Background Victims of sexual assault may receive a sexual assault forensic examination by a medical provider who may or may not be a trained sexual assault forensic examiner. Medical providers assess victims’ clinical conditions; provide appropriate treatment and medical referrals; and, given consent by the victim, collect forensic evidence through a sexual assault forensic examination that may follow steps and use supplies from a sexual assault evidence collection kit. Under its protocol for sexual assault forensic examinations, the Department of Justice (DOJ) recommends that medical providers collect a range of physical evidence. In addition, sexual assault forensic exams typically include documenting biological and physical findings such as cuts or bruises and a victim’s medical forensic history, such as the time and nature of the assault. Once the exam is complete, medical providers preserve the collected evidence, which may include packaging, labeling, and sealing evidence collection kits and storing kits in a secure location. Medical providers typically perform such exams only for acute cases of sexual assault, such as in cases where the assault occurred within the previous 72 to 96 hours, when the physical and biological evidence on a person’s body or clothes is considered most viable. DOJ, IAFN, and the American College of Emergency Physicians (ACEP) recommend that sexual assault forensic exams be performed by specially trained medical providers—known as sexual assault forensic examiners (examiners). These examiners include physicians, physician assistants, nurse practitioners, and other registered nurses who have been specially educated and have completed clinical requirements to perform sexual assault forensic exams. Sexual assault nurse examiners (SANE) —a particular type of sexual assault forensic examiner—are registered nurses, including nurse midwives and other advanced practice nurses, who have received specialized education and have fulfilled clinical requirements to perform sexual assault forensic exams. Examiner programs have been created in hospital or non-hospital settings whereby specially trained examiners are available to provide first-response care and exams to sexual assault victims. DOJ, IAFN, and some states have issued guidelines pertaining to the minimum level of training examiners should receive in order to properly collect and preserve evidence, identify victims’ medical and emotional health care needs, and provide counseling and referrals for victims. These guidelines include recommendations of objectives and topics that training programs should cover. DOJ administers several grant programs that aim to, among other things, improve response to and recovery from four broad categories of victimization—domestic violence, sexual assault, dating violence, and stalking. In our March 2016 report we describe three key grant programs administered by DOJ’s Office on Violence Against Women that could be used by grant recipients—including states or other eligible entities—to fund or train sexual assault forensic examiners. Nationwide Data on the Availability of Sexual Assault Forensic Examiners Are Limited; Officials in Selected States Reported a Need for Additional Examiners In our March 2016 report examining the availability of sexual assault forensic examiners, we found that only limited nationwide data exist on the availability of sexual assault forensic examiners—that is, both the number of practicing examiners and health care facilities that have examiner programs. While IAFN reported that, as of September 2015, there were 1,182 nurses with an active IAFN SANE certification in the United States, such data do not represent all practicing examiners nationwide. For example, the data do not account for examiners who completed training through an IAFN or a state training program but never became certified or were certified through another entity, such as a state board of nursing. IAFN also collects data on examiner programs nationwide—that is, data on hospitals, clinics, and other sites where examiners practice. Such data provide an indication of the availability of examiners, but the data are also limited. While 703 examiner programs nationwide voluntarily reported to IAFN’s examiner program database, as of September 2015, IAFN officials noted that the database is often not up to date; and some health care settings where sexual assault forensic exams are conducted, such as child advocacy centers, are not represented. In addition, data collected on staffing characteristics of examiner programs are often unavailable in the IAFN examiner program database. For example, only about one-third of the examiner programs reported on the number of examiners practicing in their program, and about one-third reported on whether examiners were available on-site versus on-call. In three of the six selected states we reviewed in our March 2016 report, grant administrators or officials from sexual assault coalitions were able to provide estimates of the number of practicing examiners, and, in all six states, they were able to provide information on the estimated number of examiner program locations in their state. Of states that reported, the number of practicing examiners and examiner programs varied by state. (See table 1.) However, such data may also present an incomplete picture of the availability of examiners. For example, only one of the six selected states has a system in place to formally track the number and location of examiners. Instead, officials generally reported on the estimated number of examiners or examiner locations that were part of a statewide examiner program or were identified through an ad hoc data collection effort. Although data are limited, grant administrators and sexual assault coalition officials in all six selected states nevertheless told us that the number of examiners available does not meet the need for exams within their states. For example, coalition officials in Wisconsin told us that nearly half of all counties in the state do not have any examiner programs available, and coalition officials in Nebraska told us that most counties in the state do not have examiner programs available. In addition, in four of the six selected states—Colorado, Florida, Nebraska, and Wisconsin— state grant administrators and coalition officials told us that few or some health care facilities in