is a DOE power marketing administration based in the Pacific Northwest. It is self-funding and covers its costs by selling its products and services. BPA markets wholesale electrical power from 31 federal hydro projects in the Columbia River Basin, a nonfederal nuclear plant and several other small nonfederal power plants. BPA also operates and maintains about three-fourths of the high-voltage transmission in its service territory.

BPA’s Federal workforce is administered under the civil service laws in Title 5 of the United States Code. Under Title 5, the U.S. Office of Personnel Management (OPM) has the ability to delegate to federal agencies most hiring and employment authorities—including the authority to hire Federal employees, process personnel actions, establish and set pay, and administer labor and employee relations activities. OPM delegated all human resources authorities for DOE to the Secretary of Energy, and the Secretary then delegated these authorities to the

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Department’s Chief Human Capital Officer (CHCO). The CHCO has further delegated these HR authorities to other organizational elements within DOE, including BPA.

In 2012, DOE’s Office of the Chief Human Capital Officer (HC) received an anonymous complaint alleging prohibited personnel practices at BPA and provided this information to the Office of the Inspector General (OIG). The OIG informed DOE that it had also received a similar complaint and subsequently requested that DOE review these matters. DOE HC conducted a review of the hiring cases identified in the complaint and communicated its findings to the OIG. Initial findings indicated BPA had not followed the personnel practice requirements of Title 5, OPM regulations, and DOE policies and procedures in exercising its delegated authority, particularly related to delegated examining hiring.

Based on these findings, DOE HC took a series of actions:

• On April 2, 2013, DOE HC required BPA to submit all cases involving delegatedexamining hiring to DOE for review and concurrence before proceeding.

• From April 22 through April 26, 2013, DOE HC participated in an OPM-led independentaudit of BPA’s hiring practices.

• On May 23, 2013, based on its preliminary findings from the April audit, OPM de-certified all BPA Federal human resources employees from conducting delegatedexamining activities.

• On May 24, 2013, DOE HC formally suspended BPA’s delegated examining hiringauthority.

• From June 17 through June 21, 2013, DOE HC conducted a routine triennial HumanCapital Management Accountability Program (HCMAP) audit of BPA’s human capitalprogram.

• On June 21, 2013, based on the preliminary findings from the HCMAP audit, DOE HCformally suspended BPA’s merit promotion hiring and classification authorities.

• On July 9, 2013, DOE HC temporarily suspended BPA’s authority to take any adversepersonnel actions against BPA employees.

• On August 14, 2013, DOE HC temporarily suspended BPA’s remaining human resourcesauthorities.

• On October 3, 2013, after conducting a special inquiry to determine the facts andcircumstances surrounding the allegations, the OIG released its report identifying anumber of recommendations.

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3. SUMMARY OF INPUT

Table 1 provides a summary of all reviews and audits of BPA’s human capital practices and programs. Each of these items has identified a range of systemic problems and has resulted in a variety of actions taken to date, as well as identification of additional corrective actions to be taken.

Table 1: Summary of Input Investigation/ Review/Audit

Completed Date Comments

DOE 2013 Human Capital Management Accountability Program Audit

August 14, 2013

The purpose of the HCMAP audit was to evaluate BPA’s HC program and ensure compliance and alignment with federal regulations and requirements and merit system principles.

The routine triennial HCMAP audit was conducted by DOE HC on-site at BPA June 17-21, 2013. Immediately following the audit, DOE HC formally suspended BPA’s merit promotion and classification authorities on June 21, 2013.

The final audit report was issued to BPA August 14, 2013. The audit cover letter formally suspended BPA’s remaining HR authorities.

The audit report summarized the results of the audit and required corrective actions. Based on the findings and required actions outlined in the report, BPA provided corrective action plan to HC on November 13, 2013.

OPM Human Capital

Assessment and Accountability

Framework (HCAAF) Audit

August 28, 2013

OPM conducted an independent HCAAF audit of BPA’s HC activities, including staffing operations, in order to assess compliance with Federal laws, regulations, rules and guidelines, as well as adherence to DOE and BPA agency guidance, local policies, and SOPs.

The audit was conducted on-site at BPA April 22-26, 2013, and continued off-site through May 30, 2013.

OPM formally de-certified all BPA Federal HC staff conducting delegated examining activities on May 23, 2013. As a result, DOE HC formally suspended BPA’s delegated examining authority on May 24, 2013.

