ISSUE PAPER ON OPM'S PROPOSED CLASSIFICATION AND QUALIFICATION STANDARDS FOR THE CONTRACT AND PROCUREMENT SERIES (GS 1102)

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP85B00552R000100050008-3
• Release Decision: RIFPUB
• Original Classification: K
• Document Page Count: 30
• Document Creation Date: December 20, 2016
• Document Release Date: July 6, 2007
• Sequence Number: 8
• Publication Date: December 2, 1982
• Content Type: REPORT

EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
OFFICE OF FEDERAL PROCUREMENT POLICY
WASHINGTON. D.C. 20503
FEDERAL ACQUISITION
INSTITUTE
ISSUE PAPER ON OPM'S PROPOSED
CLASSIFICATION AND QUALIFICATION STANDARDS
FOR THE CONTRACT AND PROCUREMENT SERIES (GS 1102)
PROBLEMS
1. The new standards that the Office of Personnel Management (OPM) plans to
issue will not meet agency needs for high quality, competent procurement work
force. This is contrar to the intent of Executive Order 12352 and will challenge
the credibility of T e rest ent's Order.
Executive Order 12352 requires OPM, "in consultation with the heads of
agencies," to "ensure that personnel policies and classification standards
meet the needs of executive agencies for a professional procurement work
force." The major procuring agencies have repeatedly informed OPM that the
standards will not meet their needs.
2. The proposed standards will diminish the Government's ability to establish or
maintain a fully competent procurement work force.
The proposed standards do not accurately describe the responsibilities or skill
and knowledge requirements of procurement positions. Further, the
standards do not accurately represent the complexity of the procurement
function or its impact on agency missions. As a result, agencies will have
difficulty attracting, recruiting, and retaining high quality personnel.
3. The standards will inflate the costs and impair the timely procurement of
goods and services essential to agency mission needs.
The personnel affected by the standards are responsible for the judicious
expenditure of $135 billion (FY 81) annually. Their business decisions can
mean the difference between fair and reasonably priced contracts which
protect the Government's interests and contracts which encourage inflated
prices, waste, unsatisfactory performance, and claims.
4. The standards will undermine the Administration's program for Federal
procurement reform, as embodied in Executive Order 12352 and Reform 88.
Executive Order 12352 and Reform 88 require numerous reforms in Federal
procurement with anticipated cost avoidance of approximately $5 billion
annually when fully implemented. These goals cannot be realized without
competent procurement personnel.
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BACKGROUND
o During 1979 and 1980, an interagency team of procurement and
personnel managers developed prototype standards. OPM was represented on
the team and helped plan, develop, and edit the prototype.
o In the spring of 1981, OPM terminated its working relationship with the
interagency team and rewrote the prototype. The agencies were not
consulted.
o OPM issued a first draft in July, 1981, which the agencies rejected as
unworkable. OPM issued a second draft in August, 1982, which the agencies
again rejected, noting that none of the major problems had been resolved
while new problems were introduced.
o On November 9, 1982, the Director of OPM's Standards Development
Center reported his plans to recommend that OPM issue the standards
without significant modification, notwithstanding the critical changes
requested by agencies, industry, and Congressmen in over 2,000 pages of
comments. At the meeting of November 9, the 24 agencies present were
unanimous in their judgment that the standards will not meet their needs.
o The following are typical of comments submitted to OPM on the draft
standards.
Mr. Carlucci (DOD): "Our personnel and acquisition representatives are
in general agreement that the standards do not meet DOD's needs to
ensure a professional procurement work force."
Mr. Kline (GSA): "We strongly recommend that you defer their issuance
until a full and complete review and analysis can be accomplished."
Ms. Beebe (Treasury): The standards would "preclude fair and equitable
evaluation of many procurement positions . . :'
Mr. Beggs (NASA): The standards "do not meet the objectives of sound
position management and will adversely affect the quality of the
procurement work force."
Mr. Sopper (HHS): "The proposed standards as written pose serious
concerns to us particularly as we move to implement E.O. 12352 and
improve the professionalism of our procurement work force."
Mr. Robinson (President, National Security Industrial Association): "We
have reviewed the draft standards and are very concerned that the
professionalism required in the procurement career field has not been
sufficiently recognized."
Senators Roth, Danforth, Pryor, Cohen and Chiles: The standards fail
"to acknowledge the caliber of individuals required to function in
today's complex government contracting system."
o In summary, the standards do not meet the agencies' needs. The
agencies are asking OPM to revise the standards to accurately represent
procurement functions and the related skill and knowledge requirements.
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OPTIONS FOR DEVELOPING REALISTIC STANDARDS AND COMPLYING WITH
SECTION 3 OF EXECUTIVE ORDER 12352
1. Assemble an OPM/interagency team of procurement and personnel
managers to rewrite standards satisfactory to agency heads, prior to OPM's
approval and issuance.
