United States General Accounting Office Washington, D.C. 20548 General Government Division B-236439 January 18,199O The Honorable David Pryor Chairman, Subcommitteeon Federal Services, Post Office, and Civil Service Committee on Governmental Affairs United States Senate Dear Mr. Chairman: This report respondsto your request for GAO to determine whether job classifications were proper for three managerial positions within the Comi%&e Department’s Office of Finance and Federal Assistance (OFFA). The positions are the Dire&x, OFF-A;the Director, Office of Finan- cial Management;and the Chief, Financial ManagementDivision, Gov- ernment positions are placed in occupational groupings, and in 1984 and 1986 the CommerceDepartment’placed the three Positions in the @min- istrative and clerical ,gro@ng. Each replaced a position that had been in the Accounting and Budget Group. “, .. ~, Your concernswere prompted by ““. allegations .. .”.._ ..,., . you received of improper personnel practices concerning the.reclassification of ..,...the .“. ,”_..l^l”.~._.,,l “,.._three .” posi- ..“., tions. It was alleged that (1) the positions were incorrectly classified, at least in part, to place unqualifiecl personsin accounting positions and (2) I,.”.,,., the top accounting position at the departmental level was, by virtue of the misclassifications, relegated to too low a level relative to the impor- tance of the accounting functions. After reading Commerce’sclassification documents,we asked the Office Redults in Brief of Personnel Management’s(OPM) Office of Classification, which devel- ops the government’s classification standards, to provide an advisory opinion as to whether the three positions were properly classified. OPM concluded that the most appropriate classification for the position of Director, Office of Financial Management,was in the Accounting and Budget Group. The position of Chief, Financial ManagementDivision, according to OPM, appeared to fit into this category as well, but certain information about the position had to be clarified before a decision could be made, In response,Commerce,in July 1989, revised the description of both positions and, saying it had originally misinterpreted the classification guidelines, reclassified them in the Accounting and Budget Group. Although we were unable to verify the reason’for the misclassification Page 1 GAO/GGD-BO-41 Commerce Job Claesiflcatlons of these two positions, we agreethat the positions as now described by Commercemeet the classification standard. The third position, the OFFA director’s position, is a Senior Executive Ser- vice @Es) -_1-.-*a” position. Although OPM felt that classification in the Account- ing and Budget Group was preferable, OPM acceptedCommerce’s classification of the OFTA director’s position on the basis of authority agencieshave in classifying SESpositions. We agree with OPM'S basis for accepting the classification. We are concernedthat Commerce,when filling the OFFA director’s posi- tion in 1984 and again in 1986, may have yislated merit system princi- ,-ples:r.egardingfair and open.competition. The possibility of such a violation is suggestedby the nature and timing of certain personnel actions taken in filling the position that appear to have given an employee an unfair ~promotion .. adv.antage.Providing this advantage is : also a prohibited practice under federal personnel laws. We are sending information about actions Commercetook to fill the position to the Office of the Special Counsel for its consideration; this independent office investigates allegations of prohibited personnel practices. ‘There are specific job series within occupational groupings. In July 1989, when Commerceredescribed and reclassified the position of Direc- tor, Office of Financial Management,it placed the position in the Finan- cial Administration and Program Seriesin the Accounting and Budget Group. In redescribing this position, Commerceremoved responsibility for technical supervision over accounting matters and assignedit to a lower level-grade 14-managerial position in the Accounting Series. Our overall goal is to improve the government’s financial management operations. OFFA provides technical supervision over Commerce’sseven accounting systems that control over $2 billion annually. Therefore, we believe supervision of the Department’s accounting function should be atKhIgher managerial level. WeV&o.belie,vethis manager should pos- sessthe qualifications necessaryto provide the required technical supervision. In response,Commercesaid it is establishing a new chief financial officer position, and, by the end of March 1990, expected to work out the organizational issuesassociatedwith the position. Background When a new position is proposed or when the duties and responsibilities of an existing position are changed,the position, according to federal Page2 GAO/GGPgo-41cOmmerceJobClaesiflccLtions ( personnel law, mustbe classified or reclassified. The classification pro- cessprovides a position with several critical elements:occupational series;job title; pay category (or pay plan); and, within the category, pay level or grade. Before a position can be