May 26, 2020

As federal, state, and local governments are increasingly called upon to address complex and interconnected “wicked problems,” their need for leaders, managers, technical experts, and front-line workers in the right jobs with the right skills at the right time has never been greater. In order to meet the unique demands of this time, the U.S. must develop a strategy that confronts laborious and time-consuming hiring practices, limited salary flexibilities, and promotion rules that value longevity over expertise and performance. Fellows, Anita Blair, Jeffrey Neal, James Perry, Tony Scardino, and Bob Tobias, discuss past, current, and potential efforts to combat these challenges.

What is needed to build a highly skilled, agile, and responsive public sector workforce with appropriate roles for civil servants, contractors, and other service providers?

Anita Blair

In recent years, federal agencies have developed new capabilities to support strategic workforce planning and management. And these new systems and tools increase our ability to assess, develop, assign, and evaluate talent.

Where the public sector still has difficulty is in the most fundamental step to building a workforce—that is, defining the work. Consequently, we still struggle with describing, measuring, and evaluating the work of public organizations at all levels.

The confusion often starts with the authorizing legislation. Laws passed nowadays are the product of divided interests. The compromise necessary to enact a law sometimes results in language that is vague, overbroad, or ambiguous. Multi-thousand-page laws virtually guarantee that implementing agencies will discover internal inconsistencies or logical gaps in the text. Overly prescriptive statutory language can be counterproductive if it prevents agencies from adopting practical efficiencies.

In the private sector, the bottom line – profits – is the standard for deciding what work should be done, and the best way to do it. Incentives in the public sector are not so direct and easy to calculate. To build and manage the public workforce we need, we should start by deciding in clear and simple terms what results they’re supposed to produce.

Jeff Neal

The most crucial reforms government needs are in hiring and compensation. The federal government relies upon hiring and compensation practices that were mostly designed in 1949. Imagine basing the processes for anything of importance on the practices of the Truman Administration. Yet, that is what happens in the federal government. The federal workforce of 1949 was mostly clerical and blue collar. Today, the federal workforce comprises highly skilled knowledge workers. Inflexible hiring and compensation hinder the government’s ability to recruit and retain the talent it needs.

James Perry

Two strategies are critical as foundations to achieve the goal of a highly skilled, agile, and responsive public sector workforce with appropriate roles for civil servants, contractors, and other service providers:

• A civil service built on validated and reliable merit-system principles that enforces public service values equally across all stakeholders (civil servants, contractors and other service providers).
• Enduring, passionate commitment to establish and sustain a public service ethic, what has come to be called public service motivation, which places public service at the center of the relationship between public institutions and those who deliver public services. The substance and spirit of this commitment is captured by Supreme Court Justice Sandra Day O’Connor: “Ours is a Nation built on pride in sacrifice and commitment to shared values—on a willingness of our citizens to give of their time and energy for the good of the whole.” This ethos should pervade our institutions regardless of who is the agent delivering public service.

Tony Scardino

In the Academy’s championing of Grand Challenges facing the public sector, I especially applaud the foresight about the criticality of modernizing the Public Service. As someone who entered public service 3 decades ago and recently departed, I have witnessed firsthand the myriad obstacles agencies and aspiring public servants encounter. Those include a complicated and lengthy application process, an inflexible career path, and unequal pay. While such obstacles can be overcome, it will take a sustained and determined effort.

With a drastically different workforce population than I encountered 30 years ago, it’s no wonder that the Academy has identified the reinvigoration of human capital to be a challenge for federal, state, and local governments. In fact, it’s more relevant than ever, as recent data suggests that the typical millennial remains in a job on an average of roughly two or three years.

Whether or not this is ideal, it is reality. If the workforce has changed so drastically, shouldn’t the employment experience for government workers evolve to meet those new conditions? If the largest-growing segment of our workforce desires to “job-hop”, the public sector should embrace it and create opportunities for employees to seek alternate jobs frequently in order to build on their skills and explore new challenges.

How can we develop strategic foresight mechanisms to anticipate and address changing workforce requirements?