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Investigation/ Review/Audit

Completed Date Comments

The audit report was issued to BPA August 28, 2013 and includes a summary of OPM’s findings and required actions. BPA provided response to OPM on October 25, 2013.

Office of Inspector

General (OIG) Special Inquiry

October 3, 2013

The DOE OIG received a complaint alleging prohibited personnel practices, including violations of veterans’ preference, at BPA. As a result, the OIG initiated a special inquiry to determine the facts and circumstances surrounding the allegations.

The OIG issued a Management Alert (DOE/IG-0891) on July 16, 2013 noting concerns about potential retaliation against employees who had raised concerns to the OIG. As a result, DOE HC suspended BPA’s ability to take adverse personnel actions.

The final OIG report Review of Allegations Regarding Prohibited Personnel Practices at the Bonneville Power Administration was issued October 3, 2013. The OIG report includes a number of recommended actions based on the issues identified.

4. BPA GET WELL APPROACH

The Department is committed to ensuring BPA achieves a fully compliant human resources program and regains HR authorities. In order to successfully achieve this, the issues identified through the described audits, inquiries and reviews must be addressed through a comprehensive approach. The approach will target the systemic and cultural issues at BPA that have resulted in non-compliance with Federal human capital laws and regulations. In addition, the approach will ensure BPA is positioned to meet ongoing mission requirements through day-to-day operations. The approach is segmented into four distinct components:

1. Establish a remediation plan governance structure and team2. Identify and execute remediation activities3. Transfer day-to-day oversight of BPA HR operations to DOE HC during remediation

period4. Report on progress to goals to enhance accountability of remediation activities

The following sections delve into the different components of the BPA Get Well Approach. Major project milestones are included in Appendix A.

5. REMEDIATION PLAN GOVERNANCE

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Due to the complexity and scope of the remediation effort, DOE HC has established a dedicated project team which includes support from each of the DOE Office of the Chief Human Capital Officer offices, including the Office of HC Policy, Accountability and Technology (HC-10), the Office of Learning and Workforce Development (HC-20) and the Office of Human Resource Services (HC-30). Additional support may be required and requested by the Department’s other servicing human resources offices. The following outlines the roles and responsibilities required to complete the required and recommended actions as identified from the various HR audits:

• Office of the Chief Human Capital Officer – The Department’s lead organizationresponsible for assisting BPA in regaining their Human Resource authorities.

• Project Sponsor – Oversee overall project execution; provide direction to BPA Project PlanManager.

• BPA Project Plan Manager – Overall responsibility of executing activities defined in the BPA“Get Well” plan.

• Office of HC Policy, Accountability, and Technology (HC-10)– Develops Department-levelhuman capital management policies and directives. Responsible for conducting HumanCapital Management Accountability Program (HCMAP) reviews of the Department’s humancapital programs; provides final approval of all additions to the Department’s PriorityPlacement and Priority Considerations Lists that result from reconstruction of hiring cases;and provides final approval of all policy-related directives and procedures developed forimplementation.

• Office of Learning and Workforce Development (HC-20) – Designs a strategic approach toidentify/analyze existing skill gaps and conduct training assessment, ensuring employees areprovided learning opportunities that effectively develop the necessary knowledge, skills andcompetencies essential to the performance of work in all human capital functional areas, aswell as management skills and competencies needed to successfully accomplish the missionof the Department. This will be accomplished through an integrated, strategic,competency-centric talent development.

• Office of Human Resource Services (HC-30)– HC-30 has the lead in the reconstruction ofdelegated examining and merit promotion hiring cases; regularizing erroneousappointments; training and development of BPA human capital staff; re-write anddevelopment of BPA’s human capital management SOPs; day-to-day human resourcesoperations; restructure and realignment of BPA’s human capital management workforce;responses to, and identification of corrective action plans for, the DOE HCMAP and OPMHCAAF audits; and response to, and identification of corrective action plans for, the OIGSpecial Inquiry.

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• Reconstruction Team– This team exists within the Office of the Chief Human Capital Officer,Office of Human Resource Services (HC-30), thereby establishing consistency in assignedstaff, reconstruction approach/processes/assignments, and project accountability – all ofwhich are critical to the overall success of this effort. The reconstruction team will consistof one Team Lead (GS-15) and two Senior HR Specialists (GS-14s), 2-3 BPA HR Specialists(GS-12/13,) and 5-8 contractors. Team members would be detailed to the team for a periodnot-to-exceed September 30, 2014.