2. Assemble an interagency team to develop a unified body of recommen-
ded changes satisfactory to agency heads, for incorporation by OPM in the
standards.
RECOMMENDATION: OPTION 1--Assemble an OPM/interagency team of procure-
ment and personnel managers to rewrite standards satisfactory to agency heads,
prior to OPM's approval and issuance.
o Would best ensure that the standards accurately reflect the procure-
ment process, procurement functions, and the requirements of procurement
positions.
o Would include OPM in the special Government-wide, interagency effort
to reform the Federal procurement system, as required by Executive Order
12352.
o Is consistent with OPM's published guidance, which calls for the
intimate involvement of occupation managers in standards development.
o Is consistent with Title 5 of the United States Code, which empowers
OPM to issue standards but does not prescribe a process for developing
standards or preclude joint development by personnel and procurement
managers.
o Assure the Government attracts and retains personnel who can
competently serve as its business managers for procurement.
o Validly and accurately represent procurement work and the require-
ments of procurement positions.
o Assure fair and consistent grading by classifiers.
o Require applicants for trainee positions to demonstrate their potential
to learn procurement as a condition for selection.
o Require employees to demonstrate their mastery of the procurement
body of knowledge as one of the conditions for selection or promotion to
critical procurement positions.
o Assure a stable grade structure--statistics show no grade creep in GS
1102 series over last decade (Tab 1--see next page).
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GRADE STRUCTURE OF CONTRACT/PROCUREMENT SERIES
Average
Grade
GS-13's
GS-14's
GS-15's
GS-1102
Year Work Force
No.
%1102's
No.
%1102's
No.
%1102's
1969
10.66
2417
13.0
940
5.1
378
2.0
1970
10.77
2371
13.5
936
5.3
359
2.1
1971*
1972
10.76
2311
14.1
923
5.7
326
2.0
1973
10.75
2201
13.8
917
5.8
323
2.0
1974
10.67
2194
13.4
917
5.6
340
2.1
1975
10.73
2250
13.3
937
5.5
357
2.1
1976
10.81
2213
13.0
944
5.6
350
2.1
1977
10.71
2306
13.0
990
5.6
369
2.1
1978
10.70
2313
12.5
1010
5.5
375
2.0
1979
10.71
2326
12.2
1031
5.4
375
2.0
1980
10.70
2471
12.4
1087
5.5
367
1.8
*Not Reported
Summary
o Average Grade of GS-1102 work force: 10.66 in 1969; 10.70 in 1980
o GS-13's (as % of total GS 1102 work force): 13.0% in 1969; 12.4% in 1980
o GS-14's (as % of total GS 1102 work force): 5.1% in 1969; 5.5% in 1980
o GS-15's (as % of total GS 1102 work force): 2.0% in 1969; 1.8% in 1980
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PLAN
o Select the OPM/interagency team.
o Analyze agency comments.
o Redraft the standards.
o Submit redrafted standards to agency heads to determine that the
standards satisfactorily reflect their requirements.
o Report periodically to the Director, Office of Management and Budget,
on progress.
NOT RECOMMENDED: OPTION 2. This option is also acceptable but does not
provide for OPM participation in rewriting the standards.
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PROBLEM I
The new standards that the Office of Personnel Management (OPM) plans to issue
will not meet agency needs for high quality, competent procurement
work force. This is contrary to the intent of Executive Order 12352 and will
challenge the credibility of the President's Order. The major procuring agencies
have repeatedly informed OPM that the standards will not meet their needs.
A. AGENCY COMMENTS (Tab 2)
B. INDUSTRY COMMENTS (Tab 3)
C. COMMENTS BY MEMBERS OF CONGRESS (Tab 4)
D. COMMENTS BY PROFESSIONAL ASSOCIATIONS AND COLLEGES (Tab 5)
 PROBLEM II
The proposed standards will diminish the Government's ability to establish or
maintain a fully competent procurement work force.
A. CLASSIFICATION AND QUALIFICATION STANDARDS ESTABLISH
CRITERIA FOR DETERMINING GRADES AND SELECTING EMPLOYEES FOR
FEDERAL POSITIONS
Tab 6: Purpose and description of classification and qualification standards
B. CLASSIFICATION STANDARD DEFICIENCIES
Tab 7: Inaccurate description of procurement process; inaccurate
application of the standards to the process
Tab 8: Inconsistent with Primary standard
Tab 9: Applies criteria from Primary standard that are not realistic
Tab 10: Internally inconsistent
Tab 11: Inconsistent with standards for other occupations
Tab 12: Factor level description (FLD) 1-9 excluded; 1-9 criteria in FLD 1-8
Tab 13: Insufficient titles to identify specializations
Tab 14: Inconsistent and inequitable grading of procurement positions
B. QUALIFICATION STANDARD DEFICIENCIES
Tab 15: Clerical experience, rather than demonstrated potential, qualifies
for trainee positions
Tab 16: Does not require employees to learn the professional body of
knowledge as a condition for selection or promotion
Tab 17: Industry, on the other hand, seeks out the most competent
professionals and believes government should do the same
 PROBLEM III
The standards will inflate the costs and impair the timely procurement of goods
and services essential to agency mission needs.