Jeff Neal

At a minimum, to mitigate the risks posed by the hiring and compensation processes, governments must engage in robust workforce planning to identify needed skills; determine lead times for hiring, training, or contracting for the employees; and maintain plans and programs as demands change. At the federal level, few agencies have adequate workforce planning programs, leading to ad hoc hiring/training/contracting efforts that may fail to meet mission demands in a timely manner. The long lead time for producing many government-specific skills means that workforce planning is becoming even more critical. For example, a college graduate hired to be contracting specialist requires two to three years of training and on-the-job experience to become fully proficient. Recruiting private sector contracting specialists is of little value, due to the complex federal contracting laws, rules regulations. Add in the lengthy time required for the antiquated federal hiring processes, and that means an agency must determine its needs for such staff three or more years in advance.

Agencies can mitigate the risks caused by long lead times with comprehensive planning programs to identify current and evolving mission skill demands, and pairing that with hiring, training and contracting programs that are timed to deliver talent when and where it is needed.

James Perry

Recommendations for occupation-specific, market-sensitive pay offered by the Partnership for Public Service, The Volcker Alliance, and National Academy of Public Administration would go a long way to providing needed “strategic foresight mechanisms” to manage changing workforce requirements.[1]

Anita Blair

While “HR” can provide tools and advice to aid in strategic workforce planning, only operational experts and leaders can say what the mission requires workers to do, now and in the future. Professional associations (for example, law, medicine, engineering) offer examples of how communities of interest can drive continuous improvement and promote public interests on behalf of their members.

To promote strategic workforce management, the Department of Defense has organized about 950,000 civilian employees, from over 600 occupational series, into about two dozen occupational “families” called Functional Communities. As with professional associations, Functional Community leaders are charged to define workforce priorities, identify skill gaps, and oversee how competencies are defined, assessed, and developed within suitable career paths.

DoD also has designed and adopted a maturity model – based on established communities such as Acquisition and Financial Management -- to help developing functional communities organize and govern themselves effectively. DoD’s Functional Community Maturity Model allows communities to assess their progress in key areas of leadership and governance, workforce planning, resource planning, and workforce development. Communities can use the model to map what they need to do to optimize workforce management. Where possible, DoD seeks to coordinate civilian functional communities with similar military occupational specialties, which helps expand sources of needed capabilities.

With fast-changing technology, new kinds of jobs appear, and traditional occupations are disrupted. The classic case is Cybersecurity, which entails a collection of competencies found across multiple occupations. Other emerging jobs not aligned with traditional occupational series include Data Science, Digital Engineering, Artificial Intelligence; the list grows fast.

Rather than try to overtake these rapid developments, it may be smarter to focus on basic, elemental competencies as building blocks that can be combined in different ways to produce new capabilities. Modern data management and technology will enable us to map, track, model, develop, and evaluate combinations of competencies. “Skill (or Talent) Stacking” – building a broad set of skills that can be combined, rather than focusing on a single specialty – is becoming a recognized way for individuals to attract more opportunities and build a unique personal brand.

In such a rapidly changing world, foresight is not what it used to be. But constantly staying alert and agile is a good way to manage the risk of surprise.

How do we ensure long-term institutional knowledge capacity amidst the retirement wave?

Anita Blair

OK, Boomer … Before we get too sentimental about the way things have always been, we should ask a few questions!

For example, are our institutions really so great that they should be perpetuated as-is? Is the “institutional knowledge” we’re talking about the product of 30 years of progressive growth and accumulated wisdom – or one year’s worth, repeated 30 times? Could it be that the federal government has a hard time attracting junior workers because there’s a disproportionate number of senior workers who show no signs of leaving soon?

Undeniably, it’s good to know where the landmines are buried. For that purpose, maps are more useful than memories. And speaking of memory, we now have the Cloud.

There are a lot of ways to preserve and transmit knowledge, but it’s equally important to create room for the next generations to grow.

What new human capital systems consistent with merit-system principles (including modernizing policies and practices for recruitment, retention, training, and development) are needed?

James Perry

Changes in recruitment and selection systems, work design and its management, and compensation systems could go a long way to improving the ability of our civil service systems to attract and retain staff, increase role reliability, and stimulate high performance.

