STUDY OF OVERTIME DONATION POLICY

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP83M00914R000800010011-5
• Release Decision: RIPPUB
• Original Classification: S
• Document Page Count: 3
• Document Creation Date: December 20, 2016
• Document Release Date: November 20, 2007
• Sequence Number: 11
• Publication Date: October 1, 1985
• Content Type: REPORT

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Position Management and Compensation Division (PMCD) of the Office of
1 rsonnel has noted a recent upward trend in requests for exception to the
regulation requiring that the first eight hours of overtime per week worked by
FLSA-exempt GS-12 through GS-15 employees be donated by the employee. This
has raised the question as to the validity of this policy.
1. So far as we can tell fran our records, the policy of donating overtime
was effected in June 1959 and was applied to employees in grades GS-11 and
above. The policy apparently evolved fran a managerial perception of abuse of
overtime by employees who routinely stayed late and/or worked on weekends and
who claimed overtime, and to instill an ethic of professionalism at those
grade levels. There is no indication that a concern for cost was a
consideration, although there obviously would be some money savings with such
a policy.
2. Periodically since 1959, and as recently as 1980 by the Executive
Committee, this policy has been reviewed, reconsidered, and studied. The
grade level was moved up to GS-12 in 1972. Throughout the years, 0GC has
expressed the opinion that the Agency policy is legal but can provide no
assurance that the Agency would win a court case.
1. In an effort to determine if there is now any need for a change in this
policy, we have considered the following information:
a. Requests for exception to this policy are increasing, according to
PMCD's records, as follows:
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c. Because there is no requirement that donated overtime be recorded
on employee time and attendance records, there is no way to
determine accurately how many employees are actually donating
eight hours per week; nor, equally, the total hours of donated
2. Based on the foregoing information, we find it difficult, if not
impossible, to determine whether this 23-year old policy deters abuse of
overtime; or whether it saves money; or whether it is a problem to any but a
very small number of employees (those for whom exceptions have been
granted).
3. A historical review, both from: the senior management and O(3C
perspectives, suggests that this policy has become very much
institutionalized, and that although managers may want authority on their own
to grant exceptions to the policy, there is no general desire to abandon the
policy.
4. It has been suggested that raising the grade cut-off to GS-13 might
5. However, in a time of salary constraints (i.e., lower pay increases,
higher rates of pay for high-technology employees in the private sector,
etc.), paying overtime to a broader base of employees may be viewed as a
positive morale factor. It also might signal a level of concern by management
6. This issue was reviewed by the Personnel Management Advisory Board
(PMAB) on 18 October 1982 with a view towards determining the need for a
policy change. Following an exchange of comments and suggestions, the
consensus was that management-directed overtime should be paid regardless of
the grade of the employee. There remains a serious concern about the
potential for abuse, however, especially if employees interpret a liberalized
policy as an open door for payment of hours worked merely for their own
convenience or style; and especially if managers and supervisors treat this
matter casually, relying on low-graded time and attendance clerks to maintain
to employees caught in an inflationary market.
the integrity of the system.
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D. RECCKMENDATION
It is recanmended that:
All Agency employees in grades GS-12 through GS-15 be paid
overtime;
Overtime be paid only when management directs that such work is
necessary and must be performed; and
? The overtime work is performed outside of the normally scheduled
workday.
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