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CFPB Report: 2015-MO-C-013 August 26, 2015

The CFPB Can Further Enhance Internal Controls for Certain Hiring Processes

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Appendix A: Scope and Methodology

To accomplish our objectives, we gained an understanding of the CFPB's employee recruitment and selection processes by interviewing staff in the OHC. We reviewed the CFPB's recruitment and selection policies and procedures, including the CFPB Human Capital Strategic Plan FY2013–FY2015, the OHC's SOP for recruitment, the incentive policy, the Career Ladder Promotions Checklist, and the Standard Operating Procedure Initiative. In addition, we reviewed applicable laws and regulations and relevant guidance, including GAO's Standards for Internal Control in the Federal Government, OPM's End-to-End Hiring Initiative, and the Presidential Memorandum.

To assess the efficiency, effectiveness, and compliance of the CFPB's employee recruitment and selection processes against the applicable criteria, we performed the following: 

  • We reviewed previous independent performance audits of the CFPB's operations and budget that contained recommendations regarding talent management and recruitment.
  • We assessed the CFPB's efforts to measure the timeliness of its hiring process, from initiation of the hiring request through the hired candidate's first day of employment, to test process efficiency.
  • We tested compliance by reviewing vacancy announcement case files, including position descriptions; job analysis forms; specialized experience statements; and evaluation support, such as assessment questions and crediting plans. However, we did not evaluate applicants' qualifications or competencies against the position requirements.

In addition, to assess the extent to which the OHC has processes to identify control deficiencies within recruitment and selection activities, we evaluated the OHC's implementation of certain monitoring activities through December 2014. To test control activities, we also judgmentally selected a sample of vacancy announcements, recruitment incentives, and noncompetitive promotions and reassignments, factoring in the variables outlined below. We compiled the population of vacancy announcements for July 1, 2012, through February 28, 2013, from information provided by the CFPB. We selected our samples to include

  • each type of recruitment and selection activity shown in table A-1
  • vacancies for both executive and nonexecutive positions
  • recruitment or selection activity within each of the CFPB's six divisions
  • vacancy announcements that were posted for each month of our sample review period

Because we used a judgmental sampling method, the results of our testing are not representative of the entire population. We used certain laws and regulations, the CFPB's policies and procedures related to employee recruitment and selection, and other relevant guidance as criteria for our detailed testing.

Table A-1: CFPB Employee Recruitment and Selection Activities, Population and Sample Size, July 1, 2012, Through February 28, 2013 
Activity Population
(number of activities identified)
(number of activities reviewed)
Competitive service vacancy announcement 130 7
Excepted service vacancy announcement 250 13a
Recruitment incentive 25b 5
Noncompetitive promotion 108 4
Noncompetitive reassignment 150 6
Total 663 35

Source: The OIG compiled the population for July 1, 2012, through February 28, 2013, based on information provided by the CFPB. Competitive service and excepted service information was recorded in BFS ARC's Classification and Recruitment Reporting System, and recruitment and relocation incentives and noncompetitive promotions and reassignments were recorded in the National Finance Center Reporting System. The National Finance Center is an OPM-certified shared service provider of human resources and payroll services within the U.S. Department of Agriculture.

a. Eight of these 13 vacancy announcements were advertised as excepted service waiver authority positions under the Dodd-Frank Act (12 U.S.C. § 5493).  Return to table

b. During the period of our review, the CFPB issued 25 recruitment incentives totaling $112,000; the median incentive was $2,000.  Return to table

We did not review the CFPB's workforce planning, compensation and benefits (with the exception of recruitment incentives), onboarding processes, or diversity and inclusion programs.22

We conducted our evaluation fieldwork from March 2013 through December 2014. We conducted this evaluation in accordance with the Quality Standards for Inspection and Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.

  • 22. We did not review relocation incentives because, according to an OHC official, the CFPB did not offer relocation incentives during our period of review. We confirmed that no relocation incentives were issued by examining a report of all recruitment and relocation incentives issued by the CFPB during our review period.  Return to text