their state have examiners available. As a consequence, officials said victims may need to travel long distances to be examined by a trained examiner or be examined by a medical professional without specialized training. While in the other two selected states—Massachusetts and Oregon—state grant administrators and coalition officials stated that some or most facilities have examiners available, they noted that there is still a need for additional capacity to reduce the burden on those examiners who are available, or to make examiners available in a number of areas where examiners are currently unavailable. In health care facilities where examiners are available, they are typically available through hospitals on an on-call basis, according to literature we reviewed as well as all grant administrators and coalition officials we interviewed for our report. In addition, among facilities that have examiners available, the number of examiners available varies and may not provide enough capacity for facilities to offer examiner coverage 24 hours, 7 days a week, according to state grant administrators and coalition officials we interviewed. Nebraska coalition officials, for example, told us that while one hospital in Omaha has a team of 26 examiners available, other facilities in the state may have as few as three examiners available. Further, officials from Florida and Colorado told us that there are few facilities in their states able to offer full coverage with examiners available 24 hours, 7 days a week. Selected States Faced Challenges Training Examiners, Maintaining Stakeholder Support, and Retaining Examiners In our March 2016 report, we found that maintaining a supply of trained examiners that meets communities’ needs for exams is challenging for multiple reasons, and that state officials have employed a variety of strategies to address these challenges, as described below. Limited availability of training. Officials in five of the six selected states told us that the limited availability of classroom, clinical, or continuing education training is a barrier to maintaining a supply of trained examiners. Regarding classroom training, some officials told us that training may only be offered once per year in their states. Additionally, officials from both Florida and IAFN told us that there is a need for qualified instructors to run training sessions. Experts and officials from Colorado, Nebraska, and Oregon also told us that medical professionals in rural areas may have difficulty completing the clinical training necessary to become an examiner. Obtaining clinical experience, such as performing exams under the supervision of a trained examiner, is a particular challenge in rural areas where hospitals may treat only a few sexual assault cases per year. One official in Nebraska told us that trained examiners in rural areas might not feel competent to perform exams due to the low number of cases they treat. A lack of continuing education opportunities may also pose a challenge for examiners in maintaining the skills necessary to perform exams. For example, the National Sexual Violence Resource Center (NSVRC) reported that— based on common challenges identified through a survey of, and group discussions among, examiner program coordinators—maintaining competency may be difficult for nurses in rural areas due to a low volume of patients presenting in need of exams and limited access to ongoing and advanced training. Officials told us they have been able to increase the availability of examiner training through alternative training methods such as web- based training courses and simulated clinical training. For example, officials in Colorado told us their state’s web-based examiner training program has made training less expensive and has increased examiner recruitment. Officials in Wisconsin told us they developed a clinical training lab that allows examiners to gain hands-on experience by performing elements of exams on experienced teaching assistants hired for the purpose of training new examiners. Further, in 2014, a DOJ- funded evaluation of examiner training programs found that a web-based training course may help increase the availability of trained examiners; the study also found that implementing web-based training had benefits such as decreasing the costs associated with attending in-person training, expanding training opportunities to remote areas, and allowing examiners to be trained by national experts. Lack of technical assistance and other supportive resources. Officials in four of the six selected states told us that the limited availability of technical assistance and other supportive resources for examiners poses a challenge to maintaining a supply of trained examiners. For example, officials in Florida, Nebraska, Oregon, and Wisconsin explained that, in general, there is a lack of mentorship opportunities and leadership within the examiner community. Officials also noted that the sustainability of examiner programs may be threatened by a lack of internal capacity, such as not having a full-time, paid examiner program coordinator available. Further, in its survey of and group discussions with examiner program coordinators, NSVRC found that examiners and examiner programs needed technical assistance and support in the following areas: aspects of performing exams, training, leadership development and policy issues, and examiner program sustainability. Officials we spoke to told us about strategies that can be used to increase support for examiners and examiner programs, such as offering web- based technical assistance. For example, officials in Massachusetts told us that, through their National Sexual Assault TeleNursing Center, trained SANEs provide remote clinical guidance to two hospitals in the state that do not have trained examiners available. In addition, officials from Colorado told us an examiner program coordinator in an urban hospital in the state provides volunteer on-call technical assistance and clinical guidance to examiners in rural parts of the state, where those resources are not otherwise available. Further, one study we reviewed found several states were engaged in promising practices to increase support for examiners, such as implementing state-wide mentorship programs, developing regional examiner list-serves and online discussion boards, creating formal leadership positions within the