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Department
of Health
and Human Services |
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Chief
Professional Officer Board
Office of the Surgeon General
Rockville MD 20857 |
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Date: |
February 16, 2006 |
From |
Chief Professional Officers Board |
Subject |
Recommendation to Suspend the “3 and Freeze” Promotion
Policy |
To |
The Surgeon General |
Thank you for meeting with the Chief Professional
Officers (CPO) Board on February 9 to discuss our concerns and
recommendations regarding the “3 and Freeze” promotion policy (Section F.3, CCPM
Subchapter CC23.4, Instruction 2-Temporary Grade Promotion). This
policy, approved by the Acting Assistant Secretary for Health in
December 2003, “freezes”
officers in their temporary grade for the remainder of their career
if they are not promoted after three attempts, with the exception
that they may be considered a fourth and final time at the request
of an OPDIV/STAFFDIV Head. The policy was approved upon completion
of the 2003 Promotion Task Force report and was based on the assumption
that several other critical actions would be undertaken concurrently
to rectify the entire promotion process, including review and revision
of the billet system and a determination of promotion rates based
on projected needs of the Corps according to the revised billet system.
However, these other critical actions have not yet been undertaken.
The CPO Board has analyzed relevant data and the projected effect
of activating this policy in the absence of the other key elements
recommended by the Promotion Task Force. Based on this review and
the expected adverse impacts on the Commissioned Corps and the Department,
the CPO Board recommends an immediate suspension of the policy and
establishment of a Task Force to further evaluate the policy and
to develop recommendations for its revision, specifically in the
context of the other ongoing Transformation efforts. Such a revised
process would consider criteria such as the officer’s current
and past performance, potential to excel in a higher grade, and role
in a Transformed Corps, before permanently restricting his or her
further career advancement.
ISSUE:
The USPHS temporary grade promotion policy
(CCPM Subchapter CC23.4, Instruction 2- Temporary Grade Promotion)
approved by the Acting Assistant Secretary for Health in December
2003 contains a provision commonly referred to as “3 and Freeze”(Section F.3).
Under this provision, beginning in PY 2006, Commissioned Corps officers
who do not receive a promotion after three attempts even if they
are recommended for promotion, will remain, or be “frozen,” in
their temporary grade for the remainder of their career. These officers
are rendered ineligible to be evaluated for promotion again, with
the exception that they may be considered a fourth and final time
at the request of an OPDIV/STAFFDIV Head. Furthermore, a process
for the fourth consideration does not yet exist.
It is our belief that any decision to
restrict an officer from being considered for future promotions
should be based on a careful review of an officer’s performance and potential, rather than
on an arbitrary number of promotion board considerations. The promotion
rates for any given year are not based on individual officers’ performance,
and thus officers should not be automatically penalized without consideration
of factors beyond the officer’s control.
BACKGROUND:
The “3 and Freeze” policy
was developed in response to recommendations from a 2003 Promotion
Task Force. Its purpose was to reduce the workload on promotion
boards tasked with reviewing each promotion-eligible officer regardless
of how many times the officer had been reviewed by a promotion
board, but not promoted. The Task Force reviewed promotion data
through 1992 and determined that officers who were not promoted
after four attempts were unlikely to be promoted.
DISCUSSION:
In 2003, the implementation of the “3 and Freeze” policy
was based on having a prospectively developed billet system in place
as well as promotion rates based on such a billet system that would
meet the needs of the Corps. Neither of these elements is in place
at this time.
The Promotion Task Force’s recommendation was based on a
statistical analysis of promotion data for 1988-1991, some of which
was published in the August 1992 issue of the Commissioned Corps
Bulletin which reported that “an officer’s best chance
for promotion is the first time he/she is considered for a specific
temporary grade.” The Commissioned Corps Bulletin went on to
report: “For the temporary 0-4 grade, the probability for promotion
after being considered four times is practically nonexistent. For
the temporary 0-5 grade, an officer’s probability for promotion
is markedly reduced after having been considered five times, but
promotion may occur. This data also indicates that an officer may
still be promoted with some frequency to the temporary 0-6 grade,
even after being considered as many as seven times.” The Task
Force also cited 2001 promotion data for the Pharmacy category that
showed there were no promotions beyond four reviews for the temporary
(T) O-4 and T O-5 grades and less than 9% of those reviewed for the
T O-6 were successful after four reviews.
The CPO Board examined promotion data for 2004 and 2005 and future
projections for 2006 and 2007 provided by the Office of Commissioned
Corps Force Management (OCCFM). Specifically the data analyses revealed
that:
- Temporary promotions have become
increasingly more competitive, particularly for the O-6 grade.
In Promotion Year (PY) 2005, officers promoted to the T O-6 grade
had an increasing number of previous considerations, with 24%
of these officers having previously been considered three or
more times, and some seven or more times.
- There is considerable variation among professional categories
in promotion rates after the first attempt. Results based on the
Pharmacy category are not representative of the other individual
categories or of the Corps as a whole. For example, of the officers
promoted to the T O-6 grade in PY 2005, only 11% of pharmacy officers
had previously been considered three or more times, compared to
30% of the Medical category, 75% of the Veterinary category, 100%
of the Therapy category, and 24% of all officers promoted. The
CPOs looked at those individual officers (by name) within their
category who had been promoted after three or more previous tries
and determined that most were performing admirably and that it
would have not have been appropriate to freeze these officers at
the T O-5 grade. The assertion in the 1992 Commissioned Corps Bulletin “that
an officer’s best chance for promotion is the first time
he/she is considered for a specific temporary grade” may
not be valid for some categories today. For example, there were
no promotions to temporary O-6 grade in PY 2005 for officers up
for the first time in either the Veterinary or Therapy categories.