• Administrative Management Staff (HC-1.5)– HC-1.5 shall provide high level administrativesupport to the Reconstruction Team and shall have lead for receiving and reviewingexternal requests for information, including Congressional requests and FOIA requests.Upon review of each item or request for information, HC-1.5 will ensure distribution to theappropriate individual within HC for response. HC-1.5 will be responsible for tracking andfollowing-up as necessary. HC-1.5 shall manage this locally by current HC-1.5 staff.

• BPA Human Resources Director (HRD) and Staff – The BPA Human Resources Director andthe members of the BPA Human Capital Management Office will report to the Department’sCHCO or designee. The staff will work closely with HC-30 on all remediation activities and,as required, travel to headquarters to receive hands-on training on thereconstruction/correction process and to gain operational exposure to a fully functionalhuman capital office. Once trained, the BPA HR Staff will provide reconstruction services forMP cases with appropriate oversight by HC-30.

• OPM Philadelphia – Responsible for reconstructing cases, identifying deficiencies, anddetailing corrective action, as outlined in the MOU between OPM and BPA. OPMPhiladelphia will provide reconstruction analyses to the Reconstruction Team forreview/approval. Approved cases will be forwarded to HC-30 for official documentation,tracking, and compliance purposes.

To achieve this massive workload, support from OCHCO offices and coordination between these offices will be required. The proposed support structure is depicted in Figure 1-1, and the responsibilities and required resources are described in more detail within each category.

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6. REMEDIATION ACTIVITIES

The following activities have been identified to remediate the required and recommended actions as identified through the various HR audits. The corrective actions are focused in the below five key areas/categories.

Reconstruct Case Files

• All of BPA’s delegated examining (DE) and merit promotion (MP) hiring cases thatoccurred between November 2010 and April 2013 are required to be reconstructed.The reconstruction effort will result in fully reconstructed files that meet DOE and OPMregulations, identify disadvantaged individuals and identify actions required toregularize erroneous appointments. Reconstruction of cases will be completed througha combination of efforts by DOE HC, BPA and OPM, as described in Resources andResponsibilities below. This workload consists of an anticipated total of approximately1,200 cases to be reconstructed and review of approximately 22,000 applicants. It isanticipated that all DE and MP cases will be reconstructed by August 31, 2014. Figure 2(below) depicts the reconstruction process for MP cases, including expectations andanticipated timeframes. The reconstruction process for DE cases is depicted in Figure 3(below).

BPA Project Sponsor

BPA Project Plan Manager

HC-10

HC-20

HC-30

HC-1.5

BPA HCM Staff

BPA HRD Reconstruction Team (HC-30)

Collaboration within HC

Figure 1: BPA “Get Well” Project Plan Support Structure

OPM Philadelphia

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Figure 2: Case Reconstruction Process – Merit Promotion

Figure 3: Case Reconstruction Process – Delegated Examining

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• Action Steps:

- Identify Reconstruction Case File Lists (MP and DEU) - Establish priority placement and priority consideration lists - Advertise Reconstruction Team Lead & Sr. HR Specialist Vacancies - Select Federal Reconstruction Team members - Identify contract staff to participate in Reconstruction Team - Review and Update priority placement and priority consideration lists - Identify individual remediation actions to regularize appointments

• Resources and Responsibilities:

o Office of Human Resource Services (HC-30) – HC-30 shall have lead for the effortsassociated with the reconstruction of the hiring cases. HC-30 will establish adedicated team focused on these efforts. The reconstruction team will requireadditional resources from what currently exists within HC-30. Specifically, thereconstruction team will consist of one Team Lead (GS-15) and two Senior HRSpecialists (GS-14s), 2-3 BPA HR Specialists (GS-12/13) and 5-8 contractors. Thisreconstruction team will be staffed by current DOE employees (via details and/ortemporary promotions) and contract staff. Detail and temporary promotionopportunities have been advertised within DOE (job announcement # DOE-HQ-HC-13-00302-MP and DOE-HQ-HC-13-00303-MP) and selections have been made. Thegoal date for establishing a complete reconstruction team is October 1, 2013.

o BPA HRD and Staff - The BPA staff associated with this effort will be detailed to HQto receive hands-on training on the reconstruction/correction process and to gainoperational exposure to a fully functional human capital office. The BPA HR Staff willprovide reconstruction services for MP cases as trained.

o OPM Philadelphia - BPA has elected to use a third party – OPM Philadelphia – toreconstruct many of the delegated examining cases. It is anticipated OPMPhiladelphia will reconstruct approximately 300 DE cases.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall haveresponsibility for final approval of priority placement and considerationdeterminations and for maintaining and updating the priority placement andconsideration lists that are generated as a result of these reconstruction efforts.