examiner community, and requiring examiner program evaluations. Weak stakeholder support for examiners. Officials in five of the six selected states told us that limited stakeholder support for examiners and examiner programs, such as from hospitals and law enforcement, is a challenge to maintaining a supply of trained examiners. Some officials told us that hospitals may be reluctant to support examiners and examiner programs due to a low number of sexual assault cases treated each year. One official told us that hospitals may be reluctant to send nurses to examiner training, as it takes away from their regular shift availability. Additionally, some hospitals do not pay examiners to be on call. Officials in three states told us that hospitals typically either do not pay examiners to be on call or pay on-call examiners significantly less than other on-call medical professionals. Apart from hospital support, officials in Colorado and Oregon explained there is a need for more multidisciplinary support for examiners, such as increased law enforcement, prosecutor, and first-responder understanding of examiners’ role. The literature we reviewed also shows that ambiguity around the role of the examiner in responding to sexual assault may be a source of conflict between examiners and other professionals. For example, examiners were found to have experienced instances where victim advocates or law enforcement questioned examiners’ medical decisions, speed of evidence collection, or asked examiners to comment on the credibility of a victim’s case. One nationally representative survey of examiner programs found that examiner program coordinators felt ongoing education of community stakeholders on sexual assault and examiner programs was needed due to the high turnover in staff at relevant community institutions and agencies, such as law enforcement officers, victim advocates, and prosecutors. Through our interviews with officials, we learned of strategies selected states have used to increase or mitigate limited stakeholder support for examiners and examiner programs. For example, officials in Colorado, Florida, Nebraska, Oregon, and Wisconsin told us that sexual assault response teams have been developed in their states to help community stakeholders to understand examiners’ role and better coordinate to meet the medical and legal needs of sexual assault victims. Low examiner retention rates. Officials in four of the six selected states told us that low examiner retention rates can be an impediment to maintaining a supply of trained examiners. In addition to the challenges of limited training opportunities, technical assistance and other supportive resources, and stakeholder support for examiners, the physically and emotionally demanding nature of examiner work contributes to low examiner retention rates. Further, studies have indicated that dissatisfaction with compensation, long work hours, and lack of support, among other things, may contribute to examiner burnout. Examiners typically work on call in addition to their full time jobs as, for example, emergency department nurses. Officials in Florida told us that examiners may be on call for 6-hour, 12-hour, or even 24-hour shifts. Further, one survey of examiner programs in Maryland found that examiners were required to be on call for an average of 159 hours per month. Wisconsin officials estimated that, although 540 SANEs were trained over a 2-year period, only 42 (less than 8 percent) were still practicing in the state at the end of those 2 years. Chairman Harper, Ranking Member DeGette, and Members of the Subcommittee, this concludes my prepared statement. I would be pleased to respond to any questions that you may have at this time. GAO Contact and Staff Acknowledgments For further information about this statement, please contact A. Nicole Clowers at (202) 512-7114 or clowersa@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this testimony. In addition to the contact named above, key contributors to this statement were Kristi Peterson (Assistant Director), Patricia Roy, Katherine Mack, Laurie Pachter, and Emily Wilson. This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.


Background We and others have identified challenges specific to VA’s management and oversight. These challenges have affected VA’s ability to accomplish its mission economically, efficiently, and effectively. For example, in April 2019, we summarized priority open recommendations from our previous reports to address these VA challenges. These recommendations cover areas affected by shortcomings in human capital management, such as veterans’ access to timely health care and reform of the appeals process for disability benefits. VA agreed or partially agreed with 28 of our 30 priority recommendations and is taking steps to implement them. We have also previously reported on human capital challenges across VA. For example, we reported in March 2017 that VA determined VBA staff resources have not sufficiently kept pace with increased pending appeals, and additional staff were needed to improve timeliness and reduce its appeals inventory. We found that VA’s written workforce plans—which cover recruiting, hiring, and training—were not consistent with sound workforce planning practices. We recommended that VBA ensure the development of a timely, detailed workforce plan for recruiting, hiring, and training new hires. As of October 2018, VA had taken steps to address this recommendation, but still needed to address risk mitigation strategies for ensuring it has appropriate capacity to manage appeals workloads and improve timeliness of appeals decisions. In addition, VA officials told us in August 2017 that VA had taken actions to hire more staff to update regulations on disability eligibility criteria. However, as of September 2018, the agency was still working to hire these staff. Furthermore, we reported in August 2018 that VHA’s Sterile Processing Services experienced workforce challenges such as lengthy hiring time frames and limited pay and professional growth potential. Officials told us that these challenges resulted in difficulty maintaining sufficient staffing. These challenges pose a potential risk to VA medical centers’ ability to ensure access to sterilized medical equipment. We recommended that VHA examine the services’ workforce needs and take actions based on the assessment. As of July 