I. PURPOSE

This directive provides revised procedures for supervisors in the Office of Field Operations (OFO) who conduct, document, and report on IPPS assessments. FSIS has revised this directive in its entirety.

KEY POINTS

• Introduces a revised IPPS Assessment Form
• Introduces new guidance on conducting an IPPS
• Merges content from the IPPS Supervisory Guide

II. CANCELLATION

FSIS Directive 4430.3, Revision 3, In-Plant Performance System (IPPS), 9/11/12

III. BACKGROUND

A. IPPS provides a firsthand, onsite observation of how well employees conduct FSIS inspection and verification procedures in federally-inspected establishments. In addition, IPPS assesses employees’ demonstrated knowledge of job requirements, appropriate regulatory decision-making, and ability to execute inspection and verification procedures.

B. This directive is to be followed by OFO supervisors who rate the performance of non-supervisory in-plant inspection program personnel (IPP). In-plant inspection positions that are subject to IPPS assessments are identified in Attachment 1. The supervisory positions that are required to conduct IPPS assessments include:

1. Front-line Supervisors (FLS)
2. Multi-IPPS Supervisors
3. Supervisory Public Health Veterinarians (SPHV)
4. Supervisory Consumer Safety Inspectors (SCSI)

C. IPPS is a tool that supervisors use to assess the work of non-supervisory in-plant inspection program personnel (IPP). IPPS includes the following benefits:

1. Encourages effective communication between supervisors and their subordinates;
2. Identifies and addresses the need to improve employees’ knowledge of their job requirements;
3. Encourages correlation with employees to ensure consistency in inspection methods and applications;
4. Recognizes on-target or noteworthy employee performance;
5. Assists in measuring organizational performance through OFO’s performance standards; and
6. Links IPPS assessment results and work unit meeting topics to address common or group needs that are discovered during IPPS visits (example: matters on which supervisors find misunderstandings or lack of program execution among multiple inspection personnel).

IV. GENERAL SUPERVISORY RESPONSIBILITIES

A. Supervisors are to conduct at least two IPPS assessments for employees covered by IPPS during the performance rating cycle. Typically, the first IPPS assessment is conducted between setting performance standards and the midyear progress review. The second IPPS assessment is usually conducted between the midyear progress review and the completion of the annual performance rating.

EXCEPTION: If an employee is supervised for part of the year, it may not be feasible for a supervisor to conduct two assessments before the close of the rating cycle.

B. Supervisors can conduct more than two IPPS assessments during the rating year and are to do so if they cannot thoroughly assess all of the elements and sub-elements over two assessments, or if they have a need to follow up on issues identified in previous IPPS assessments.

C. Supervisors are to ensure that IPP are reporting inspection results in accordance with Agency regulatory requirements, policies, and procedures.

V. OVERSIGHT AND MANAGEMENT CONTROLS

A. OFO has established a management control system that provides multi-layered, in-depth management oversight of the public health and management activities carried out by IPP. The management control system also provides OFO with the capability to demonstrate and verify its effectiveness in protecting the public health by achieving and maintaining specific levels of performance in its daily food safety, food defense, and management and supervisory operations.

B. To carry out this oversight, OFO managers and supervisors review IPPS assessment results and provide appropriate feedback as follows:

1. The SPHV reviews 25 percent of IPPS assessments conducted by the SCSI with at least two of these reviews accomplished by direct observation.
2. The FLS reviews 10 percent of IPPS assessments conducted by the SPHV and SCSI with 1 percent of these reviews accomplished by direct observation.
3. The District Manager (DM) team reviews 10 percent of IPPS assessments conducted by the FLS, SPHV, or SCSI with at least 1 percent of these reviews accomplished by direct observation.
4. The Executive Associate for Regulatory Operations (EARO) reviews 2 percent of IPPS assessments that have been reviewed by the DM team.

VI. IPPS AND THE PERFORMANCE MANAGEMENT SYSTEM

A. IPPS does not replace the Agency’s performance management system. OFO uses IPPS, which applies to non-supervisory in-plant occupations, to assess employees’ knowledge of their job requirements. IPPS:

1. Is designed to provide supervisors with a structured process to look at specific elements of the job;
2. Is used to provide feedback to employees to identify, address, and correct areas where there is a need for improvement in performance; and
3. Does not provide or assign a performance rating. Therefore, IPPS data can be used, along with other data and information about an employee’s performance, to determine the performance rating.

B. Performance management is mandated by 5 U.S.C. Chapter 43 and is a statutory requirement for Federal agencies. Every Federal agency is required to have a performance management system under which supervisors identify and set performance expectations and monitor performance. FSIS monitors performance by way of a midyear progress review and rates performance annually by assigning a summary level rating. Summary level ratings are expressed as Outstanding, Superior, Fully Successful, Marginal, or Unacceptable.