Regularize Erroneous Appointments

• Through the reconstruction of hiring actions, it is anticipated there will be erroneousappointments that need to be regularized. Regularizing appointments will bringerroneous hires into alignment with Federal laws, as well as DOE and OPM policies andguidance.

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• Action Steps:

- Review Erroneous Appointment List - Identify Case Owner to Execute Regularization Activities - Propose remediation recommendations to HC-10 (HC-30) - Case provided to HC-30 to take action necessary to regularize - Execute approved remediation activities (HC-30) - Appoint employee legally, if possible - If unable to appoint employee legally, notify HC-10


o Office of Human Resource Services (HC-30) – HC-30 shall have overall lead forensuring erroneous appointments are identified and regularized, coordinating asneeded with HC-10 for cases that require OPM review. This will be accomplished bythe Reconstruction Team.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall haveresponsibility for coordinating with OPM and approving the regularization oferroneous appointments. This work will be accomplished with local staff and willnot require additional resources.

Improve the Skills and Competencies of the BPA HR Workforce

• A predominant number of BPA’s key HR positions have been filled by individuals with noFederal HR experience, a contributing factor in BPA staff being de-certified by OPM, aswell as the suspension of BPA’s HR authorities. To reinstate DEU certifications fromOPM across the BPA HR Workforce, staff is required to receive training in the followingareas: basic staffing; conducting valid job analysis and assessment tool development;qualifications analysis; basic processing of personnel actions; initial delegated examiningtraining; and training on the use of various hiring authorities, including the manyveteran hiring authorities. Additionally, BPA staff will need to receive appropriateformal and on-the-job training to obtain the skills and demonstrate competencies in thevarying areas of HR.

• Action Steps:

- Finalize OPM Training Plan (see Appendix B) - Identify DOE HC required training - Build assessment tool to gauge BPA’s current competency levels - Define HR Training Framework for ongoing development - Develop On the Job Training Rotation Program - Conduct On the Job Training Rotations

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- Track Completion of training activities


o Office of Human Resource Services (HC-30) – HC-30 shall have lead for ensuringproper training – formal and informal – of BPA’s HCM staff. This will requirecoordination and collaboration with HC-20. This work will be accomplished withlocal staff and will not require additional resources.

o Office of Learning and Workforce Development (HC-20) - HC-20 shall lead the BPAeffort for adopting and implementing a more systematic approach to assessingcritical skills for the entire BPA HCM workforce, identifying and addressing skills gapsusing appropriate training – formal and informal. This will require coordination andcollaboration with HC-30. This work will be accomplished with local staff and willnot require additional resources.

o Office of HC Policy, Accountability and Technology (HC-10) – All training plans mustbe reviewed and approved by HC-10. This work will be accomplished with local staffand will not require additional resources.

Review and Update HR Policies and SOPs

BPA has approximately 125 “Personnel Letters” that serve as HR policy documents and instructions. Each of these will need to be reviewed, and likely re-written, to ensure compliance with applicable laws and policies. Additionally, where procedures don’t exist, they will need to be developed. All Personnel Letters and SOPs are expected to be evaluated, and when applicable, re-written, reviewed and approved by March 31, 2014.

• Action Steps:

- Revise and update standard operating procedures (SOPs) and guidance to be reflective of applicable laws, regulations, and DOE policies and instructions (BPA HCM)

- Provide revised SOPs to HC-30 for review (BPA HCM) - Provides reviewed/coordinated SOP to HC-10 for approval (HC-30) - Publish and implement revised SOPs (BPA HCM)


o Office of Human Resource Services (HC-30) – HC-30 shall have lead for reviewing andapproving the re-write and development of BPA’s human resources procedures andguidance. HC-30 shall manage this locally by current HC-30 staff with BPAemployees performing the major aspects of the work.