2019, this recommendation remained open. In 2018, VA’s Office of Inspector General identified leadership and workforce investment as a major management challenge. The Inspector General noted that the root cause for many of the issues it identified at VA was poor and unstable leadership and staffing shortages. Also, a 2015 Independent Assessment found that VHA’s leadership pipeline was not robust enough to meet its current and future needs. The report also concluded that VHA could not identify potential leaders and prepare them to assume their future roles. It stated that inadequate succession planning and unfocused leadership development efforts contributed to these problems. Finally, the report found that VHA may have difficulties meeting projected demand for services if it does not increase its total number of clinical employees, such as physicians, and their productivity. Effective succession planning can help agencies ensure they have a pipeline of talent to meet current and future mission requirements, according to OPM and our past work. Succession planning is a proactive and systematic process where organizations identify the positions they consider to be too critical to be left vacant or filled by any but the best qualified persons, according to OPM guidance. Organizations then develop a plan to fill those positions with qualified and capable employees. The guidance also states that organizations should take a planned, deliberate, and holistic approach to selecting, developing, and engaging their workforce. In our prior work, we noted that effective succession planning is more than filling existing vacancies with people with the same occupational skills and competencies. Rather, succession planning focuses on current and future needs, and develops pools of high-potential staff to meet the organization’s mission over the long term. VA, VHA, and VBA Need to Fully Incorporate Key Succession Planning Leading Practices Our assessment found that VA’s succession planning efforts partially met one leading practice and did not meet four. VHA met two and partially met three leading practices. VBA partially met three and did not meet two leading practices (see table 1). VA Does Not Have an Up- to-Date Department-wide Succession Plan VA lacks a current, department-wide succession plan. It also has not met four of the key leading practices for succession planning, but has partially met one practice. VA Directive 5002 requires that VA use the administrations’ plans to develop a workforce and succession plan annually. However, VA has not produced a leadership-approved, department-wide succession plan since 2009. VA officials said the 2009 plan does not reflect their current succession planning efforts. Obtain active support and participation from leadership: Not met. According to VA officials, VA has tried to update its 2009 succession plan; however, leadership has not approved a revised plan because of leadership turnover. VA has developed a draft workforce plan, but as of July 2019, VA leadership had not approved the draft plan. Active leadership support for succession planning could help VA strengthen its current and future capacity to serve veterans. Develop succession plans aligned with strategic goals: Not met. VA officials did not provide evidence that VA’s succession planning process was aligned with strategic goals. OPM strategic human capital management regulations require an agency’s human capital policies and programs to align with its missions, goals, and strategic objectives. Developing an up-to-date succession plan aligned with the department’s strategic goals would help VA to establish a strategic process for meeting its current and future workforce needs. Analyze current and future workforce gaps: Not met. VA officials told us that they have conducted some analyses of workforce data for mission-critical occupations, but they did not provide evidence that VA analyzes or projects workforce gaps for leadership positions or for each mission-critical occupation. For example, in accordance with the VA MISSION Act of 2018 (MISSION Act), VA reported on the steps it is taking to achieve full staffing capacity. The report included data on VA’s onboard employees, turnover rates, and growth rates for the department’s total workforce, and growth and turnover rates for clinical positions and a limited number of other positions. VA also forecasted its overall hiring requirements for the current and upcoming fiscal year based on the budget and average turnover. However, the report, which VA produces to meet the specific requirements of the MISSION Act, does not include an analysis of workforce gaps for leadership positions or for specific mission-critical occupations. OPM’s strategic human capital management regulations require agency human capital policies and programs be based on comprehensive workforce planning and analysis, and use comprehensive data analytic methods and gap closure strategies to monitor and address skill gaps within mission-critical occupations. Further analyzing workforce gaps could help VA identify current and emerging workforce challenges and inform succession planning strategies. Identify strategies for closing workforce gaps: Partially met. VA has identified some strategies for addressing workforce gaps, though not within a succession planning process. VA’s Corporate Senior Executive Management Office (CSEMO) is responsible for managing the Senior Executive Service (SES) across the department and its administrations. CSEMO coordinates the hiring, placement, training, and development of VA’s SES employees. VA also has an SES Candidate Development Program, which identifies and develops talent to fill key SES positions. Further, in its MISSION Act report, VA identifies several strategies to achieve full staffing capacity. For example, the report discusses efforts to recruit and retain clinical staff through the VHA Education Debt Reduction Program and the VA Health Professional Scholarship Program. The report also discusses the Hire Right Hire Fast model initiated in 2017 that aims to fill open positions and reduce the time to hire for the medical support assistance occupation. VA officials have not provided evidence that they developed strategies for addressing future workforce gaps as part of the agency’s succession planning process. VA’s strategies are focused on closing current vacancies and achieving