A. ONCE THE GOVERNMENT HAS DECIDED TO CONTRACT FOR THE
PERFORMANCE OF CERTAIN WORK, PROCUREMENT PERSONNEL-AS
AGENTS OF THE FEDERAL GOVERNMENT-ARE RESPONSIBLE AND
ACCOUNTABLE FOR THE CONDUCT OF THAT WORK.
o Prices paid to contractors
o Costs associated with system maintenance and operation
o Cost resulting from claims, protests and litigation
o Quality of the goods and services acquired
o Cost of delays in obtaining needed goods and services
o Cost of terminating contracts
o Cost to detect and correct mistakes
o Cost of waste, fraud and abuse
o Number of procurement personnel required
o Cost to industry of doing business with the Government
o Volume and detail of the regulations required
C. EVERY DOLLAR SAVED BY REDUCING WORK FORCE QUALITY WILL BE
LOST MANY TIMES OVER THROUGH LOWER QUALITY BUSINESS DECISIONS.
THIS IS A CONCERN OF:
o The Congress (Tab 18)
o The Boards of Contract Appeals (Tab 19)
o The agencies (Tab 20)
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PROBLEM IV
The standards will undermine the Administration's programs for Federal
procurement reform, as embodied in Executive Order 12352 and Reform 88.
Accomplishing the procurement reforms in Executive Order 12352 and the procure-
ment goals of Reform 88 depends upon competent and professional people who can
recognize problems and opportunities, exercise sound business judgment, and take
initiative. As excessive regulations are decreased, professionalism and competency
of the work force must increase.
A competent work force is the key to achieving the anticipated cost avoidance of
$5 billion from procurement reforms. Not only will the largest proportion of the
procurement cost savings be attributable to a competent and professional work
force, but none of the remaining features of the procurement system to accomplish
the reforms of Executive Order 12352 can be fully achieved without such a work
force. The Proposal for a Uniform Federal Procurement System, which the
Administration submitted to the Congress in February 1982, listed the following
principal features of the System and the percentage of savings that each of these
features would contribute.
CONTRIBUTION
SYSTEM OBJECTIVES TO COST SAVINGS
Professional Work Force 22%
Simplification 20%
Commercialization 15%
Improved Competition 14%
System Standards 10%
Uniform Policy 10%
Integrated Management System 9%
TOTAL 100%
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AGENCY COMMENTS
- The following agency representatives submitted comments calling for significant
changes in the standards to meet agency needs for a high quality work force.
o Mr. Frank Carlucci, DOD (4 letters)
o Mr. Ray Kline, GSA (2 letters)
o Ms. Cora P. Beebe, Treasury
o Mr. Dale W. Sopper and Mr. Thomas S. McFee, HHS
o Mr. Donald B. Rock, Federal Aviation Administration, Transportation
o Ms. M. Moncada, Federal Highway Administration, Transportation
o Mr. William S. Heffelfinger, Energy
o Mr. Carl E. Grant and Mr. S. 3. Evans, NASA
o Mr. John P. Horton, EPA
o Mr. Thomas 3. O'Connor, HUD
o Mr. William R. Reise, Labor
o Mr. Thomas Ubois, NSF
o Mr. 3. R. Scully, Army
o Mr. Everett Pyatt, Navy
o Mr. 3. Craig Cumbey and Mr. James E. Williams, Jr., AF
o Vice Admiral E. A. Grinstead, DLA
o General Robert T. Marsh, AF
o Mr. Ira L. Kemp, Headquarters, AF
o Mr. Frank Gearde, Jr., Agriculture
o Mr. Allen W. Smith, Agriculture
o Mr. Clyde C. Cook, VA (2 letters)
o Mr. William C. Clohan, Jr., Education
o Mr. Hilary Rauch, Energy
o Mr. George E. Dausman, Army
o Mr. William B. Ferguson, GSA
o Ms. Charlotte Brooks Spann, Interior
o Mr. J. H. Flaherty, Navy
The following are excerpts from agency comments.
- Excerpt from Mr. Frank Carlucci's letter of October 6, 1982.
"The net effect of the proposed standards is a downgrading of the
stature of the procurement work force which is incompatible with the DOD
Acquisition Initiatives, the proposed Federal Procurement System,
Executive Order 12352, and congressional direction. If implemented, DOD's
ability to carry out its acquisition mission in an effective, efficient, and
professional manner will be seriously impacted. I can assure you that the
acquisition process and the competence of the acquisition work force are
issues that have my personal attention."