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o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall collaboratewith HC-30 on policy review and approval. This work will be accomplished with localstaff and will not require additional resources.

o BPA HRD and Staff – BPA HCM shall review and rewrite/develop BPA HR policyimplementation guidance and Standard Operating Procedures and shall coordinatewith HC-30 for review and approval.

Optimize the BPA HR Structure

• As a result of the findings from the various reviews and audits, it is critical to restructureand realign the BPA Human Capital Management workforce to streamline delivery andalign functions to enhance accountability.

Going forward, BPA must focus on ensuring key HCM management and staff positions,including the Human Resources Director position, are filled permanently by candidateswith appropriate Federal HR knowledge and experience. BPA must focus on developinginternal Human Resources Workforce strategies that will enhance HR competencies andfacilitate effective partnerships with line managers. This restructuring and realignmentof the BPA HCM workforce will require close coordination with DOE HQ.

It is anticipated the reorganization and realignment of BPA’s HCM workforce will becompleted by March 31, 2014.

• Action Steps:

- Assess necessary resources - Determine proper alignment of positions/functions - Propose realignment to more effectively utilize resources - Ensure all supervisory positions are filled - Realign Staff, as appropriate


o Office of Human Resource Services (HC-30) – HC-30 shall have responsibility forworking with BPA in the reorganization and realignment of their HCM workforce.HC-30 shall manage this locally by current HC-30 staff with BPA employeesperforming the major aspects of the work.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall collaboratewith HC-30 in accordance with the DOE Reorganization procedures. This work will beaccomplished with local staff and will not require additional resources.

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o BPA HRD and Staff – BPA HCM shall review current processes and organizationstructures to define to-be structure recommendations.

7. CONTINUITY OF BPA HR OPERATIONS

As a result of the varying reviews and audits, BPA’s HR authorities have been temporarily suspended until their HCM office can demonstrate the ability to be fully compliant with all applicable laws and regulations, as well as Departmental polices. As such, to ensure BPA can continue to meet mission requirements, their day-to-day human resources operations will need to be overseen by DOE HC. All of BPA’s HR activities, ranging from processing personnel actions to performance management, will need to be reviewed by DOE HC before BPA can proceed.

Table 2 provides a summary of the various categories that exist within day-to-day human resources operations. As the scope of human resources activities in large and complex, this list may not be all-inclusive, and where gaps may exist within the list, it should not be assumed BPA HCM has authority in those areas. As BPA demonstrates competencies and compliance with applicable laws, regulations and policies in each area, authority for these operations will be provisionally returned to BPA HCM.

Table 2: Day-to-Day Operations Day-to-Day Operations/Functions

Awards • QSI Processing• Cash Award (Performance)• Cash Award (Contribution, Suggestion or Invention)• Time-Off Award

Staffing • Delegated Examining• Competitive Appointments (Permanent)• Temporary/Time-Limited Appointments• Special Veterans Appointments (e.g., VRA, 30 Percent, SSP, etc.)• Merit Promotion• Reassignments & Promotions• Reinstatements, Transfers, Conversions, & Special Authorities• Provisional Appointments• Time-Limited Appointments• Emergency/Indefinite Appointments• Noncompetitive Promotions by Accretion of Duties• Excepted Service Appointments• Expert and Consultant Appointments• Excepted Service Appointments• Pathways Appointments

Compensation and Pay-Setting Authority

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• Superior Qualifications & Special Needs Pay-Setting• Promotion Pay-Setting• Within-Grade-Increases• Quality Step increases• Recruitment Incentives• Retention Incentives• Relocation Incentives• Student Loan Repayment Program• Tuition Assistance

Official Personnel Folder Administration Workforce Shaping

• VERA/VSIP Processing• Reorganizations

Benefits • Retirement calculations and advisory services• OWCP• Drug Testing• Health Unit Oversight• Fitness Unit Oversight• Library Oversight• FMLA• Leave Donor/VLTP• Reasonable Accommodations• Drug & Alcohol Program• Employee Assistance Program• Telework

Learning Development/Training • Approval of new training development• Audit for Training Requests• Leadership Programs• Mandatory Department-wide Training• Leadership Forum• Executive Coaching• IDPs• New Employee Orientation

Performance Management • Awards

Employee Relations • Arbitrations• Administrative Grievances• Case Review/Concurrence (July 2011-present)• Coordinate HQ OGC Review/Concurrence (July 2011-present)• Oversight/Review/Concurrence of all daily actions

