SUMMARY OF YOUR COMMENTS TO THE UNIFORM GUIDELINES ON EMPLOYEE SELECTION PROCEDURES

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP89-01114R000300050010-8
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 10
• Document Creation Date: December 9, 2016
• Document Release Date: May 22, 2001
• Sequence Number: 10
• Publication Date: January 30, 1980
• Content Type: MF

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EEO- 80-390
30 January 1980
Deputy Director for Administration
Deputy Director for Operations
Director, National Foreign Assessment Center
Deputy Director for Science and Technology
Director, Equal Employment Opportunity
Comptroller
airman, Unitorm Guidelines Task Force
SUBJECT Summary of your Comments to the Uniform
Guidelines on Employee Selection Procedures
1. Your comments on the Uniform Guidelines on Employee
Selection Procedures Implementation Plan have been reviewed and
each recommendation summarized in the, attached for your study.
Attachment:
As stated
cc: Director PPPM
Inspector General
Chairman, "E" Career Service
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j R E C O M M E N D A T I O N S
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DDA
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DDS$T
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NFAC
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COMPT
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-DJPPPM
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airman
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"E" Car Ser.
A=Agree
D=Disagree
X-Comment
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Summary of Uniform Guidelines on Employee Selection Procedures
This summary does not contain the views of
the DDO and NFAC, whose comments were received
after the summary was compiled
Recommendation 1, - ? ; , ;
-------.DDA:--- Publishing- a Headquarters Notic
o t~;
in +t,;
.
n
yvi gunnel are to nave guidelines to follow 'pending publica-
tion of the regulation. In addition to the notice, I would
also suggest that an orientation for managers and personnel
officers be given to more thoroughly explain the background
and the new procedures.
progra:m .and
procedures is -a necessity
.the resnon_> Lble:=
Comptroller: While we have no problem with the idea of
an Agency notice on the subject, the draft proposed by the
task force needs to be rewritten to make it more succinct
and to the point. It should be a simple announcement of the
existence of the guidelines and of Agency policy to comply
with Federal requirements prohibiting discriminatory employ-
ment practices.
Recommendation 2
D/EEO: Since ultimately all of the selection processes
of the Agency will be scrutinized, is it possible that
recommendation two could be extended to all Agency emplo-
yees. The sex and ethnic identification of employees will
be necessary to ascertain adverse impact in areas other than
hiring including for example, promotion, training, employee
development.
Comptroller: The self-identification sheet seems
innocuous enough, and we see no problem with including it as
a part of the application package. We note that since
completion of the form would be voluntary, race information
for statistical purposes would be imprecise. However, this
might not be a concern since the proposed procedure would
limit the definition of an applicant to those who complete
the form along with other pertinent application papers.
DDS&T: A question which might be raised is how to
treat statistically those applicants who choose not to
complete the self-identification sheet. If significant
numbers choose not to complete the form, they would probably
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be carried asI"other", thus seriously eroding the utility
of the statistical data. Additionally, if the completed
form accompanies the applicant's folder to the selecting
components, the potential is that this will prejudice selection
decisions in the same way that in the past race and sex
information, along with photographs, were deemed potentially
prejudicial. I think it makes most sense for OPPPM to
remove the form before circulating the files for indications
11
---Recommendation 3_.
DDS?,T: Some lack of clarity exists with the definition
of "applicant" proposed by the Task Force. In many cases
the PHS and self-identification sheet will be insufficient
to determine if the individual meets the entrance-on-duty
qualifications. It appears then that such an individual
should not be considered an applicant until he/she. has been
interviewed.
D/EEO: I consider it vital that Recommendation Three
and Recommendation Fourteen be combined in a single recommenda-
tion. My strong concern is that steps may be taken to
ensure the lack of adverse impact in the selection of
"applicants," as defined in your recommendation three, I am
equally concerned that adverse impact not occur during
selection as it occurs prior to the applicant's designation,
as "applicant." For that reason, I also recommend that the
penultimate line of your current recommendation fourteen be
revised to read: "...to detect imbalance in the "pre-applicant"
screening process."
Recommendation 4
D/EEO: I recommend that Recommendation Four be reworded
to state: "The Office of Personnel collect applicant and
pre-applicant data (i.e., race, sex, etc. information) for
all clericals, and forward monthly to the Office of EEO."
Recommendation
DDA: This states that statistical records for professional
applicants will be maintained by each component and forwarded
to a directorate focal point for consolidation. This
procedure will result in 'double counting" since applicant
files are frequently reviewed by more than one office.