classified, a position description must be writ- ten. This document describesthe actual tasks, duties, and responsibili- ties of the position and the relationship of that position to other positions. Using the position description, a classifier evaluates the duties and responsibilities of the position against applicable Position Classification Standards, which are developed and issued by OPM. The comparison is made against each standard’s classification factors in areas such as knowledge required by the position, scopeand effect of the work, and supervision received and provided. On the basis of this evaluation and comparison, the classifier makes a judgment about the most appropriate job series,title, pay plan, and grade for the position. The job series is a specific occupation within a group or family of occu- pations with broad similarities. The CommerceDepartment’s personnel office placed the three OFFA positions in the “300” occupational group, which is titled “General Administrative, Clerical and Office Services Group.” Within this group, the OFFA director’s position was classified in the 301 series (“Miscellaneous Administration and Program Series”), and the two other positions were classified in the 346 series (“Program Analysis Series”). Accounting positions are in the 600 group (“Account- ing and Budget Group”), specifically the 6 10 “Accounting Series.” Objjectives,Scope,and Our objectives were to determine whether M&hodology l the positions of Director, OFFA; Director, Office of Financial Management; and Chief, Financial ManagementDivision were properly classified; and . there was any basis for allegations received by the Subcommittee (1) that the reclassifications were done, at least in part, to place unqualified persons in accounting positions and (2) that the top accounting position at the departmental level was, by virtue of the misclassifications, rele- gated to too low a level relative to the importance of the accounting functions. To carry out these objectives, we obtained position classification and other documents from the CommerceDepartment’s Office of Personnel Page 3 GAO/GGD-SO-41 Cknmerce Job CladflcatSoxw c and Civil Rights and the Office of Inspector General. We reviewed descriptions of OFFA'S organizational alignment and history, forms show- ing personnel assignmentsto the positions, and personnel records show- ing the education and work experiencesof position holders. We also reviewed federal personnel laws and regulations and OPM guidance on position classification and related matters. We interviewed Commerce’sAssistant Secretary for Administration and officials of the personnel office and OFFA to obtain information about the history and classification of the three positions and duties of those who hold the positions. We also obtained a list of the job series for financial managementpositions in the Washington, D.C. offices of sevenother Commerceorganizations. OPM's Office of Classification assistedus in determining the propriety of the classifications. This office develops classification standards for governmentwide application and advises government agencieson classi- fication matters. Our work was done in Washington, D.C.,intermittently between Febru- ary 1989 and September 1989, in accordancewith generally accepted government auditing standards. We received written commentson a draft of this report from the CommerceDepartment and OPM (see app. II and III) and oral comments from the Office of the Special Counsel(seep. 13). OFFA'S responsibilities include providing the CommerceDepartment with OFFA and History of Positions - l administrative and operational policies and procedures on financial assistanceprograms, including grants, cooperative agreements,loans, and loan guarantees; l policies and managementservicesfor financial and accounting matters, including review and approval of accounting systems; l travel managementpolicies and procedures; . managementof the Working Capital Fund and other resources;and l administrative payments servicesto Department clients. OFFA is under the Assistant Secretary for Administration. The Office of Y Financial Management,which includes the Financial ManagementDivi- sion, is one of five organizations within OFTA. (Seeapp. I for OFFA'S cur- rent organization.) Page4 GAO/GGD-gO-41CommerceJobClesslficatione The hree Positions Two of the three positions-Director, OFFA, and Director, Office of Financial Management(originally Chief, Financial ManagementDivi- sion)-were established the sameyear in which OFFA was formed, 1984. The third position-Chief, Financial ManagementDivision (originally Chief, Financial ManagementBranch)-was established in 1986. Each was placed in the 301 or 346 series when established, and each replaced a position that had been in the 610 Accounting Series.According to their 1984 or 1986 position descriptions, each retained responsibility for Com- merce Department accounting functions, Each position, when established, was filled with a nonaccountant. Two of the three current incumbents were original office holders. The posi- tion of OFFA director has been held by the sameperson since 1984. The current Director of the Office