First, we should re-orient recruitment and selection systems to hire for the organization, not just the job, thereby emphasizing selection based on competence and commitment to public service. This would require new human capital systems to:

• Make an organization’s identity and reputation salient in assessing its attractiveness to talent.
• Shape job advertising to put greater emphasis on mission and public values
• Use selection procedures that predict both competence, and public service and prosocial motivation.
• Screen candidates with tests for integrity and corruption, build in more realistic job previews, and use probationary periods and alternative selection processes to validate hiring decisions

Second, we should leverage the meaningfulness of public service and public work to motivate high performance:

• Improve capacity to design work to connect employees with direct service beneficiaries so employees understand the social significance of their work.
• Increase knowledge about and use of self-persuasion and other self-administered interventions to connect employees to beneficiaries.
• Increase knowledge about and use of job crafting among supervisors and employees to give employees more influence in how they frame their work, physically, socially and cognitively.
• Increase career counseling to facilitate employees’ identifying and strengthening their callings.

And, finally, we should align compensation systems to reinforce public service by:

• Using total compensation as the benchmark for comparisons with other sectors
• Using a variety of methods (e.g., alternative, efficiency and public-service-motivation adjusted wages) to benchmark base pay to the value of the work.
• Designing pay comparability assessments to use salary surveys and complement them with indicators such as job application queues and turn-down rates to provide insights into adjustments that could be made in pay rates.
• Establishing policy and designing salary structures for more pronounced wage dispersion for high-skill occupations and executives.
• Using low-powered incentives (such as recognition) rather than high-powered incentives (such as traditional forms of contingent pay such as merit pay) to reinforce public service/prosocial motivation and incentivize high performance.

Anita Blair

We sometimes forget that the intricate processes associated with enforcing Merit System Principles are not dictated by law but were designed by regulators to provide a safe harbor for managerial decisions. Managers who follow the prescribed process gain a high level of assurance that they won’t be found to have violated the law. The safe-harbor approach, however, needs to foreclose every loophole and thus gets more complicated and elaborate over time.

We could enforce Merit System Principles differently, without changing the law at all. For example, to address the problem of nepotism, we could ask hiring managers and selectees to state under oath that they are not related. Similarly, to prevent political or other favoritism, we might require sworn disclosures about relevant common interests. If the issue is ensuring that qualified Americans get a chance to be considered for federal jobs, we could invite applicants to submit their qualifications to a database and require managers to consult the database and provide reasons for their choices before making hiring decisions. False statements, conspiracy, or other abuse of these processes could lead to serious penalties, including removal and being barred from future federal employment.

Although we usually associate Merit with nondiscrimination, Merit System Principles also require that the federal workforce be used efficiently and effectively; that employees should be retained on the basis of adequate performance and separated if unable or unwilling to meet required standards; and that employees should be provided training to improve performance.

We need to build better managers and supervisors, including giving them effective training and tools to deal with problem employees. Bullying, abuse, or toxic behavior by anyone – supervisor or employee – should not be tolerated. Year after year, large majorities of federal employees responding to the Federal Employee Viewpoint Survey disagree that “steps are taken to deal with a poor performer” in their work unit. We might dedicate more effort to address the problem of co-workers who make it harder for good workers to do their jobs.

Tony Scardino

It is easy to make statements like “fix this” or “change that.” The hard part is to identify ways to improve archaic and long-standing regulations that restrict flexibility and limit options for an incoming workforce that is unlike their predecessor generations. If we start with some specific goals that would need more examination before adoption, let’s begin with the following: (1) streamline the application process to allow for more, not less, human interaction (even virtually); (2) model effective practices from private sector hiring by designing an employment system that allows more options for public servants to move around to different job series, agencies, and locations; and (3) create a less rigid pay system that more closely tracks to the commercial world, (that is, not all GS-14 positions are created equal, so harder-to-find skillsets should correlate to higher paying jobs).

If we accept that changes need to be made to reduce attrition and build a dynamic, flexible, and dedicated workforce, a good place to start would be updating Title 5 of the US Code, which governs rules of federal government organizations and its employees. Admittedly, this would be a big lift. But if we don’t start now, then when? I’m reminded of the phrase that “hope is not a good strategy.” Incisive and thoughtful analysis needs to be done on Title 5 in order for the federal government to remain competitive, especially in times of a strong national economy or even more recently a worldwide pandemic.