- Promotion rates for T O-6 have fluctuated considerably
since 1988 ranging from a high of 42% in 1992 and 1993 to a low
of 15% in 2004. This variation in promotion rates adds to the arbitrary
nature of the “3 and Freeze” policy, since promotion
rates are not directly linked to the qualifications of officers
under consideration or their billet grades.
- A projected 322 T O-5 officers
(43% of all T O-6 eligible officers and 68%, 62%, and 55% of
T O-6 eligible officers in the Therapy, Dietitian, and Medical
categories, respectively) will be frozen in grade for the remainder
of their career after PY 2006 based on a 25% promotion rate.
This represents 20.5% of all current T O-5s in the Corps and
5% of the current total active duty strength (excluding the Commissioned
Officers Student Training and Extern Program (COSTEPs).
However, a differential impact is expected across categories. For
example, 41% of all current T O-5s in the Therapists category are
expected to be frozen, followed by the Dietitian (28%), Scientist
(28%), and Medical (27%) categories. The categories with the lowest
percentage of current T O-5s projected to be frozen in grade are
Health Services (13%), Engineer (14%), Pharmacy (15%), and Environmental
Health (16%). If the promotion rate for T O-6 is less than 25%, then
these numbers and their impact will increase accordingly.
- While the new promotion policy
was accompanied by the provision of categoryspecific and Corps-wide
benchmarks to assist officers with preparing for promotion precepts,
this has not been accompanied by career development infrastructure
and other enhancements needed to support successful career planning
and a transparent promotion process.
Impact on the PHS Mission
The CPO Board is concerned that implementation
of this policy will have a detrimental effect on the Corps’ ability
to perform its public health and emergency response missions. Specifically,
the Board is concerned about significant adverse impacts on the following
aspects of the Corps:
Esprit de Corps/Deployment Readiness:
With nearly 50% of the Corps deploying in response to the 2005
hurricanes, and the highest level of readiness in the history of
the Corps, it is clear that there is an unprecedented level of
esprit de corps among officers. Imposing the “3 and Freeze” policy could have a devastating effect
on the morale of all officers, many of whom were pivotal in the recent
disaster response and who will be critical in responding to future
disasters. Nearly all of the officers who will be affected by the “3
and Freeze” met readiness standards for PY 2006, and it is
estimated that at least 50% of these officers deployed for the 2005
hurricane response. By being frozen in grade, officers have little
or no incentive to obtain or maintain their readiness status, support
the Professional Advisory Committees, or recruit for the Corps.
Recruitment: Potential Corps officers may not consider a career
in the Corps if they ascertain that their chances of career advancement
can be limited by administrative decisions not directly related to
their professional performance.
Retention: Once an officer is frozen for future promotions, the
officer may decide to leave the Corps immediately or perhaps decide
not to serve beyond 20 years. This is especially important for categories
in which there are current shortages and/or declining numbers (e.g.,
medical, nurse, dental, veterinary). This may lead to further reduction
in the overall Corps strength and ultimately prevent or at least
diminish the Corps ability to achieve its mission. Thus, increased
efforts will be needed to recruit and retain replacements for these
officers, which may divert limited resources from public health practice
to recruiting, hiring, and training personnel and other force management
activities.
RECOMMENDATION:
To ensure the continuity of the Corps’ ability
to carry out its public health mission to advance, protect, and
promote the health and safety of the nation, the CPO Board respectfully
recommends that you:
(1) Support an immediate suspension of
the “3 and Freeze” policy,
Section F.3 of the USPHS temporary grade promotion policy (CCPM Subchapter
CC23.4, Instruction 2- Temporary Grade Promotion), to allow time
for review of this policy and the development of new recommendations
for consideration, and
(2) Support establishment of a Task Force
with representation from the CPO Board, the Surgeon General’s
Policy Advisory Council (SG PAC), and the Professional Advisory
Committee (PAC) Chairs to a) evaluate the implications of this
policy within the context of the Transformation and b) propose
recommendations for future promotion policies that are in line
with the goals of the Transformation.
If you concur with our recommendations, we ask that you forward
the attached memorandum to the Assistant Secretary for Health for
approval and action.
Thank you for your continued exemplary leadership of the Corps.
Very respectfully,
William S. Stokes, DVM, DACLAM
Chief Veterinary Officer
Chair, CPO Board
The CPO Board:
RADM Dushanka Kleinman, Chief Dental Officer
RADM Richard Barror, Chief Engineer Officer
RADM Carol Romano, Chief Nurse Officer
RADM Robert Pittman, Chief Pharmacist Officer
CAPT Linda Brown, Chief Health Services Officer
CAPT Janice Huy, Chief Dietitian Officer
CAPT Charles McGarvey, Chief Therapist Officer
CAPT Helena Mishoe, Chief Scientist Officer
CAPT David Rutstein, Chief Medical Officer
CAPT Craig Shepherd, Chief Environmental Health Officer
CAPT William Stokes, Chief Veterinary Officer
RADM Richard Wyatt, Research Officers Group (ex officio)
cc:
Deputy Surgeon General
Chief of Staff, OSG
SGPAC
PAC Chairs |