- Excerpt from Mr. Ray Kline's letter of September 30, 1982.
"Executive Order 12352 requires that OPM work with the executive
agencies to ensure that classification and qualification standards meet their
needs for a professional procurement work force. OPM does not appear to
grasp the serious nature of this requirement. Recognizing that procurement
professionals are the government's business managers, the President is
determined to create an environment for proper maintenance and
professional growth of the work force."
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- Excerpt from Mr. William S. Heffelfinger's letter of October 5, 1982.
"The Department of Energy (DOE) has reviewed the proposed final
occupational standards for the Contract and Procurement Series, GS-1102.
The standards as currently drafted are unacceptable to this Department in
several important areas."
- Excerpt from the letter by Mr. Carl E. Grant and Mr. S. 3. Evans of September
30, 1982.
"We consider the proposed qualification standard for the GS-1102
series to be unacceptable in that it contains inaccuracies, many serious
deficiencies, and poses numerous problems for all affected personnel. The
standard does not meet the needs of the agency and would not offer a
positive inducement to the development of a professional procurement work
force. Our detailed comments and recommendations are in enclosure 2."
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INDUSTRY COMMENTS
- The following firms and industry associations submitted comments which strongly
support the goal of strengthening work force professionalism and revising the
standards to meet that goal.
o National Security Industrial Association
o American Bar Association
o Crowell and Moring
o Witte and Leste, P.C.
o Hughes Aircraft
o United Technologies
o Norris-NI Industries
o Boeing
o McDonnell Douglas
o McDermott, Inc.
o Hazeltine Corporation
o Emerson (Electronics and Space Division)
o American Defense Preparedness Association
o ILC Data Device Corporation
o Electronic Industries Association*
o Newport News Shipbuilding*
o ANADAC*
o Allis-Chalmers*
o GTE Service Corporation*
o National Council of Technical Service Industries*
o American Institute of Certified Public Accountants*
- Excerpts from the letter by Wallace Robinson, Jr., President, National Security
Industrial Association.
"We have reviewed the draft standards and are very concerned that the
professionalism required in the procurement career field has not been sufficiently
recognized.
* * * *
"This would seriously reduce the ability of the government to attract and
retain high caliber federal employees in the procurement career field.
Additionally, it might result in industry personnel dealing with lower level, less
knowledgeable and less experienced personnel on complex matters for which these
government personnel are inadequately prepared.
* * * *
"We in industry seek out the most competent professionals to handle these
responsibilities and we believe the government should do the same." (emphasis
added)
*These letters were submitted on the Administration's Proposal for a Uniform
Federal Procurement System.
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COMMENTS BY MEMBERS OF CONGRESS
o Senator William V. Roth, 3r.
o Senator John C. Danforth
o Senator William S. Cohen
o Senator Lawton Chiles
o Senator David Pryor
o Representative Jack Brooks
o Representative Samuel S. Stratton
o Representative Stan Parris
o Representative Michael D. Barnes
- Excerpts from the joint letter to OPM of October 20, 1982 by Senators Roth,
Cohen, Danforth, Chiles and Pryor.
"We have reviewed the final Classification and Qualification standards for
the Contract and Procurement series, GS-1102, and have found that our previous
concerns with the proposed standards have not been addressed.
w r r r
"A fundamental concern which we emphasized in our previous letters . . . is
the failure of the proposed standards to acknowledge the caliber of individuals
required to function in today's complex government contracting system.
Procurement has developed into a specialized profession which demands a high
level of knowledge, skill, and judgment. Rather than improve the job standard to
coincide with the development of the profession, however, the final standards
underestimate the level of knowledge and expertise required for quality
procurement decisions."
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COMMENTS BY PROFESSIONAL ASSOCIATIONS AND COLLEGES
- The following professional associations and colleges submitted comments which
strongly support the goal of strengthening work force professionalism and the
development of standards which meet that goal.
o National Conference of Boards of Contract Appeals Members
o National Institute of Governmental Purchasing
o National Contract Management Association (letters from
individual members of the Board of Governors)
o National Association of Educational Buyers
o American Assembly of Collegiate Schools of Business
o George Washington University, School of Government and Business
Administration (Washington, D.C.)
o Arizona State, College of Public Programs (Tempe, Arizona)
o Ohio State University, School of Public Administration (Columbus,
Ohio)
o Austin Community College (Austin, Texas)
o St. Joseph University, College of Business Administration
(Philadelphia, Pennsylvania)
o Weber State College (Ogden, Utah)
- Excerpts from Resolution E on OPM Classification and Qualification Standards,
adopted by the National Institute of Governmental Purchasing at its 1981 National
Convention.
"Therefore be it resolved that the National Institute of Governmental
Purchasing fully supports the efforts of the U.S. Office of Federal Procurement
Policy to revise the proposed standards in light of current and enlightened
procurement practices."