of Financial Managementwas Chief of the Financial ManagementBranch when it was established in 1986. Although the original office holder of the position of Chief, Financial ManagementDivision (now Office of Financial Management)left Com- merce in 1986, and personnel records were no longer available, a state- ment by her former supervisor indicates that she was not an accountant. OF%J’sAdvisory Becausethe 301 and 346 series were used even though position descrip- tions showed responsibility for accounting functions, ,weasked OPM'S O@nion Office of Classification if the job series for each position was proper. As a basis for its review, we gave the Office of Classification the position and organizational- classification-documents we received from Com- merce’s personnel office. The classification office gave its written opin- ion on June 2,1989. For the position of Director, OFFA, OPM'S classification officials said there is often “no perfect” answer in assigning a job series for a management position at this level-the SE% The series,the officials said, dependson what the organization needsat the time and the expertise required to managethe organization. And, while the 606 Financial Management Seriesor the 610 Accounting Seriesmay be preferable, the 301 classifi- cation was acceptablegiven the authority agencieshave in classifying sEspositions. For the position of Director, Office of Financial Management,OPM offi- cials said the most appropriate series would be the 610 Accounting Seriesrather than the 346 Program Analysis Seriesbeing used. This opinion was basedon the position’s duties, which require supervision over three accountants, and a Commerceevaluation statement, which Page5 GAO/GGD9o-41cOmme~Jobclaesificstlolllr . emphasizedthe technical expertise and responsibilities of the position over the purely supervisory responsibilities. For the position of Chief, Financial ManagementDivision, conflicting information clouded OPM’S advisory opinion. OPM officials said the duties described in the position description clearly placed the position in the 610 Accounting Series.OF'FAorganization material, however, showed the position supervising six nonaccountants.This discrepancy, the OPM offi- cials said, should be explained. We gave Commerce’spersonnel office a copy of OPM'S opinion and asked Cbmmerce’sResponse it to (1) provide any additional information it believed would alter the t# the OPM Opinion opinion and, if none, (2) provide information on actions it intended to take to correct the classifications. The office changedthe descriptions of the positions of Director, Office of Financial Management,and Chief, Financial ManagementDivision, and, on July 20, 1989, reclassified the two positions. It said the positions had been misclassified becauseit had misinterpreted classification guidelines. Regarding the position of Director, Office of Financial Management, Commerce’spersonnel officials said the position belongs in neither the 346 nor the 610 series, They said the position requires managerial expertise rather than a technical knowledge of accounting systems and, as such, the position description was inaccurate and would be revised to eliminate technical supervision over systems accounting work. They placed the position in the Financial Administration and Program Series, GS-601.This series includes work for which no other, more narrowly defined series within the Accounting and Budget Group is appropriate. Regarding the position of Chief, Financial ManagementDivision, Com- merce’s personnel officials said the position no longer was responsible for systems accounting-series 610-functions, and the position description would be rewritten accordingly. They placed the position in the 601 series becauseof program responsibilities for cash and debt management. According to Commercepersonnel officials, the professional accounting expertise within OFFA rests with the Chief, Accounting Systems and Review Division. The division chief is an accountant who reports to the Director, Office of Financial Management. Page 6 GAO/GGD9041 CommerceJob Cladfications After reviewing Commerce’sresponseand the two revised position descriptions, an OPM official said the 601 classification was acceptable for the two positions, He did not judge whether Commerce’sreassign- ment of the accounting responsibilities was proper; he said agenciesare responsible for organizing work in a manner that they, rather than OPM, seeas best meeting their needs. We agreewith OPM that the current descriptions of the two positions fit the 601 classification. We also agreewith OPM'S basis for accepting the 301 classification for the Director, OFFA, position. Beyond what we asked OPM to determine, we have several concernsresulting from Commerce’s actions in classifying and filling the OtiA positions. One concern involves the reason for the misclassifications; a secondinvolves a possible merit system principle violation in filling the OFFA director’s position; and the last concern involves the placement of OFF'A'Saccounting responsibilities. Commerceofficials said misclassifications were due to its staff’s misin- Urklear Why terpretation of OPM'S classification