full staffing capacity. However, our prior work has found that leading organizations do more than just focus on replacing individuals; rather, they engage in broad, integrated succession planning and management efforts to strengthen both current and future organizational capacity. Additionally, OPM’s strategic human capital management regulations require agencies to plan for and manage current and future workforce needs, and to make progress towards closing any knowledge, skill, and competency gaps. Furthermore, because VA has not conducted a full analysis of its future workforce gaps, VA cannot identify strategies for closing those gaps. Monitor, evaluate, and update succession plans and strategies: Not met. VA provided limited evidence that it monitors and evaluates workforce planning strategies. For example, VHA and VBA produce action trackers to monitor the progress of some human capital initiatives at the administration level. However, because VA officials did not provide a current succession plan with strategies for closing workforce gaps, VA’s limited monitoring and evaluation efforts are not clearly linked to a succession planning process. Monitoring and evaluating the outcomes of strategies, policies, programs, and activities is one of the key systems established in OPM’s strategic human capital management regulations, and requires agencies to identify, implement, and monitor process improvements. Monitoring and evaluating activities as part of its succession planning process could help VA ensure that it is implementing effective strategies. Furthermore, regularly updating its succession plans would help VA identify and address current and emerging workforce gaps. VHA’s Succession Plan Is Consistent with Some Leading Practices but VHA Performs Limited Monitoring and Evaluation of Its Plans VHA developed a succession plan in 2016, and its efforts have met two of the five succession planning leading practices for both leadership and mission-critical occupations. However, leadership has not ensured that VHA has complete workforce data. In addition, VHA’s monitoring and evaluation of its succession plans is limited. Obtain active support and participation from leadership: Partially met. VHA leadership has dedicated resources to succession planning. For example, VHA leadership dedicated staff and financial resources to develop a succession plan for VHA in 2016. VHA leadership also established the Healthcare Leadership Talent Institute (HLTI) in 2015 to strategically manage and develop VHA’s leadership talent. In addition, the former Undersecretary for Health approved the 2016 plan and encouraged staff to use the plan to develop talented staff, improve workplace culture and employee engagement, and address workforce challenges to improve the veteran experience. However, VHA leadership has not ensured that VHA’s plan incorporates leading practices and departmental requirements for succession planning, primarily related to analyzing workforce gaps and monitoring and evaluating its plan. VHA officials also told us that VHA does not provide leadership succession planning guidance to Veterans Integrated Service Networks (VISN) or medical centers because VHA has started to centralize leadership succession planning at the national level. Additional support and involvement from top leadership, such as providing additional oversight and guidance, could help to ensure VHA is meeting department-level succession planning requirements, and ensure that succession planning efforts achieve workforce goals. Develop succession plans aligned with strategic goals: Met. VHA has developed a succession plan and strategies that align with the administration’s and department’s strategic goals. The 2016 succession plan discusses VHA’s strategic direction—which includes strategic goals, major initiatives, and legislation that affect VHA’s workforce—and succession planning priorities. For example, the plan describes VHA’s strategies to adapt to a changing veteran population and to ensure it can provide sufficient, patient-driven primary and mental health care to meet the needs of veterans. Analyze current and future workforce gaps: Partially met. VHA’s 2016 succession plan analyzes current and projected workforce trends for both leadership and mission-critical occupations. For example, the plan presents the total number of executive leadership positions and the number of vacancies in those positions. In addition, the plan includes analyses of recent historical and projected workforce trends for mission- critical occupations, including prior and anticipated onboard, retirement, quit, and total loss rates. VHA collects workforce data from facilities annually and displays these data on its internal website, which is accessible to VHA staff who make human capital and workforce planning decisions. Although VHA tracks workforce data, our prior work has identified weaknesses with these data. For example, in October 2017, we found that VHA was unable to accurately count the total number of physicians in VA medical centers. Medical centers annually report data through a workforce planning tool; however, this tool does not include information on contract physicians, fee-basis physicians, and physician trainees. All of these arrangements help medical centers meet their demand for physicians, which have regularly been identified as one of VHA’s top shortage occupations. We recommended VHA develop and implement a process to accurately count all physicians providing care at each medical center. VA disagreed with this recommendation and, as of March 2019, had not implemented this recommendation. Improving the completeness and accuracy of its data would help VHA better address workforce gaps. Identify strategies for closing workforce gaps: Met. VHA’s 2016 plan identified strategies for closing workforce gaps. For leadership positions, HLTI offers training programs focused on developing future healthcare leaders. In addition to managing development programs, HLTI has implemented several initiatives to address specific gaps in leadership positions and build a succession pipeline of talent. For example, HLTI facilitates an annual talent review process by identifying and developing clinical and administrative leaders at medical centers who are interested in moving up into medical center director positions, the highest position in a VA medical center. VHA has