- Excerpt from the letter of November 10, 1981 by Hubbert L. O'Brien, National
President, National Contract Management Association
The standards "do not appear to appreciate the need for professional stature
for people responsible for contracting activities in the Federal Government.
. . . such a view is not consistent with the findings of the Commission on
Government Procurement and others such as the General Accounting Office. It is
also counter to our perception of the needs of the public contracting process...."
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PURPOSE AND DESCRIPTION OF CLASSIFICATION AND QUALIFICATION STANDARDS
A. THE FACTOR EVALUATION SYSTEM OF CLASSIFICATION
Since 1975, standards have been prepared under a factor-point approach called the
Factor Evaluation System (FES), a quantitative job evaluation method. Positions
are evaluated in terms of nine factors under this system.
FACTOR
POINTS
1.
Knowledge required by the position
50-1850
2.
Supervisory controls
25-650
3.
Guidelines
25-650
4.
Complexity
25-450
5.
Scope and effect
25-450
6.
Personal contacts
10-110
7.
Purpose of contacts
20-220
8.
Physical demands
5-50
9.
Work environment
5-50
Every factor is divided into as many as nine levels, and every level has a unique
point value. For instance, Factor 1-Knowledge Required by the Position-has nine
levels. Level 1-1 is worth just 50 points; level 1-9 is worth 1,850. Factor Level 6,
by comparison, has four levels. Level 6-1 is worth 10 points. Level 6-4 is worth
110. When classifying a position, the classifier determines the appropriate level
within each of the nine factors and records the point value for that level. Points
from the nine factors are totalled; the total points are equated to a grade by means
of a conversion table.
5
7
9
11
12
13
14
15
855-1100
1355-1600
1855-2100
2355-2750
2755-3150
3155-3600
3605-4050
4055-4480
The Primary Standard defines every level of the nine factors in terms broad enough
to apply to all General Schedule (GS) occupations. It also assigns the point value
for each level. (Note: classifiers are not permitted to split the difference between
two levels. A position either requires level 1-8 or level 1-9 knowledge--there is no
level 1-8l4). The Primary Standard is often referred to as the "standard for
standards," since the factor level descriptions in all standards derive, in theory,
from the factor level definitions in the Primary Standard.
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C. THE PROPOSED FINAL GS 1102 CLASSIFICATION STANDARD
Classifiers will use two different sections of the standard in grading individual
positions: Factor Level Descriptions (FLDs) and Benchmarks.
1. Factor level descriptions expand the Primary Standard's definitions for
each level in terms of procurement functions.
2. Benchmarks are sample position descriptions for typical positions,
which are used by classifiers in determining the grade levels for a
specific position.
D. GRADING INDIVIDUAL POSITIONS
Since Benchmarks are intended to represent typical positions, classifiers often
prefer to use them as the primary basis for grading positions. In other situations,
classifiers prefer to use the factor level descriptions in grading positions and make
no reference to benchmarks. The same grade should result from using benchmarks
or factor level descriptions, alone or in any combination.
This standard contains criteria for the recruitment of positions within a specific
occupational specialty. These qualifications would include a description of the
work performed, skill, knowledge, and education requirements, general and
specialized experience requirements, personal characteristics required, and a
rating or evaluation guide. This information enables the hiring office to determine
position requirements and recruit those personnel best suited for the position. Its
purpose is to ensure that personnel hired for trainee positions have the potential to
learn the occupation's work and that those individuals selected for higher grade
levels have the skill and knowledge required for competent performance.
 INACCURATE DESCRIPTION OF PROCUREMENT PROCESS;
INACCURATE PPLI ATION OF STANDARDS TO THE PROCESS
The treatment of "Two Step Formal Advertising" exemplifies the many Instances in
which the standards do not dearly describe important procurement concepts.
According to the "Principles of Government Contract Law" (a recognized textbook)
"Two step formal advertising is a hybrid mix of formal advertising and
negotiation. The purpose of it is to make more use of formal advertising in
technical contracts where existing specifications are so indefinite that negotia-
tion between prospective contractors and the government is required."
According to the pro sed GS-1102 classification standard (from a description of a
GS-7 trainee position
"The specialist procures supplies or services primarily through formal
advertising or two step formal advertising, or through limited use of negotiation
techniques. Negotiated transactions are usually developmental assignments
designed to increase the employee's skill and knowledge. Requirements involve
standard specifications and established markets."
PROBLEM: Two step formal advertising is far more complex than the work
normally performed at the GS-7 level. At present, this is normally
GS-I1 and higher work. The reference to standard specifications and
established markets is incompatible with two step advertising and
reflects a basic lack of understanding of this important procurement
concept. As a result, this language is likely to mislead classifiers
into underrating the skill and knowledge levels required for two step
advertising and the grade levels at which two step advertising is
properly performed.
