The challenge faced by EPA and other agencies in using such measures is that there is not always a clear link between specific human capital strategies and strategic programmatic outcomes. This is partly because there may be multiple causes of a specific outcome, only one of which is related to a targeted human capital strategy, and unforeseen circumstances that affect implementation of a strategy. Our recent testimony on human capital challenges at the SEC and key trade agencies illustrates the practical difficulties that agencies may encounter.[Footnote 30] We testified that during 2001, U.S. trade agencies increased staff levels to address insufficient monitoring and enforcement of trade agreements. However, we noted that measuring the effectiveness of this strategy might be difficult because the agencies' workloads in other areas continue to grow, which could cause them to shift resources intended for trade compliance to other program areas.[Footnote 31] If shifts in resources occur, the agencies may not be able to improve the effectiveness of trade compliance efforts, even though the human capital strategy initially succeeded in acquiring additional resources.
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