Audit of the CPSC’s Position Designation and Suitability Program
Update and implement EXRM directives, policies, and procedures regarding position designation to reflect current EXRM operations and address current OPM policies and guidelines.
Develop and maintain an accessible database with all information required to effectively manage the position designation and suitability program. At a minimum, this system should contain the name of the employee or contractor, position number and title, position designation, tier of background investigation completed, entry-on-duty date, date the background investigation was requested, date the background investigation was completed, whether it was an initial investigation or reinvestigation, whether reciprocity was applied, and reinvestigation due date.
Use the information developed in Recommendation Two to track an employee’s investigation versus the designation of their position and ensure they are properly aligned.
Use an automated tool to track when employee and contractor reinvestigations are due.
Update the investigations of employees whose completed investigation has exceeded the five-year reinvestigation requirement.
Allocate the appropriate resources going forward to ensure that all reinvestigations are initiated on or before the due date.
Establish a process to include Office of Human Resources Management during the drafting of the statement of work to determine the appropriate investigative tier for contractors prior to when the request for quotes is released to potential vendors.
Develop a formal documented process (directive or standard operating procedure) for onboarding contractors.
Develop a system to communicate any changes in the onboarding process to contracting officer’s representatives and other personnel involved in the onboarding of employees and contractors.
Develop and document a systematic and repeatable risk assessment process to evaluate the risk of applying reciprocity for incoming contractors.
Regarding contractors, develop and maintain an accessible database containing the information outlined in Recommendation Two, as well as the contract number, similar CPSC position, contractor name, employer, and name of contracting officer’s representative.
Complete the work required to fully implement OPM’s recommendations from 2017.