 The following is one of the many inconsistencies between the proposed GS-1102
standards and the Primary Standard. In theory, all classification standards are
supposed to conform to the Primary Standard, a generic standard applying to all
occupations.
The Primary Standard, Level 5-6 of Factor 5 (Scope and Effect), states that:
"The work involves planning, developing and carrying out vital administrative or
scientific programs.
"The programs are essential to the missions of the agency or affect large
numbers of people on a long-term or continuing basis."
However, the proposed GS-1102 standard Benchmark 14-01 was only rated level 5-
5, even though its Scope and Effect parallel the Primary Standard 5-6:
"Work performed, decisions made, and solutions devised have major impact on
the agency mission. Some decisions, such as contract award or termination,
impact on substantial portions of the nation's commercial sector. Conse-
quently, the work affects the economic livelihood of specific sections of the
country, as well as large numbers of people."
The proposed GS-1102 Benchmark 14-01 also states that this employee:
"Serves as a contracting officer for a major system or program characterized
by: (1) very large funding levels and the commitment period over a long period
of time (five years or more); (2) the magnitude and terms of the contract
substantially impact on the well being of the corporation or subsidiary; and (3)
the agency head monitors progress due to criticality and visibility of the
program . . . The employee is delegated unlimited authority to plan and carry
out the contractual activities required ...."
PROBLEM: The Factor Level 5-5 described in Benchmark 14-01 clearly meets
the requirements of Factor Level 5-6 in the Primary Standard. The
grade of the Benchmark was inequitably lowered one level as a
result of this misapplication of the Primary Standard.
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APPLIES CRITERIA FROM THE PRIMARY STANDARD THAT ARE NOT
REALISTIC
The following is one of the criteria in the Primary Standard that are not realistic.
In describing the highest level contacts between Government and Industry, the
Primary Standard, Factor Level 6-4, states that:
"The personal contacts are with high ranking officials from outside the
employing agency at national or international levels in highly unstructured
settings (e.g., contacts are characterized by problems such as:... each party
may be very unclear as to the role and authority of the other....")
In the proposed GS-1102 standard, this criterion is faithfully replicated. For
instance, the GS-1102 standard Factor Level Description 6-4 states in part that:
"Personal contacts include high-ranking officials from outside the employing
agency in highly unstructured settings where the purpose of the contacts is
generally defined only in the broadest conceptual terms and where the role and
authority of the parties may be unclear initially."
PROBLEM: In fact, the most important, highest level contacts between
Government and Industry take place in meetings that:
(a) Have definite purposes, agenda and structure.
(b) Involve people who carefully investigate each other's roles,
responsibilities or issues in advance.
Because the Primary Standard misrepresents the characteristics of
the highest level contacts between Government and industry, it is
unlikely that any contract negotiator will have contacts at the 6-4
level. Thus, even though the negotiators are dealing with high level
corporate officials on extremely complex issues, these contacts will
not be considered by classifiers to be high level contacts.
 Another problem with the proposed GS-1102 standard is that its Factor Level
Descriptions in some instances do not agree with its Benchmarks in describing the
same grade determining criterion.
For example, Factor Level Description 7-4 of Factor 7 (Purpose of contacts)
states:
"Contacts are to justify, defend, negotiate, or settle matters involving
significant or controversial issues. Negotiations at this level involve major
procurements of considerable consequence and importance. The employee is
responsible for justifying and defending the agency position when the issues are
strongly contested because of their impact or breadth. Contract administration
or termination settlements at this level involve the resolution of very difficult
or complicated issues, such as settlement of contracts which have significant
adverse impact on the contractor's financial posture or allocation of
controversial corporate overhead expenses."
Compare this with the wording of Benchmark 13-02:
"Contacts are for the purpose of monitoring, evaluating, and resolving major
matters of contractor performance, management, and progress. To obtain a
fair and reasonable solution, the employee must justify and negotiate, often
under adversary conditions, major issues.
r * r ?
"The employee has contracting officer authority for contract administration
functions in a major contractor or Government facility. Contracts typically
extend over several years and cover research, development, testing, and
production of complex equipment systems or other complex programs, services
or construction.
"Assignments include delegated authority for planning, coordinating, and
administering long-term contracts for major systems or programs on which
significant accountability and management control are required.
"(The employee requires) knowledge of cost and pricing techniques to negotiate
and approve a variety of pricing and special agreements, including final
overhead rate agreements which have a major financial impact on a large
number of contractual actions. (The employee also) issues unilateral
determinations which, if appealed by the contractor, must be fully supported,
justified and defended before appeals boards or courts of law."
PROBLEM: Benchmark 13-02 reads like Factor Level Description 7-4 but is only
rated level 7-3. The proposed standard will result in variations in
the grade levels of positions depending on what part of the standard
the classifier applies. This conflicts with the principle behind the
Factor Evaluation System.