also identified strategies to close gaps for its mission-critical occupations. For example, VHA requires facilities to develop action plans as part of the annual workforce planning cycle to reduce the risk of having critical staffing shortages. For instance, one VA medical center identified increasing human resources training and awareness of recruitment, retention, and relocation funding as an action to address shortages in dentist positions—the clinical occupation with the most severe shortage of candidates at that medical center. In addition, VHA established an initiative for hiring mental health providers, which involved hosting a virtual career event, partnering with professional organizations, and implementing other marketing and recruitment strategies. Monitor, evaluate, and update succession plans and strategies: Partially met. VHA has taken some steps to monitor, evaluate, and update its succession planning. VHA updates its succession plan approximately every 4 years and issues limited updates to the plan annually. VHA’s Office of Workforce Management and Consulting tracks workforce data nationally and provides data and risk scores by occupation to VISNs and medical centers so they can monitor workforce trends. VHA also uses these data to assess to what extent facilities’ efforts are achieving workforce goals. For leadership positions, VHA officials told us that HLTI evaluates its leadership development programs and that these evaluations are used to modify the programs to better meet VHA’s succession needs. However, VHA’s 2016 plan only included limited evaluations of previously identified strategies because VHA has not established a process for evaluating its succession planning efforts. While VHA tracks facility-level metrics for various occupations, VHA’s plan did not discuss specific methods for monitoring and evaluating its succession planning strategies. For example, VHA tracks the vacancy rates for medical center director positions; however, VHA has not identified a process to monitor and evaluate the effectiveness of the talent review process it has implemented for identifying and developing medical center director candidates. The plan also mentioned that subject matter experts within VHA suggested expanding monitoring efforts of certain recruitment and retention programs. As noted above, agencies are required to identify, implement, and monitor process improvements under the evaluation system established in OPM’s strategic human capital management regulations. Additional monitoring and evaluation of VHA’s succession plans and strategies could help VHA to assess the effectiveness of its strategies, and to identify and address emerging workforce challenges. VBA Analyzes Some Gaps in Its Mission-Critical Workforce, but Has Not Developed a Succession Plan for Leadership Positions VBA has partially met three key leading practices for succession planning and has not met two practices. Its strategic workforce plan, which VBA officials said is their primary succession planning document, only incorporates some key leading practices for mission-critical occupations. The plan does not address succession planning for leadership positions. Obtain active support and participation from leadership: Partially met. VBA’s leadership has taken some steps to promote succession planning, but has not fully incorporated departmental requirements or key leading practices. VBA officials told us that VBA’s leadership prioritizes filling vacancies for mission-critical occupations. For example, human capital staff brief VBA leadership monthly on vacancies and hiring initiatives. However, our prior work has found that leading organizations do more than simply backfill specific positions; rather, they engage in broad, integrated succession planning and management efforts to strengthen both current and future organizational capacity. As noted above, OPM’s strategic human capital management regulations require agencies to plan for and manage current and future workforce needs. In addition, VBA officials told us that VBA’s leadership reviewed and approved its strategic workforce plan. However, unlike VHA’s plan, VBA’s plan does not indicate that it was reviewed and approved by leadership. VBA leadership also has not ensured that VBA’s plan incorporates departmental requirements or key leading practices. Some of the missing leading practices discussed below—such as aligning plans with strategic goals, identifying strategies to close workforce gaps, and monitoring and evaluating those strategies—are also required by VA’s succession planning directive. VBA leadership also has not ensured that VBA is performing succession planning for leadership positions, which is required by VA’s succession planning directive and recommended by leading practices. In addition, strategic human capital management regulations require agencies to ensure leadership continuity by, in part, implementing and evaluating succession plans for leadership positions. According to VBA officials, VBA’s strategic workforce plan does not include succession planning for leadership positions because VBA plans Senior Executive Service (SES) development in coordination with the Corporate Senior Executive Management Office (CSEMO). While CSEMO manages SES development, VBA officials told us that VBA provides input to CSEMO on VBA’s SES needs. VBA officials did not provide evidence that they are identifying current and future leadership needs. Furthermore, VBA’s leadership also includes General Schedule (GS)-13 to GS-15 managers, who are below the SES level. Planning for those managers would not involve coordination with CSEMO. Therefore, incorporating leadership succession planning into its existing workforce planning processes could help VBA strategically identify and better meet current and future leadership needs. Develop succession plans aligned with strategic goals: Not met. Officials stated that VBA’s strategic workforce plan is the primary document that would discuss succession planning, but this document does not discuss strategic goals and how VBA’s plans align with those goals. As noted earlier, OPM strategic human capital management regulations require agency policies and programs to align with the agency’s mission, goals, and strategic objectives. Aligning plans with strategic goals could help VBA better achieve current and future mission requirements. For