Federal agencies must use appropriate authorities and follow proper  procedures in converting political appointees to career positions. OPM Approved 78 of 99 Political to Career Conversion Requests Agencies Intended to Complete from January 1, 2010, through March 17, 2016

As shown in figure 2 below, OPM reviewed 99 agency requests to convert  individuals from political to career positions. The agencies proposed to  complete these conversions during the period of our review. OPM denied  21 and approved 78 of the 99 political conversion requests. Of the 78  approved conversion requests, agencies followed through and converted  69 political appointees to career positions. During the period, agencies also completed 7 conversions without  obtaining OPM approval. OPM conducted post- appointment reviews for 4 of these 7 conversions, denying all 4. For each  of the 4 denied cases, agencies undertook various remedies, such as  readvertising positions, in response to OPM’s concerns. OPM did not complete a review for the 3 other conversions because the  appointees were no longer in the career positions to which they were  converted. While Agencies Appeared to Have Acted Appropriately, OPM Case Files Lacked Supporting Documents for Most Approved Conversion Requests

For the 78 OPM-approved agency requests, agencies appeared to have  used appropriate authorities and followed proper procedures in converting  political appointees to career positions. As part of this effort, OPM’s  Agency Records Office is drafting a records schedule for maintaining  political conversion files, which OPM expects to be completed by the end  of calendar year 2017. Additionally, OPM’s procedures do not require its staff to verify they have  reviewed documentation required by OPM checklists. We were, however, able to support OPM’s decisions with  additional documentation obtained directly from involved agencies. Additionally, to provide  greater assurance that its staff reviewed all documentation required by  OPM checklists to support a conversion request, OPM can incorporate a  process requiring its staff to verify they have reviewed such  documentation before recommending approval or denial of agencies’  conversion requests. Recommendations for Executive Action

We are making the following two recommendations to OPM:  The Associate Director of Merit System Accountability and Compliance  should ensure that OPM’s finalized records schedule on retaining  conversion case files specifically lists all documentation that must be  saved in its case files. Specifically, for each of the 78 cases, our review of OPM’s case  files and additional documentation from individual agencies supported  OPM’s conclusion that each of these conversions appeared to be free of  political influence. GAO staff who made key contributions to this report  are listed in appendix V.

Appendix I: Political Conversions Reviewed and Completed from January 1, 2010, through March 17, 2016

	Number of conversion requests reviewed by OPM 1

Appendix II: Objectives, Scope, and Methodology

The objectives of this engagement were to provide information on  conversions of political appointees to career positions, and examine the  implementation and effectiveness of the Office of Personnel  Management’s (OPM) 2010 policy for reviewing these conversions. Specifically, this report examines (1) conversion requests submitted by  agencies and reviewed by OPM, (2) whether agencies used appropriate  authorities and proper procedures in conversions approved by OPM, (3)  conversion requests denied by OPM and referred to the Office of Special  Counsel (OSC), and (4) the extent to which OPM has complied with  governmentwide reporting requirements stipulated by the Edward “Ted”  Kaufman and Michael Leavitt Presidential Transitions Improvements Act  of 2015 (Transitions Act).
Why GAO Did This Study

Federal agencies must use appropriate authorities and follow proper procedures in converting political appointees to career positions, including obtaining prior approval from OPM.
GAO was asked to provide information on political conversions and examine the implementation and effectiveness of OPM's policy for reviewing them. GAO, as part of its review, examined (1) conversion requests submitted by agencies and reviewed by OPM, (2) whether agencies used appropriate authorities and proper procedures in conversions approved by OPM, and (3) conversion requests denied by OPM and referred to OSC.
GAO obtained and corroborated OPM data on the number of political conversions OPM reviewed and agencies intended to complete from January 1, 2010, through March 17, 2016. GAO also assessed OPM's reviews of all approved political conversion requests during the same period.

What GAO Found

The Office of Personnel Management (OPM) approved 78 of 99 requests to convert political appointees to career positions agencies proposed to complete from January 1, 2010, through March 17, 2016. OPM denied 21 requests for varying reasons, such as bypassing qualified veterans, and referred 9 denied cases to the Office of Special Counsel (OSC). Of the 78 approved requests, agencies followed through and converted 69 political appointees to career positions. During the period, agencies completed 7 conversions without obtaining OPM approval; OPM completed post-appointment reviews for 4 of these 7 conversions, denying all 4. For each of the 4 denied cases, the agencies undertook various remedies, such as readvertising positions, in response to OPM's concerns. OPM did not complete a review for the 3 other conversions because the appointees were no longer in the career positions to which they were converted.
Agencies appeared to have used appropriate authorities and followed proper procedures for each of the 78 OPM approved requests. GAO's review of OPM's case files and additional documentation from agencies supported OPM's conclusion that each of these conversions appeared to be free of political influence and complied with merit system principles. However, for 55 of the 78 requests, OPM's case files did not provide enough information for GAO to initially support OPM's approvals of the requests. GAO could only decide after obtaining and reviewing supporting documentation directly from involved agencies.
OPM's procedures for reviewing political conversion requests do not specify which agency documents it should save into case files. Further, OPM's procedures do not require its staff to verify they have reviewed agency documentation required by OPM checklists. OPM officials told GAO that it is drafting a records schedule to be completed by the end of calendar year 2017 for maintaining political conversion files. Without this schedule, OPM risks not maintaining complete documentation to justify conversion request decisions.

What GAO Recommends

GAO recommends that OPM (1) ensure its finalized records schedule lists all documentation that must be saved in OPM's case files, and (2) establish a policy requiring its staff to verify they reviewed all documentation required by OPM checklists before recommending approval or denial of a conversion request. OPM partially concurred with both recommendations, but believes it has a process to thoroughly review conversion requests. GAO continues to believe the recommendations are valid, as discussed in the report.