 INCONSISTENT WITH STANDARDS FOR OTHER OCCUPATIONS
One of the purposes of the Primary Standard is to insure that comparable work is
graded at the same level regardless of occupation. For that reason, it is essential
that the standards interpret the Primary Standard consistently. The following is
one of the many inconsistencies between the proposed GS-1102 standard and other
standards in their interpretation of the Primary Standard. _
Factor Level Description 1-9 from the Forestry (GS 460) Standard states that one
example of 1-9 level knowledge is:
"Knowledge of forestry sufficient to formulate policy and to provide leadership
and direction of a dynamic timber management program covering one or more
states and embracing a wide variety of administrative and technological
problems."
There is no Factor Level Description 1-9 in the proposed GS:
0,21102 standard.
Instead, the GS-1102 Factor Level Description FLD 1- includes t e following
words:
"Knowledge and skill sufficient to procure major systems or subsystems, e.g., . .
. the development and production of an attack aircraft with new and enhanced
weapon modes (e.g., air-to-air missiles or air-to-ground missiles), where little
or no contractual precedent exists to serve as guidance in developing or
modifying procurement strategies or pricing structures."
PROBLEM: While managing forestry programs probably requires significant
knowledge, we do not believe it requires more sophisticated know-
ledge than that required in procuring major weapons systems.
However, the wording of the GS-1102 1-8 means that the knowledge
required for major systems procurement will never be rated higher
than 1-8, even though the knowledge required for managing timber
programs is being rated 1-9. This is another illustration of the lack
of understanding of the procurement process that pervades the
proposed GS-1102 standards.
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FACTOR LEVEL DESCRIPTION 1-9 EXCLUDED;
1-9 CRITERIA WRITTEN INTO GS 1102 FACTOR LEVEL DESCRIPTION 1-8
- Excerpt from the letter of September 22, 1982 by J. Craig Cumbey, Deputy
Assistant Secretary of the Air Force for Civilian Personnel Polic and James E.
Williams, Jr., Deputy Assistant Secretary of the Air Force for Acquisition
Management,
"The lack of a Factor Level Description (FLD) 1-9 creates a fatal flaw. It is
recognized at both OPM and within the functional community that positions
exist which will require the use of FLD 1-9 to classify. Although the number of
such positions may be small in comparison to the overall size of the career
field, they are still significant and are due appropriate recognition. Further, we
consider FLD 1-8 as written to be subject to possible misinterpretation to cover
legitimate 1-9 situations."
The Primary Standard, Factor Level 1-8, requires:
"Mastery of a professional or administrative field to apply experimental
theories and new developments to problems not susceptible to treatment by
accepted methods."
The Primary Standard, Factor Level 1-9, requires:
"Mastery of a professional field to generate new hypotheses or theories; or
equivalent skills and knowledge"
The proposed GS-1102 standard, Factor Level Description 1-8, requires:
"Mastery of a functional area sufficient to extend contracting techniques and
develop innovative approaches for use by other contracting personnel in solving
a variety of procurement problems . . . Knowledge and skill sufficient to
procure major systems or subsystems . . . where little or no contractual
precedent exists to serve as guidance in developing or modifying procurement
strategies or pricing structures .. . Skill in developing new approaches or
contract provisions to solve unprecedented problems." (emphasis added)
PROBLEM: The standard strongly implies that highest level
knowledge required for the most critical procurement
position only rates a 1-8 while the highest level knowledge
required for comparable work in other occupations rates
1-9.
 PROBLEMS: 1. The standard will instruct classifiers to title all positions
"Contract Specialist," with three, optional, parenthetical
modifiers (Price Analysis, Negotiation, or Administration)
allowed. The standard will eliminate the Procurement Analyst
(staff), Procurement Officer, Procurement Agent, and
Termination Specialist titles. The agencies object to the use
of only one title, even with the parenthetical modifiers.
Applying the modifiers will be left to the option of the
classifiers and may be inconsistently applied.
2. Inconsistent application of the various job titles (specialties)
would significantly complicate the already complex tasks
associated with recruitment, career management, and
specialist training. The skills required at the advanced levels
in each specialization are diverse and specialized. For this
reason, it would be inappropriate to combine the
specializations under the single, general title "Contract
Specialist," even with three optional modifiers.
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INCONSISTENT AND INEQUITABLE GRADING OF PROCUREMENT POSITIONS
- Excerpts from the letter of December 16, 1981 by James M. Beggs to Dr. Devine.
"Your memorandum of October 1, 1981, emphasized the importance of position
classification accuracy and position management effectiveness. You stressed
line management accountability for position management and indicated that a
primary purpose of this effort is to ensure that employees who do substantially
equal work have the same grade and pay. I fully support that objective.
"Proper position classification, in turn, is highly dependent upon the use of
clear, thorough, objective standards.