example, VBA does not clearly describe how succession plans and strategies for its veterans claims examining occupations—a mission-critical occupation series—will address VBA’s goal to provide veterans benefits and services in a timely manner. It can also help VBA officials create a clear and convincing case for agency leaders to dedicate resources―both budget and personnel―to succession planning. Analyze current and future workforce gaps: Partially met. VBA’s strategic workforce plan includes some analysis of current and future workforce gaps for mission-critical occupations, but not for leadership positions. For example, according to the plan, VBA has increased the number of employees in its veterans claims examining occupations. VBA also anticipates that it will need additional claims processors to meet future demand. However, the plan does not contain similar information for leadership positions, either at the SES level or at lower levels. As noted above, agency human capital policies and programs are to be based on comprehensive workforce planning and analysis. Analyzing workforce gaps in leadership could help VBA better understand its current and future workforce requirements to meet its evolving mission requirements. Identify strategies for closing workforce gaps: Partially met. VBA’s strategic workforce plan does not identify strategies or actions to close anticipated workforce gaps. VBA’s plan states that a forthcoming action plan will develop specific goals and corresponding targets, but VBA officials told us they are still developing this plan. As noted earlier, agencies are required to plan for and manage current and future workforce needs, and make progress towards closing knowledge, skill, and competency gaps. However, VBA does have training and development programs designed to ensure a pool of capable employees is available to take over leadership positions. For example, the Assistant Director Development Program helps prepare GS-14 and GS-15 employees for leadership positions within VBA. Nonetheless, identifying a coordinated set of strategies in its plan for filling leadership positions and closing mission-critical workforce gaps could help VBA address challenges in these areas. Monitor, evaluate, and update succession plans and strategies: Not met. VBA updates its strategic workforce plan every 4 years and issues limited updates to the plan annually. However, VBA’s plan does not provide any information on monitoring or evaluating strategies to close workforce gaps for mission-critical occupations or leadership positions. It also does not include updates to actions or strategies based on past performance. Monitoring and evaluating the outcomes of strategies, policies, programs, and activities is one of the key systems established in OPM’s strategic human capital management regulations, and requires agencies to identify, implement, and monitor process improvements. VA’s Succession Planning Directive Has Not Been Updated Since 2003 and May Not Reflect All Relevant Legal Requirements VA has not updated its succession planning directive since 2003 and VA officials told us that the directive does not incorporate legal requirements put in place since then. VA’s succession planning directive establishes the requirements and assigns the roles and responsibilities for succession planning across the department. VA’s directive identifies succession planning as an ongoing activity intended to best meet the needs of the department over time. According to VA officials, VA has attempted to update the directive twice since 2003, but has not completed the update due to leadership turnover. In addition, officials stated that they had to delay updating the directive to revise it to incorporate new regulatory and legislative changes that occurred during those past efforts to update the directive. A key update to legal requirements since 2003 is OPM’s strategic human capital regulations. These regulations establish the framework agencies are to use to plan, implement, evaluate, and improve human capital policies and programs. OPM originally issued the regulations in 2008 and then revised them in December 2016. In addition, the VA Choice and Quality Employment Act of 2017 requires VA, among other things, to establish a single database that lists each vacant position in VA that the Secretary determines is critical to the mission of VA, difficult to fill, or both. Updating the directive could help to ensure it reflects legal requirements put in place since 2003, such as OPM’s strategic human capital regulations. Updating the directive is also consistent with GAO’s Standards for Internal Control in the Federal Government, which requires management to identify and respond to significant changes, such as new laws and regulations. In addition, we found that VA, VHA, and VBA do not follow all of the requirements outlined in the directive. For example, the directive assigns responsibility to VA, VHA, and VBA for monitoring and evaluating their succession planning strategies, which is consistent with leading practices. However, as stated above, we found that VA, VHA, and VBA do not conduct sufficient monitoring and evaluation. Updating the directive could help VA clarify and recommunicate succession planning roles and responsibilities across the department and its administrations. Conclusions We and others have previously identified leadership turnover and mission-critical vacancies that have affected VA’s ability to provide services to veterans. Addressing these challenges will require a planned and holistic approach to succession planning that focuses on current and future mission requirements over the long term rather than on filling existing vacancies with people with the same occupational skills and competencies. VA, VHA, and VBA have taken important steps to develop a pipeline of talent to fill leadership positions and mission-critical occupations. For example, each has developed training and development programs for aspiring leaders. However, VA lacks a current department-wide succession plan for leadership positions and mission-critical occupations, as required by its own directive. Establishing a department-wide succession plan and improving existing workforce plans would help VA identify and develop pools of high-potential staff to meet VA’s mission over the long term. Meanwhile, VHA and VBA could each take additional steps