September 30, 2014
Attracting, engaging, and deploying a workforce is a key outcome within the CFPB's strategic goal to advance the agency's performance by maximizing its resource productivity and enhancing its impact. In 2012, the Office of Human Capital issued its Human Capital Strategic Plan FY2013-FY2015, which aligns with the CFPB's goals and outcomes. This plan includes the goal of attracting, engaging, and deploying a workforce to meet dynamic challenges and to provide effective oversight of the consumer financial marketplace. The CFPB faces challenges in meeting this goal due to competition for highly qualified staff with the unique skill sets needed to fulfill its mission. Further, as the agency seeks to build and sustain a high-performing workforce, it will need to strengthen workforce planning, establish appropriate training and development programs, implement an effective performance management system, and put in place a comprehensive diversity and inclusion program. In addition, the Office of Human Capital will need to continue to focus on developing an effective overall human capital infrastructure, a critical step to ensuring alignment with the CFPB's outcomes and its goals of recruiting and retaining a diverse workforce.
A key first step in ensuring that the CFPB has a workforce that can effectively carry out its mission is identifying the critical technical, managerial, and leadership skills through workforce planning. In its 2003 report Human Capital: Key Principles for Effective Strategic Workforce Planning, the U.S. Government Accountability Office (GAO) highlights successful principles for workforce planning that include determining the critical skills and competencies needed to achieve an agency's mission, along with strategies to address skill and competency gaps. The CFPB has established a workforce planning process, but the CFPB has acknowledged the need to broaden its workforce planning to include identifying mission-critical occupations and related competency models, emerging needs, and potential skills gaps. In determining the appropriate strategy to narrow any skill gaps, the CFPB will need to consider the means to obtain the right sets of skills, including the proportion of contracted versus federal employees, and permanent versus term employees.
As a new agency, the CFPB had to quickly build its workforce while simultaneously identifying and recruiting the best-qualified people to meet immediate and long-term staffing needs. Managing a current workforce of more than 1,300 employees requires appropriate management and leadership skills. In its most recent human capital annual report to Congress, the CFPB reported skill development initiatives for managers and supervisors; however, the agency needs to further cultivate management and leadership competencies and develop a long-term approach to workforce planning.
In the CFPB's Human Capital Strategic Plan FY2013-FY2015, workforce planning is a component of the first human capital strategy. The plan outlines several initiatives related to workforce planning, including continually assessing workforce planning needs. The CFPB reports on its workforce planning efforts in its annual reports to Congress. In the December 2013 report, the CFPB states that its workforce planning process aligns with the annual budget process and identifies workforce requirements proactively. The CFPB has identified four categories of mission-critical occupations and has begun revising its competency model framework. The CFPB plans to use the competency models for career development and training, as well as for clarifying career paths across job families. Additionally, the agency has conducted a structured organizational design analysis of each division.
The CFPB has identified as one of its key human capital strategies recruiting and retaining a highly skilled, diverse staff through effective workforce planning and talent acquisition methods, as well as through diversity and inclusion programs. The agency has acknowledged that supervising consumer compliance at financial institutions and nondepository entities can be highly complex and specialized, and that without appropriately skilled staff, it will be challenged in meeting its statutory requirements and accomplishing its mission. Our work on the CFPB's supervision program shows the challenges that the CFPB faces in meeting its need for unique skill sets and establishing appropriate staff training and development programs. We found that as of June 2013, 55 percent of the examination staff members were below the minimum grade level for commissioning, indicating that most staff members had not completed the series of supervisory training courses and proficiency examinations required to become a commissioned examiner. While the CFPB works to roll out a finalized commissioning program by the end of 2014, it is commissioning examiners through an interim program.
An additional challenge to retaining a qualified and diverse workforce relates to the CFPB's performance management system. In a March 2003 report, GAO reported that a performance management system can benefit the day-to-day management of an organization, thereby helping it achieve results. The report also notes the need for such a system to have safeguards to ensure the transparency or fairness of evaluations of an employee's performance. In early 2014, the CFPB acknowledged that disparities were identified in employee performance evaluations based on race, age, office location, and length of employment. As a result, the performance management system that was implemented in fiscal year 2013 is being replaced.
Further, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requires federal financial agencies, including the CFPB, to develop standards for equal employment opportunity and the racial, ethnic, and gender diversity of the agency's workforce, and to report annually on the recruitment and retention of minorities and women and on other diversity practices. In March 2014, the CFPB reported in its Office of Minority and Women Inclusion annual report that agency officials acknowledged the need to continue strengthening the agency's efforts to hire a diverse workforce. In addition, the CFPB acknowledges that in the aggregate, the agency is diverse; however, its workforce could better reflect the nation's multicultural composition. Retention of a diverse workforce is also a challenge, and the CFPB plans to assist managers and leaders in developing diversity and inclusion strategies to strengthen employee retention efforts. As the CFPB continues to create a high-performing workforce, such challenges should continue to be an area of focus.
The CFPB noted in its most recent human capital annual report to Congress that it continues to develop its human capital practices, including several ongoing initiatives related to workforce planning, recruitment, and retention. Initiatives include the implementation of a new process for position management and position approval to ensure a consistent approach to recruitment. Additionally, as reported in its human capital annual report to Congress, the CFPB has partnered with diversity and professional groups as part of its recruitment efforts. The CFPB's No Fear Act Annual Report FY 2013 states that the agency continues to build its equal employment opportunity program and has identified goals for the next two years to establish and administer plans to ensure that the CFPB has a demographically diverse workforce. In response to developments in early 2014, the CFPB conducted its own internal analysis of the performance management system results for 2013. Based on the findings of this analysis, the CFPB is collaborating with the collective bargaining unit that was established in May 2013 to develop a new performance management system and is taking additional steps to promote fairness and inclusion in the workplace.
As the CFPB continues to evolve, the agency is further developing its human capital infrastructure. As part of this effort, the CFPB has been establishing human capital policies and working on allocating and prioritizing its resources. The CFPB acknowledges that employees were hired at a rapid pace over the past three years to meet statutory requirements under the Dodd-Frank Act. This rapid growth, coupled with a workforce that is geographically dispersed, enhances the importance of having the appropriate policies and procedures in place and engaging all staff members in a consistent manner. The dispersed nature of the CFPB's workforce calls for a targeted communication strategy to reach staff members who are working remotely. Other components of the agency's human capital infrastructure, such as career maps and additional managerial development programs, will take time to implement.
Additional areas for improvement include streamlining the application process and continuing to develop targeted outreach programs and communications to champion the benefits of careers at the CFPB. As noted previously, the need to recruit and retain a diverse workforce is critical, and improving the CFPB's compensation and benefits policies and practices will contribute to achieving that goal. In addition, establishing a new performance management system that is fair and contributes to developing its workforce will be a challenge for the CFPB and will likely require improvements in components of its human capital infrastructure. Underlying many of these outstanding challenges is the need for the CFPB to implement a comprehensive human resources information system strategy.
As stated earlier, the CFPB identified several ongoing initiatives in its most recent human capital annual report to Congress that will aid in developing its human capital infrastructure. The CFPB has developed many policies and procedures, implemented a new position management process, and created a workforce planning handbook for leadership and hiring managers. For employee development, an individual development planning process has been instituted, and the CFPB has core competency courses and new learning projects underway to enhance technical expertise for all employees. In addition, CFPB employees are provided many workplace flexibilities in an effort to promote employee engagement and productivity. The CFPB is also collaborating with the collective bargaining unit on many aspects of its human capital infrastructure, including compensation, benefits, and a new performance management system.