"... in our judgment, (the proposed standards) fall fatally short of fulfilling
these purposes. Broadly viewed they appear to preclude procurement agencies
from tapping significant pools of available college talent, present a number of
troublesome inconsistencies and reflect an extremely over-simplified
understanding of procurement operations of the Federal Government.
"Based on our view, we believe both the tentative qualification and
classification standards for the GS-1102 series do not meet the objectives of
sound position management and will adversely affect the quality of the
procurement work force. Thus it appears to us that a major revision of these
standards is essential."
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- Excerpt from the letter of September 22, 1982 by 3. Craig Cumbey, Deputy
Assistant Secretary of the Air Force for Civilian Personnel Policy, and James E.
Williams, Jr., Deputy Assistant Secretary for Acquisition Management:
"The qualifications standard has virtually opened the door to all employees in
the federal service with one year's experience as a GS-4 with substantive
clerical or other experience. Although the proposed standard has better defined
"substantive" experience, the definition is not adequate to equate the exper-
iences that qualify with the requirements of earning an undergraduate degree.
Again, this is not at all in consonance with our requirements".
 DOES NOT REQUIRE EMPLOYEES TO LEARN THE PROFESSIONAL BODY OF
KNOWLEDGE AS A CONDITION FOR SELECTION OR PROMOTION
- Excerpt from the letter of October 5, 1982 by Mr. William S. Heffelfinger,
Department of Energy:
"We urge the adoption of a qualification requirement for the GS-1I level which
would entail the completion of a specific number of college level procurement
courses.
"This will give us the needed flexibility in recruitment while ensuring that only
properly trained individuals can advance to responsible positions in the procure-
ment profession."
 INDUSTRY SEEKS OUT COMPETENT PROFESSIONALS
From the statement of Walter O'Neil, Procurement Committee, National Security
Industrial Association before the Senate Subcommittee on Federal Expenditures,
Research and Rules (February 2,
"The Procurement Commission recognized that contracting personnel were
required to be knowledgeable in several disciplines in order to effectively
perform their duties and to satisfy the requirements of assigned responsibility.
Contracting officers must at least be conversant in cost and pricing analysis,
economic benefit analysis, financial management, the law and its ramifications,
technical considerations and ultimately as the team leader for the contracting
process. The contracting officer is the person who signs the contract and is
responsible for the consummation of all aspects of the contract. It is our
observation that the programs which enjoy the greatest success have a con-
tracting officer who is the most highly qualified.
"We consider our procurement personnel in industry to be nothing less than
professional. We require the necessary skills, education and abilities at the
entry level and promote and transfer on demonstrated ability. We urge the
government to recognize the required expertise levels and to act in a similar
fashion."
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IMPACT OF WORK FORCQUALITY
ON PROCUREMENT COSTS
- Excerpt from the letter by Senators Chiles and Danforth of November 9, 1981.
"We are firmly convinced that the ability of the procurement system to
function properly is dependent on the training and skill of the people who buy goods
on behalf of the government. Indeed, as we come to depend less and less on
regulations and government specifications to govern procurement decisions, it
becomes increasingly important that we be able to depend on the professionalism
and expertise of the government's procurement personnel. Wise procurement
decisions can save millions--even hundreds of millions of dollars. Poor decisions
can cost just as much. A commitment to upgrade the training of procurement
personnel is, in fact, the linchpin of the draft proposal for a new procurement
system recently submitted to the Congress by the Office of Federal Procurement
Policy." (emphasis added).
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IMPACT OF WORK FORCE QUALITY
ON PROCUREMENT COSTS
- Excerpts from the letter by Charles T. Duvall, President, National Conference of
Boards of Contract Appeals Members; Administrative Judge, Armed Services Board
of Contract Appeals.
"...the level of errors and omissions in contract documents, and judgmental
errors during contract administration, which often result in costly contractor
claims, are directly related to the degree of professionalism and expertise of
procurement personnel.
"Over 2,000 claims are currently pending before federal contract appeal
boards. A substantial number of these cases end in upward adjustments in contract
prices, either by settlement or board decision. In 1980, 40% of board decisions
sustained, in whole or part, contractor appeals; some upward price adjustments
reached six figures.
"We conclude that it is in the best financial interests of the government and
the taxpayers it serves to set higher rather than lower standards for recruitment
training and qualificatiop of procurement personnel, and urge you not to adopt
these lowered standards." emphasis added
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IMPACT OF WORK FORCE QUALITY
- Excerpt from the letter to OPM by Everett Pyatt, Principal Deputy Assistant
Secretary of the Navy (Shipbuilding and Logistics) of September 24, 1982.
"Finally, we are most concerned that the standards do not recognize that
contracting personnel are responsible for the business arrangements that
obligate the billions of dollars spent annually by the Department of the
Navy. We are anxious to assist you in ensuring that the subject standards
accurately reflect the knowledge and skills required to properly perform the
contracting function."