to fully incorporate key leading practices into their succession planning. Addressing VA’s challenges will require active leadership support and clear departmental guidance outlining VA’s and its administrations’ responsibilities for succession planning. However, VA has not updated its succession planning directive since 2003 due to leadership turnover, among other factors. Updating the directive could help ensure VA and its administrations are complying with relevant legal requirements—including OPM’s strategic human capital management regulations—and ensure they understand their roles and responsibilities for succession planning. Recommendations for Executive Action We are making a total of four recommendations, including two to VA, one to VHA, and one to VBA: The Secretary of Veterans Affairs should develop a department-wide succession plan for leadership and mission-critical occupations that incorporates key leading practices for succession planning. (Recommendation 1) The Under Secretary for Health should incorporate key leading practices into VHA’s succession planning processes, including monitoring and evaluating VHA’s succession planning. (Recommendation 2) The Under Secretary for Benefits should develop a succession planning process for all leadership positions and incorporate key leading practices into VBA’s succession planning for leadership positions and mission- critical occupations. These practices include aligning the plans with strategic goals, identifying strategies to close workforce gaps, and monitoring and evaluating VBA’s succession planning. (Recommendation 3) The Secretary of Veterans Affairs should update VA’s 2003 directive on workforce and succession planning to incorporate relevant legal requirements, including OPM strategic human capital management regulation requirements. (Recommendation 4) Agency Comments We provided a draft of this report to the Secretary of Veterans Affairs for review and comment. VA provided written comments, which are reproduced in appendix III. VA concurred with all four recommendations. VA also provided technical comments, which we incorporated as appropriate. We are sending copies of this report to the appropriate congressional committees and the Secretary of Veterans Affairs. In addition, the report is available at no charge on the GAO website at http://www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512-2757 or goldenkoffr@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix IV. Appendix I: Leadership Positions and Mission-Critical Occupations Table 2 summarizes leadership positions and mission-critical occupations at the Department of Veterans Affairs (VA), Veterans Health Administration (VHA), and Veterans Benefits Administration (VBA) as identified by the department and administrations. Appendix II: Description of Key Leading Practices for Succession Planning We reviewed our past reports and Office of Personnel Management guidance to identify the following key leading practices for succession planning. The list below explains the importance of the practices and provides examples of how agencies can demonstrate them. 1. Obtain active support and participation from leadership. Agencies’ top leadership actively participates in, regularly uses, and ensures the needed financial and staff resources for key succession planning and management initiatives. This leadership is important because it can provide (1) stability during plan development and implementation, (2) champions within the agency, and (3) integration with other key management planning efforts. This practice may be demonstrated by, for example, leadership participating in key succession planning meetings and ensuring succession planning policies are up-to-date. 2. Develop succession plans aligned with strategic goals. Agencies discuss how workforce knowledge, skills, and abilities for leadership and mission-critical occupations will contribute to the achievement of strategic and annual performance goals. This alignment helps ensure agencies’ plans provide the talent needed to meet their current and future mission requirements. This practice may be demonstrated by, for example, integrating succession planning into strategic planning and annual strategic objectives review assessments. 3. Analyze current and future workforce gaps. For leadership and mission-critical occupations, agencies identify the current talent state and critical skills in the workforce, future workforce needs, and current and future workforce gaps. This gap analysis is important for identifying the skills and competencies needed for achieving its missions and goals even as the agency’s operating environment changes. This practice may be demonstrated by, for example, conducting and documenting current and projected workforce analysis, including workforce gaps. 4. Identify strategies for closing workforce gaps. Agencies identify strategies for closing workforce gaps for leadership and mission- critical occupations, such as recruitment strategies, training, and developmental opportunities. This planning is important for aligning strategies to eliminate gaps, and tailoring workforce programs and processes to the agency’s needs. This practice may be demonstrated by, for example, developing and implementing action plans and training and development programs. 5. Monitor, evaluate, and update succession plans and strategies. Agencies identify and track performance measures and progress against goals to measure the effectiveness of succession management programs, and regularly update plans to reflect lessons learned. This performance monitoring is important for measuring both the outcomes of strategies and how the outcomes have helped accomplish the agencies’ missions and goals. This practice may be demonstrated by, for example, conducting progress assessments or revising programs based on past performance. Appendix III: Comments from the Department of Veterans Affairs Appendix IV: GAO Contact and Staff Acknowledgments GAO Contact Robert Goldenkoff, (202) 512-2757 or goldenkoffr@gao.gov. Staff Acknowledgments In addition to the contact named above, Shannon Finnegan (Assistant Director), Alexander Ray (Analyst-in-Charge), Colleen Corcoran, Karin Fangman, Robert Gebhart, and Sarah Green made key contributions to this report. Steven Flint, Shelby Kain, Christy Ley, Marcia Mann, Rachel Stoiko, and James Whitcomb also made contributions.