In order to streamline the application process, government agencies should relax the rules for specific knowledge, skills, and experience. We should question why we hire into job series so stringently. There would be many benefits to hiring entry level employees as “generalists” and let them move around to other similar positions throughout the government. In this way, a public servant could spend a decade or more working at different jobs, while learning more about an agency’s mission, sharing knowledge with various colleagues along the way. Specialization is desired, even critical, for some occupations, but less so for others. Corporate America routinely hires the best possible job candidates without specific vacancies in mind. They recognize that natural attrition and changing skillset requirements bring a continuous need for new employees. All levels of government should follow suit and find ways to expand the flexibility of the hiring process to improve both recruitment and retention.

Flexibility in career paths is critical for the public sector to recruit and retain top talent.

Today’s workforce is anticipated to work into their late 60’s or early 70’s. With a career span approaching 50 years, it’s anticipated that public service will only be a portion of a professional career, whereby experienced workers will enter public service if the barriers for entry and lateral movement are reduced. Shifting to the Federal Employees Retirement System (FERS) almost 40 years ago diminished the “golden handcuffs” effect of long-time service by reducing the impact on pensions if federal employees left the government before reaching retirement age. However, more needs to be done to entice newer generations to join the public sector at different times during their long careers. This lateral movement for talented workers among and between the public, private, and non-profit sectors will create perspectives and skillsets that benefit each sector.

Lastly, all levels of government continue to require hiring into job series and grade levels, which is a practice that is too rigid in terms of compensation levels available to talented professionals interested in working in the public sector. Many jobs require primarily technical skills that are challenging to acquire, while others require softer skills that are hard to teach. Yet both skillsets and attributes are treated equally in terms of salaries, where time in grade oftentimes determines promotion potential and higher compensation.

How should the MPA curriculum be adapted to meet future workforce needs?

James Perry

The MPA (and its equivalents) has been resilient, adapting continuously over the years, to absorb needs to upgrade student knowledge and skills about institutions (e.g., the significant expansion of nonprofit sector education within MPA programs since 1990), tools (including statistical tools, and economic and data analytics), and values. The MPA may need further adaptation, but to focus primarily on it will leave the future workforce woefully underdeveloped. Although a Masters has been the flagship degree in public affairs, public administration and public policy for decades, we need to think more expansively about education to meet future workforce needs.

The number of MPA degrees granted each year serves only a small part of the future public service workforce. To meet future workforce needs, employers, universities, schools of public affairs, and others should consider other realities of the future public workforce:

• Undergraduate education. A larger portion of the future workforce will come to public service with undergraduate degrees only. Universities and public affairs programs must consider how undergraduate curricula serve the needs of these students for public service;
• Continuing and professional education. Higher education, especially schools of public affairs and administration, must increase demand for and its capacity to deliver continuing education for both alumni engaged in public service and public servants without prior exposure to public service education;
• Civic and citizenship education. American democracy and the institutions that sustain it depend on an informed and educated citizenry. Thus, a critical future workforce need is meaningful and effective civic education (see, for example, the March 2020 final report of the National Commission on Military, National and Public Service, Inspired to Serve, https://inspire2serve.gov/sites/default/files/final-report/Final%20Report.pdf)

Bob Tobias

Although it is possible to rewrite an MPA or MPP curriculum in terms of addressing the Grand Challenges, the most innovative ideas based on the best available research published in the most prestigious peer reviewed journals, will never be implemented to successfully address the Grand Challenges without the personal development of public sector leaders. To prepare students to successfully design and implement solutions to the Grand Challenges, there must an increased curriculum focus on the development of students’ personal capacity to lead themselves and others.

The world of the Grand Challenges represents the ever more complex challenges faced by public sector leaders, the relationship between cause and effect is clear only in retrospect, and solutions must emerge from mining collective intelligence while conducting safe to fail experiments. This world requires adaptive leaders with interpersonal skills seen in high levels of emotional intelligence coupled with a level of adult development that includes the ability to understand different perspectives and incorporate those differences to create adaptive solutions.

These adaptive challenges cannot be dealt with by following established knowledge, proven guidelines, and methods known to experts. Adaptive challenges are those for which the necessary knowledge to respond does not yet exist, so training in “best practices” inevitably falls short. While technical problems may be very complex and critically important (like replacing a faulty heart valve during cardiac surgery), they have known solutions that can be implemented by current know-how. They can be resolved through the application of authoritative expertise and through the organization’s current structures, procedures, and ways of doing things. Adaptive challenges require adaptive leaders for resolution.[2]

As Albert Enstein noted, “[w]e cannot solve our problems with the same level of thinking that created them.” Federal leaders want to increase the performance of their organization through those they lead but are able to maximize the contributions of those they lead. Ingesting federal leaders with expertise concerning the proper filing out of evaluation forms or increasing the technical training in their field will not create the adaptive leaders we need. It takes much more.