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Accordingly, you could have 15 applicants with 53 rejects,
thus.distorting and making invalid any type of 'statistical
data. In lieu of this procedure, I recommend that each
office reviewing a file complete a form, such as shown in
Tab J, and return it to SPD/Professional Staffing Branch.
(PSB). After the file has been reviewed by all interested
components, PSB would review the individual forms and make a
master form indicating results:of review andireasons for
eject _?`(if _appropriate.-)-.-._ - This-way, each. app .icant woul&F__be
-counted only once
Another advantage to this system would be a time-sa.ving
factor for personnel officers at the office levels and the
directorate levels. While your report states that the
record-keeping will be a simple task requiring little time,
I believe this to be an optimistic statement, particularly
for the large offices such as Communications and for the
directorate level where ten or more reports would have to be
consolidated.
Recommendation 8
DDS&T: With the understanding that some applicants are
disqualified by OMS and OS and a percentage will withdraw
their applications, the proposed flow data can reflect
unfairly on office of directorate selections. To compensate
for this situation, a fourth line might be added, on the
Uniform Selection Procedures Summary Report, to each occupational
series for reporting drop-outs which occur after processing
begins.
D/EEO: Recommendation Nine should be reworded to state
that the Office of Personnel collect data by race, sex, etc.
on all applicants rejected for medical and security reasons
and provide results monthly to the Office of EEO."
Recommendation 10
DDS&T: Clarification is needed because all employees
at a grade level are "considered" for promotion at the same
time. Some of those "considered" are recent EOD's, those
recently promoted, those at the top of their grade scale, or
those comparatively ranked too low to progress to higher
levels. It should be clearly stated whether information is
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required on all personnel in a given grade and job category
or only those recommended for promotion.
Recommendation 11
Comptroller: The proposed summary reports--for new
hires and promotions--will generate lots of paper. not, to
mention the time-.required to ; maintain- and tabulate the data.
Would it not be poss-ib1 e to--maintain-- the record.- -at least on-
a-pplicants/new hires-- centrally in 0/PPPM?_ ,And. is it--necessary
--to record data by occupational series? What= about the
applicant not placed in process but considered for two or
more positions in different occupational series or in
different offices? Statistical data in such cases would be
distorted and could lead to erroneous conclusions, particularly
in applying the "4/5th's" or "80 percent" rule.
DDSEiT: If OEEO and OPPPM review the applicant flow
data quarterly, this reporting frequency appears to be quite
adequate for directorate reviews as well.
Recommendation 12
Comptroller: See comments for Recommendation 11.
Recommendation :L3
D/PPPM: We agree with Recommendation 13 provided that
this Office determines the specific functional relationship
between the MEC and the Screening Panel.
Recommendation 14
D/EEO: See comments for Recommendation 3.
Recommendation 1.5
D/EEO: I recommend that Recommendation Fifteen be
reworded in accord with the following edited version: The
Director of Equal Employment Opportunity be responsible for
the application of the 80% rule and the determination of
adverse impact in the total selection process and for informing
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The Uniform Guidelines, though impacting heavily on
personnel selection procedures, remain essentially a Baedeker
for Equal Employment Opportunity. In the view of the Task
Force, therefore, the Director, EEO is the Agency officer
who is responsible for determining adverse impact, proposing
resolution, and ensuring Agency compliance with the Uniform
Guidelines.,. This responsibility does not,_however, attenuate
the responsibility of the Director of Personnel;for the
collection- and -monitoring -of personnel dat ;4 rather-,- the--
Agency as requiring the Director of EEO and ihe.Director of
Personnel to work closely in a cooperative effort to identify'
adverse impact and remedy its causes.
Recommendation :16
DDS&T: An office should be given an opportunity to
correct its procedures before a full-scale investigation
begins. This could be done by notifying an office that
adverse impact is perceived and giving that office a specified
number of days to provide a solution to the problem.
D/EEO: I recommend that Recommendation Sixteen be
revised to read., "if adverse impact exists, the Director EEO
may, at his discretion, appoint an EEO Specialist to conduct
an evaluation of the total selection process for the job
category concerned." I further recommend that the second
paragraph of text following Recommendaton Sixteen be. dropped.
Recommendation :17
DDA: The form proposed (Tab J) to indicate the reasons
for rejection does not provide for instances where the
rejection is based on the reviewer's intuitive judgment or
results of the personal interview. The interview is a
valuable hiring tool where such factors as oral communica-
tion, ability to think on one's feet, personal appearance
and motivation may be demonstrated. There is nowhere on. the
current form that a weakness in one of these areas could. be
appropriately explained.