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• Employee Relations Instruction• Coordination of employee relations cases with HQ OGC and BPA GC for individuals pending

active litigationLabor Relations

• Arbitrations• Negotiated Grievances• Oversight/Review/Concurrence of all daily actions• Establishment of labor authorities• Review of Collective Bargaining Agreements• Establishment of statutorily required Agency Head Review• Coordination of legal reviews when necessary• Collective Bargaining Grievances• Impact and Implementation Bargaining• Relocations• Reorganizations


o Office of Human Resource Services (HC-30) – HC-30 shall have responsibility for theoversight of day-to-day human resources operations at BPA. These operationsinclude the processing of personnel actions, performance management, andbenefits and work-life services. This does not include employee and labor relations.HC-30 shall manage this locally by current HC-30 staff with BPA employeesperforming the major aspects of the work. As HC-30 will have ultimate responsibilityfor reviewing and approving routine HR activities at BPA, and as a result of theDeputy Secretary’s memorandum dated October 24, 2013, the BPA HumanResources Director shall have a direct reporting relationship to HC-30.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall haveresponsibility for oversight of employee and labor relations activities at BPA. Thescope of work associated with this category includes HC review of all routineemployee relations and labor relations items due to BPA’s loss of HR authorities, allemployee and labor relations cases referred by the Office of Special Counsel (OSC),and all employee and labor cases referred by the OIG. This work shall be performedprimarily by current HC-10 staff.

o BPA HRD and Staff – BPA HRD and staff will continue to perform the major aspect ofthe day-to-day work with oversight and approval authority from HC-30 untilauthorities are returned to BPA in each work category.

8. DEFICIENT HR FUNCTIONAL AREAS

As a result of audits by OPM, HC and other entities, several deficient HR areas were identified at BPA. Areas where specific deficiencies were identified were (1) Information Systems; (2)

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Personnel Processing; (3) Retirement/Benefits; (4) Worklife Programs; (5) Staffing/Classification; (6) Employee Development/Training; (7) Performance Management; and (8) Employee and Labor Relations. The proposed timeframes for remediating deficient areas vary. As required actions are completed, the authority to independently perform certain HR functions may be provisionally re-issued to the BPA Human Resources Office. Figure 4: BPA Remediation Timeline Bonneville Power Administration (BPA) Deficient Functional Area Remediation Timeline August 2013 through September 2014

List of Activities Prog

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to

Dat

e

Aug

'13

Sep

'13

Oct

'13

Nov

'13

Dec

'13

Jan

'14

Feb

'14

Mar

'14

Apr

'14

May

'14

Jun

'14

Jul '

14

Aug

'14

Sep

'14

Deficient Areas:

1 Information

Systems 0%

2 Personnel Processing 0%

3

Retirements/Benefits 100%

4 Worklife Programs 0%

5

Staffing/Classification 0%

6 Employee

Development/Training 0%

7 Performance Management 20%

8 Employee & Labor

Relations 0%


o Office of Human Resource Services (HC-30) – HC-30 will establish specific

performance metrics and support the HC-established communication plan to address inquiries, approvals, and decisions through appropriate HC and BPA channels. This includes a Department level approval process for all HR functional areas until BPA’s HR authority is restored. Although, the timelines displays only high level activities, it further supports the need to track and monitor all ongoing activities at the lower levels to ensure all goals and objectives are accomplished within the established timeframes.

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o Office of HC Policy, Accountability and Technology (HC-10) – HC-10 shall ensurecompliance of HR actions with Departmental procedures, applicable regulations, andlaw. Assess compliance of HR actions, reauthorizing BPA to resume HR functions asnecessary requirements and milestones are met.

o BPA HRD and Staff – BPA HCM shall take necessary action to ensure the regulatoryand legal compliance of all HR actions consistent with HC-30 direction and guidance.Actions taken will facilitate BPA regaining authority to independently accomplish HRfunctions.

9. AUDIT ACCOUNTABILITY AND REPORTING

Response to DOE HCMAP Audit and Completion of Identified Corrective Actions

• BPA prepared a response to the DOE HCMAP audit report and findings within 90 days ofthe date of the report, focusing on the identified corrective actions and a plan toachieve these actions. A summary of the required and recommended actions identifiedin the audit is included in Appendix D.


o Office of Human Resource Services (HC-30) – HC-30 shall have lead responsibility forcoordinating with and reviewing BPA’s response to the DOE HCMAP audit, includingreviewing the proposed corrective actions plans. HC-30 shall manage this locally bycurrent HC-30 staff with BPA employees performing the major aspects of the work.This will require coordination and collaboration with HC-10.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 will beresponsible for the final review and acceptance of BPA’s DOE HCMAP Auditresponse. This work will be accomplished with local staff and will not requireadditional resources.