C. Supervisors are to use their judgment when combining data from IPPS assessments that are completed during the rating period and other information regarding an employee’s performance. The performance rating is to reflect the employee’s performance for the entire rating cycle.

D. The IPPS Assessment Form does not replace any existing performance appraisal processes or FSIS forms. Supervisors are to continue to use AD-435E and the PRT to set performance expectations, conduct progress reviews, and rate employees annually on their performance.

VII. TIMEFRAMES FOR CONDUCTING REQUIRED IPPS ASSESSMENTS

A. Supervisors, at their discretion, may conduct more than two IPPS assessments during the rating year. Supervisors are encouraged to do so if they cannot thoroughly assess all the performance elements over two assessments, or if they need to follow up on issues identified in previous IPPS assessments.

B. For guidance purposes, the following are the general timeframes:

1. October 1 through October 30. Issue new performance standards for the beginning of the rating cycle, sign and date Blocks 12 and 13 of FSIS Form 4430-10.
2. November 1 through February 28. Conduct the first IPPS assessment and document results on the IPPS Assessment Form (See section IX. for the form’s availability).
3. March 1 through March 31. Conduct the midyear progress review, sign and date Block 15 on FSIS Form 4430-10.
4. April 1 through September 30. Conduct the second IPPS assessment and document results on the IPPS Assessment Form.
5. October 1 through October 30. Complete the annual performance rating at the end of the appraisal cycle and sign Blocks 19 and 20 on FSIS Form 4430-10.

VIII. IPPS ASSESSMENT PROCESS

A. When conducting IPPS assessments, supervisors are engaged in fulfilling their critical Supervision performance element. In addition, supervisors are to fulfill requirements related to the critical Mission Support performance element, as IPPS is a means by which supervisors ensure inspection personnel are carrying out their critical mission-related work activities. To receive a Fully Successful rating in these critical elements, supervisors are to successfully fulfill their responsibilities related to the IPPS.

B. The supervisor plays a key role in ensuring that:

1. Decisions made by IPP are uniform, consistent, and in accordance with applicable statutes, regulations, issuances, and other Agency policies; and
2. Duties performed by IPP are in accordance with prescribed inspection methods and procedures.

C. Supervisors also are to ensure that IPP are applying the appropriate inspection methods, using effective regulatory decision-making, documenting findings appropriately, and implementing regulatory enforcement actions properly.

IX. ASSESSMENT CRITERIA

A. OFO supervisory personnel are to use the following steps to assess non-supervisory IPP knowledge of their job requirements.

B. Assess the Performance Elements. The performance elements and activities are tailored to non-supervisory in-plant inspection program occupations. The performance elements include:

1. Mission Support (Critical);
2. Communications (Critical); and
3. Individual Contributions to the Team.

C. Plan and Prepare for IPPS Assessment. Preparation is an important aspect of any IPPS assessment. Before conducting the IPPS assessment, the supervisor is to:

1 . Select a sufficient number of elements (and their sub-elements) on the IPPS Form to cover during the IPPS assessment to ensure that all applicable elements are covered for the positions before the end of the annual rating period.

NOTE: Make sure the mandatory critical mission support and other critical elements are covered first.

2. Determine how employees are maintaining electronic information as required by their positions.

3. Review and assess Public Health Information System (PHIS) data and reports, where applicable, to identify potential problem areas to focus on during the IPPS assessment. Attachment 3 outlines PHIS reports and other data sources supervisors can use to prepare for an IPPS visit. Supervisors are to also review these data sources to determine whether IPP responsible for maintaining the PHIS system at the plant level are keeping the establishment profile current, completing routine inspection tasks, properly entering data concerning scheduled procedures performed or not performed, and entering unscheduled procedures performed. This data review will give the supervisor insight into the decisions that the inspector makes regarding which procedures to perform and at what frequency. The supervisor can use the standard reports to determine whether trends are developing, which indicate whether the inspectors are on or off target in performing their verification duties. Examples of data sources supervisors are to review before an IPPS visits include:

• a. Review noncompliance records to determine whether the NRs are being written in accordance with FSIS Directive 5000.1, Verifying an Establishment’s Food Safety System.
• b. Use the electronic Animal Disposition Report from PHIS to determine whether the inspector or the PHV is keeping the data current and is performing the appropriate humane handling procedures. The supervisor is to review the data to see if humane handling procedures performed are covering all humane handling activities over time, and that proper times are recorded for each activity.
• c. Review food safety assessments and enforcement actions at the establishment where the assessed employee participated in a recent food safety assessment or enforcement action. The IPPS visit can be used to determine the inspection personnel’s effectiveness in carrying out the verification plan and reporting on issues identified. The supervisor is to also review the verification plan and the inspection personnel’s verification reports and provide feedback to the employee.