To correct this omission in the form, I suggest that-,
in addition to the items now stated, more space be provided
to encourage the officer to expand on the reasons for rejection
with a specific section allotted for "interview results."
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Recommendation 18
DDA: My choice is Alternative 18
DDS$T: I support Alternative Recommendation 18
D/EEO: I strongly urge the acceptance.of Recommendations
Eighteen and Nineteen. Concurrently, I strongly urge the
--rejection -of Alternative Recommendations E :glhteen and Nineteen
-as` well as Nineteen A.
I disagree with the concepts exemplified in the alternative
recommendations, and I feel obliged to point out the basis
for that conflict. If the Office of EEO and the Director of
.EEO are the base of Agency expertise in equity and the
determination of adverse impact, then that expertise and
resultant judgements should be as accepted as is the judgement
of the Office of Medical Services in medical matters, the
Office of Security in security matters, the Office of Personnel
in personnel matters, and the Office of General Counsel in
legal matters. Even if that were not the case, the "high-
level management review" allegedly provided by the "Board"
proposed in Alternative Recommendation Nineeteen is not what
it is purported to be. The membership of the Board does not
consist of management, it consists of representatives of
those components outside of the chain of command. Secondly,
except for personal knowledge the only expertise in the
matter of adverse impact on the Board would rest in the
General Counsel. Thirdly, the presence on the Board of the
Director of Personnel, who is responsible for the operation
of major elements of the selection process suggests a conflict
of interest.
Use of the phrase "promotes objectivity" as applied to
the Board, suggests the presence of a fundamental lack of
objectivity in the Office of EEO and in the position of
Director EEO. Why would there be less objectivity in the
Director of EEO and the Office of EEO than in other non-line
decision-making or enforcement components such as the
Office of Security or the Office of Inspector General. With
regard to Alernative Recommendation Nineteen A, the structure
of this recommendation guarantees ineffectiveness by its
design. As stated, lack of agreement with regard to adverse
impact could only be presented for decision to the DDCI
by agreement "of the Director EEO and the Head of the Directorate
concerned."
Alternative Recommendation 18
D/EEO: Strongly urge rejection of Alternative Recommendation
18. See comments for Recommendation 18.
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D/PPPM; For the reasons accompanying them in the
Report we strongly urge the adoption of Alternative Recommendation
18, 19, and 19A and the parallel alternative page 4 of the
draft notice at Tab F. We believe that informal discussions
will contribute to the resolution of most cases of real
adverse impact. Where such resolution does not result,'the._.
Review Board is a reasonable means to dealithdifficu:lt
DDA: My choice is-Alternative Recommendation 18.
DDSFT: I support Alternative Recommendation 18. See
comments for Recommendation 18.
Recommendation 19
D/EEO Strongly urge rejection of Alternative Recommendation
19. See comments for Recommendation 18.
DDA: My choice is Alternative Recommendation 19.
D/PPPM: Strongly urge adoption of Alternative Recom-
mendation 19.
DDS&T: "The Executive Committee will review such
appeals. The EC will be supported by the D/OPPPM and the
C/PSS serving as non-voting advisors."
It is important to involve senior line mangers in this
process. It is far better to have the deputies advising the
DDCI on a matter so important to their operations (rather
than the IG, and GC, and the Comptroller). Further, this
avoids creating another board.
Alternative Recommendation 19
DDA: My choice is Alternative Recommendation 19
D/PPPM: Strongly urge adoption of Alternative Recom-
mendation 19
Alternative Recommendation 19A
D/PPPM: Strongly urge adoption of Alternative Recom-
mendation 19A.
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or the completion of these recommendation ]if approved.
Recommendation 21
D/EEO: I strongly recommend that a deadline, perhaps
of December 1980, be placed on the Directors of Personnel
and Equal Employment Opportunity and,the.Director of..Training.
#' S
D/EEO: See comments for Recommendation 21
Recommendation 22
Recommendation 25
D/PPPM: With regard to Recommendation 25 we would
emphasize the term: time-phased". Job analysis as required
by the Uniform Guidelines is not something that can be done
either instantly or once-and-for-all. Planning for a continuous
program emphasizing priority of positions will be required.
DDStT: While the goal of this recommendation is laudable,
serious resource implications are apparent. It is difficult
to foresee this kind of activity being completed in the near
term given the difficulties PMCD encounters doing the current
three-year review.
Recommendation 28
DDS$T: I recommend that the DDA be given this responsibility
instead of the General Counsel.
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