Response to OPM HCAAF Audit and Completion of Identified Corrective Actions

• BPA prepared a response to the OPM HCAAF audit report and findings within 30 days ofthe date of the report (unless an extension is granted by OPM), focusing on theidentified corrective actions and a plan to achieve these actions. A summary of therequired and recommended actions is included in Appendix E.


o Office of Human Resource Services (HC-30) – HC-30 shall have lead responsibility forcoordinating with and reviewing BPA’s response to the OPM HCAAF audit, includingreviewing the proposed corrective actions plans. HC-30 shall manage this locally by

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current HC-30 staff with BPA employees performing the major aspects of the work. This will require coordination and collaboration with HC-10.

o Office of HC Policy, Accountability and Technology (HC-10) - HC-10 shall collaboratewith HC-30 on OPM HCAAF Audit response. This work will be accomplished withlocal staff and will not require additional resources.

Response to OIG Special Inquiry and Completion of Identified Corrective Actions

• DOE, in coordination with BPA, provided responses to the OIG Special Inquiry report andfindings, focusing on the identified corrective actions and a plan to achieve theseactions. A summary of the recommended actions is included in Appendix F.


o Office of the Chief Human Capital Officer (HC-1) – HC-1 shall lead the effortsassociated with responding to the OIG Special Inquiry and the recommended actionscontained within. This will require collaboration with HC-10, HC-20, HC-30, and BPAleadership and HCM staff.

Congressional and Freedom of Information Act (FOIA) Requests for Information

• It is anticipated there will be multiple external requests for information – bothCongressional requests and FOIA requests – that will be received and forwarded to HCfor action. Each of these requests will need to be reviewed, tracked, coordinated andappropriately responded to.


o Administrative Management Staff (HC-1.5) – HC-1.5 shall have lead for receiving andreviewing external requests for information, including Congressional requests andFOIA requests. Upon review of each item or request for information, HC-1.5 willensure distribution to the appropriate individual within HC for response. HC-1.5 willbe responsible for tracking and following-up as necessary. HC-1.5 shall manage thislocally by current HC-1.5 staff.

Responses to OIG Referrals and Inquiries

• The OIG expects to receive multiple referrals, inquiries, employee complaints, etc., thatwill need to be reviewed, tracked, coordinated and appropriately responded to.


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o Administrative Management Staff (HC-1.5) – HC-1.5 shall have responsibility forreviewing items and inquiries referred to HC by the OIG. Upon review of each itemor request for information, HC-1.5 will ensure distribution to the appropriateindividual within HC for response. HC-1.5 will be responsible for tracking andfollowing-up as necessary. HC-1.5 shall manage this locally by current HC-1.5 staff.

10. Timeline, Tracking and Metrics

Refer to the BPA Project Plan Timeline and Tracking Tool for detailed timelines and tracking mechanisms related to each of the key categories described above.

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11. Project Plan Implementation and Approval

Principles of Implementation

The Office of the Chief Human Capital Officer (HC) and Bonneville Power Administration (BPA) are committed to carrying out the requirements of this plan in a transparent and collaborative manner. The following principles will guide the accomplishment of action items associated with fulfilling the requirements of this plan.

1. Open DialogueOperate with transparency and a free exchange of information to foster greaterphilosophical alignment.

2. Collaborative Decision-MakingDOE HC will work in collaboration with BPA to ensure HR services are supportive ofBPA’s mission. DOE HC has final decision authority with respect to the human resourcesfunction until such time as these authorities are re-delegated.

3. Minimize Workforce DisruptionWork to minimize impact to employees as a result of implementing the “get well” planobjectives. DOE HC and BPA agree that the fundamental principle when regularizingpositions will be to consider and/or place disadvantaged veteran candidates.

4. Fiduciary ResponsibilitiesWork collaboratively to accomplish actions necessary to implement the “get well plan”in as efficient and cost-effective manner as possible.

5. Internal Controls and GovernanceAssure appropriate internal controls and governance processes and procedures areadopted and followed.

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