4. Review feedback from previous IPPS assessments to determine whether there are follow-up issues to cover during the visit. When a follow-up is required, supervisors are to make sure that the employee has completed the remedial assigned activities prescribed at the time of the prior IPPS assessment. Supervisors are to also reassess the elements and sub-elements on which follow-up was indicated.

5. Identify new Agency directives and notices that are relevant to the employee’s assignment and position. In addition, supervisors are to use the IPPS assessment as an opportunity to ensure that the employee has followed the instructions in the new directive or notice, as required, including ensuring that any required Memoranda of Interview are in place for required awareness meetings with establishment management, and that there is adherence to any verification procedures or other instructions provided in the issuance.

6. Ensure that employees have successfully completed required training (examples: on-the-job training or formal training courses). Training reports are available through AgLearn at http://www.aglearn.usda.gov/. District office personnel can provide supervisors with training reports and information upon request.

D. When completing the IPPS Assessment Form, a supervisor is to document very briefly how she/he prepared for the IPPS visit, including information on the data sources that he/she used.

X. METHODS FOR CONDUCTING AN IPPS ASSESSMENT

A. In general, supervisors are to use the following methods singularly or in combination when conducting IPPS assessments:

1. Observe the employee performing verification tasks;
2. Review documentation, reports, and correspondence in the government files;
3. Observe plant conditions and compare them to inspection results and noncompliance records on file; and
4. Ask questions about inspection methods, regulatory decision making, documentation, and enforcement procedures (e.g., types of regulatory control actions that can be taken and when; due process) to the Agency employee as he/she performs inspection verification activities. Provide hypothetical situations or scenarios to get the employee to describe what she/he would do in response to the situation.

B. Supervisors are to properly plan, prepare, and execute the plan to document an effective IPPS assessment.

NOTE: A supervisor does not have to conduct IPPS visits at all establishments on an employee’s assignment. However, the supervisor is to ensure that the employee can demonstrate an understanding of the methodology relevant to the whole assignment and an ability to execute it.

C. When conducting an IPPS assessment, a supervisor is to verify that the employee is:

1. Applying the appropriate inspection methodology, such as observing establishment employees conducting procedures, reviewing establishment records, and performing tasks;
2. Utilizing effective decision making to determine whether there is noncompliance;
3. Documenting their findings appropriately, if required;
4. Implementing enforcement actions properly (e.g., verification plans for suspensions and Notices of Intended Enforcement (NOIEs)), when authorized to do so; and
5. Implementing regulatory control actions.

D. The supervisors is to meet with the employee at the end of the assessment and provide verbal feedback on performance.

E. The supervisors is to complete the IPPS Assessment Form. The supervisor is to state whether the employee’s understanding and ability to execute regulatory requirements was satisfactory using Yes or No. A supervisor can document positive performance briefly in the narrative boxes. If the supervisor finds that performance of a sub-element is unsatisfactory, he/she is to clearly describe the deficiencies observed and discussed in documentation that is within the character limit allotted for the narrative boxes (2000 characters).

F. The supervisor is to provide a copy of the assessment to the employee within 2 weeks of the assessment, by either printing a hard copy for the employee or emailing a PDF copy.

G. When applicable, a supervisor’s findings are to also include recommended actions that the employee is to take to improve her/his knowledge and execution of inspection methods (e.g., review relevant directives, review Inspection Methods training module) and a timeframe for completing the action.

H. The supervisor is to follow the directions outlined in DR-4040-430, Performance Management, when an employee’s performance is unacceptable in one or more critical elements at any time during the performance appraisal cycle.

I. The supervisor is to contact the appropriate district office for further guidance if misconduct issues are identified during the IPPS visit.

J. The supervisor is to monitor follow-up items to ensure that they are accomplished.

K. The supervisor is to follow up on any sub-elements for which performance was found to be unsatisfactory during the next IPPS assessment.

XI. IPPS ASSESSMENT FORM AND MAINTENANCE

A. A supervisor can download the fillable PDF IPPS Assessment Form or the Word format IPPS Assessment Form (see example in Attachment 2) via InsideFSIS at: OFO Resources (Level 2 eAuthentication is needed to access this page).

B. This Directive will be revised and reissued with new instructions once new storing and tracking methods for the IPPS are implemented.

NOTE: IPPS Assessment Forms are not filed in the Human Resource Operation’s official personnel folder or the employee’s performance file.

XII. QUESTIONS Refer questions on conducting IPPS assessments to the appropriate District Office.

See full PDF for Attachments

• POSITIONS COVERED BY IPPS
• IPPS ASSESSMENT FORM
• DATA SOURCES FOR IPPS PREPARATION