When Jim Collins, author of Good to Great, was asked whether Level 5 leaders are born or can be developed, he said he didn’t know, but what he did know was there is no chance to reach the Level 5 leadership level unless the aspiring leader engages in “inner development.” What is inner development?

We know it when we experience it in the behavior of others: it is those for whom I am willing to give my discretionary energy to accomplish their goals and objectives. When I ask federal leaders to identify the behaviors that induced them to give their discretionary energy to another, they always identify the same types of behaviors: they spent time helping me develop; had my back; empowered me and allowed me to fail; listened; accepted my advice and respected me. In short, they engaged intellectually, and, more importantly, emotionally with me. There is never a reference to technical ability. All references are to the quantity and quality of emotional connection.

The “inner development” described by Bill George in Truth North is a shift in a leader from “I” to “We;” a change in focus from the leader’s success as an individual to a genuine concern for the mutual development and achievement of the group.

The data is clear. A “We” workforce, one where the leader is engaged with the led and the led with each other, is far more productive. Gallup has discovered work units in the top quartile of employee engagement outperformed those in the bottom quartile by 21 percent in productivity. In addition, they saw a decrease of 37 percent in absenteeism, and a 48 percent decrease in safety accidents.

It is the responsibility of a leader to create a “We” workplace. Gallup found that 70 percent of variance in team level engagement is based on the leader. This is mirrored by the finding of the Partnership for Public Service that the “key driver” of employee engagement is effective leadership.

Why Is it so difficult for federal leaders to emulate that which they so admire, when the data shows it is so necessary for success? Habits are hard to identify because the behavior is automatic and hardly noticed, hard to unlearn, and it is even harder to create new behavior habits. Inner development does not come easy.

It occurs when a leader is able to move the values, assumptions, beliefs and expectations (VABES) that drive her behavior automatically, habitually, and unconsciously into plain sight and then make a conscious decision to either adopt or change those VABES. The more VABES a leader consciously determines, the more authentic are her behaviors. And the easier it is for her to collaborate intellectually and connect emotionally with those she leads.

We make decisions about leader authenticity very quickly, and the greater a leader is judged as lacking authenticity, the greater the distance the led create from the leader. The led run away from an inauthentic leader at precisely the time the leader needs connection to solve ever more adaptive problems leaving moldering piles of unsolved, unaddressed problems (e.g. Grand Challenges).

As Alvin Toffler once observed, “[t] he illiterate of the 21^st century will not be those who cannot read and write, but those who cannot learn, unlearn, and relearn.”

Such inner development demands dedicated time and focused attention in a fast-paced work environment. For example, it requires the time and courage to:

1. Engage in self-reflection to define my true purpose and the decision to live it;
2. Determine whether my habitual solutions continue to be effective and, if not, exhibit the dedication to unlearn the old and relearn something new;
3. Evaluate whether my perception of the quality of my relationship with those I lead is symmetrical with their perception of me;
4. Identify the specific actions I might take to create a workplace where it is safe to say “I don’t know;”
5. Notice whether I am willing to ask for help from those I lead;
6. And, am I willing to cultivate the humility necessary to identify and remove my personal barriers to do what I now know should be done.

A leader’s inner development also requires an agency investment. Most leaders are unable to engage in inner development by reading a book and acting on what they learn. It makes sense because it would be an oxymoron for a person seeking to learn how to connect with others to be able to learn the behavior without interacting with others. Most leaders need a group learning experience built on trust and mutual respect, where they are supported by colleagues as they unlearn old behaviors, identify new desired behaviors and take one step forward and two steps back. They need to experience their failures as new learning and learn to regularly celebrate success. They need the confidence of practiced experience in order to apply what they learn in their workplace.

Federal sector leaders want the opportunity for inner development to increase productivity.

They recognize that accumulating power and directing others is not sufficient to inspire knowledge workers to engage with each other to solve adaptive problems for which there in no known answer.

Those they lead are entitled to the best possible quality of leadership, and the public demands better results. It is time for MPA and MPP Programs to create the curriculum that challenge students to engage in the inner development necessary to successfully lead in today’s work environment.

What impact does the Covid-19 pandemic have on this Grand Challenge?

Bob Tobias

It highlights the need for leader inner development to address the adaptive challenge of creating a high performing organization that is for the most part quarantined at home and uncertain of future rules and requirements—often even lacking the basic equipment, organization, and support for a productive teleworking environment.

Working at home Increases the need for the personal development of federal leaders. Working remotely requires a new level of trust and the ability to increase empowerment and goal clarity. It also requires the courage and ability to create collaborative relationships in what is for the most part a command and work control environment, which is antithetical to the style of leadership and organizational culture needed for success.

And the undisputed need for pace, may thwart the need to slow down, reflect, decide to change, practice the new, and become comfortable with the new. I suggest the results of slowing down will reinvigorate leaders looking for a new approach, followers hungering for a new approach, and the public deserving of a new approach.

Universities are in survival mode, particularly in the Fall 2020 period. New class development is not on their agenda.

In short, the COVID-19 crisis accentuates the need for personal leadership development, and, at the same time increases the risk it will not be available for those who need it the most.

James Perry

Covid-19 may need to move to our rear-view mirror before we have the perspective needed to answer this question. My sense now is that our collective experience with Covid-19 will influence the general climate for modernizing and reinvigorating public service. Will the sum of forces flowing from our experience facilitate “modernizing and reinvigorating”? I expect they will. We may need to embrace radical changes in the process, but I also expect our experience will reinforce needs for essential public workers and functions. The cumulative effects may sustain reinvigorating public service.

Tony Scardino

Modernizing the public sector won’t be a quick or easy endeavor, but great interest exists for developing a workforce that is modern, agile, and exceptional. This is all the more important during the COVID-19 pandemic and its eventual aftermath. Without modifications to the existing human resources systems and requirements, this is not going to happen. Urgent review should commence, with action imminent, so that changes are made timely and public service can continue to attract and retain the best and the brightest.

ABOUT THE CONTRIBUTORS

Anita Blair. Deputy Assistant Secretary of Defense, Civilian Personnel Policy, U.S. Department of Defense. Former Deputy Assistant Secretary for Human Resources and Chief Human Capital Officer, U.S. Department of the Treasury; Chief Strategist, National Security Professional Development Integration Office. Positions with U.S. Department of the Navy: Acting Assistant Secretary of the Navy, Manpower & Reserve Affairs; Deputy Assistant Secretary of the Navy, Total Force Transformation; Deputy Assistant Secretary of the Navy, Military Personnel Policy. Business Lawyer & Litigator, Private Law Practice. Note: Anita Blair is an Academy Fellow and a federal employee. The views expressed here are her own and not attributable to the federal government or any agency.

Jeffrey Neal. Former Chief Human Capital Officer, Department of Homeland Security; Chief Human Resources Officer, Defense Logistics Agency, U.S. Department of Defense; Deputy Chief Human Resources Officer, U.S. Department of Commerce.

James Perry. Distinguished Professor Emeritus, Paul H. O’Neill School of Public and Environmental Affairs, Indiana University; Editor-in-Chief, Public Administration Review. Former positions with Indiana University: Associate Dean; Director, American Democracy Project; Director, Institute for the Study of Government and the Nonprofit Sector. Former Senior Research Associate, National Academy of Public Administration; Special Assistant to the Assistant Secretary for Personnel Administration, U.S. Department of Health and Human Services.

Tony Scardino. Managing Principal, Grant Thornton. Former Deputy Under Secretary (Acting) and Chief Financial Officer, United States Patent and Trademark Office, U.S. Department of Commerce; Associate Chief Financial Officer for Budget, U.S. Department of Housing and Urban Development; Deputy Staff Director and Chief Financial Officer, Federal Election Commission; Budget Officer, Broadcasting Board of Governors; Senior Budget Analyst, Federal Bureau of Investigation.

Bob Tobias. Distinguished Practitioner in Residence, Department of Public Administration and Policy, American University; Director, Key Executive Leadership Program, American University; Director, Institute for the Study of Public Policy Implementation, American University; Member, IRS Oversight Board. Former positions with National Treasury Employees Union: National President; Executive Vice President; General Counsel. Former Member, Commercial Activities Panel.