guidelines. We are unclear as to how M&classifications the misclassifications may have occurred given the significant differ- Odcurred encesin OPM'S definitions of the 300 and 600 groups and the clarity of OPM'S guidance in this classification area. However, becauseall records concerning the three positions were not available-the records retention period had expired-and becauseavailable records were incomplete, we could not conclusively determine the reasonsfor the misclassifications. Nevertheless,becauseof the differences in definition and the clarity of OPM'S guidance, we still do not understand how misinterpretations could have occurred. OPM'S guidance says differences between diverse occupational groups are relatively simple to make. We believe that OPM's definitions of the 300 and 600 groups make them diverse. OPM defines the 300 occupa- tional group to include jobs which are of “. . . a general clerical and administrative nature.” In clear contrast, the 600 group includes jobs which are of “. . . an accounting, budget administration, related financial management,or similar nature.” OPM'S guidance also addressesspecific job series (e.g., 601,610) to be used after the occupational group has been established. Accounting was the only professional work in the two positions when they were estab- lished and, as such, would appear to have determined the position series,which would be 610. OPM establishesqualification requirements for all occupations to ensure successfulperformance. For “professional” Page 7 GAO/GGIMO-41CommerceJob ClassiIlcations - occupations such as accounting, OPM has established minimum qualifica- tion requirements. Under the federal classification system, as long as performance or technical supervision of “professional” work is required, the professional qualification requirements generally deter- mine the series classification of the position. Still another factor raises a question about the explanation. Each of the misclassified positions replaced one which had previously been classi- fied in the 610 Accounting Seriesand, although other functions were added or deleted as a result of various reorganizations, accounting responsibilities were retained. This, together with OPM'S guidance, would clearly make the 600 group the only appropriate occupational category in which to place the positions. This is true as well for the position of Director, OFFA, when it was estab- lished in 1984. It was a GM-16 position then, rather than today’s SES- level position. Like today however, the position was placed in the 301 series.Among the position’s duties was the oversight of the design and modification of Commerce’saccounting systems to insure that they embody generally acceptedaccounting principles and standards. We gave the 1984 position description to OPM'S Office of Classification and asked if the 301 series was appropriate. An OPM classification official said the position should have been classified in the 610 Accounting Series. Possible Merit System Allegations were made to the Subcommitteethat Commerce’sreclassifi- cations were done, at least in part, to place unqualified individuals in Vjolation accounting positions. Merit system principles (6’U.S.C.Section ~2301(&)(-I-))require federal career positions to be filled on the basis of open and fair competition. It is a prohibited personnel practice (6 USC. Section 2302(b)(6)) to “grant any preference or advantage not autho- rized by law . . . including defining the scopeor manner of competition or the requirements for any position . . .” to give an advantage to a par- ticular individual. Commercetook a series of actions to reclassify and fill at least one of the positions, the directorship of OFFA, which, when taken together, appear to have resulted in an advantage being given to one employee for Y promotion. The sequenceand nature of these actions raise concerns about the reason for the reclassification and the merits of the selection process.A summary of those actions and our analysis follows. Page 8 GAO/GGIHO-41CommerceJob Classifications April 1,1984: The Director, Office of Federal Assistance,GM-1101(Gen- era1Businessand Industry Series)-16,was detailed to the position of Director for Finance, Executive Service (ES)-610series.The detail, we believe, was improper. OPM'S qualification standards require that a per- son detailed to a position be qualified for it. OPM requires persons appointed to accounting positions to have a collegedegreein accounting, or a degreethat includes at least 24 semesterhours of accounting, or the equivalent in education and experience.According to her employment application, which she submitted for the OFFA director’s position, the Director had neither an accounting degreenor the equivalent education and experience.OPM'S requirement has been in effect since before 1984. August 12, 1984: The detail was terminated, and the Director returned to the Office of Federal Assistance. August 15/16, 1984: OFFA and the position of Director, OFFA, GM-301-16 were established. This new position consolidated the departmental accounting and financial managementresponsibilities of the former position of Director for Finance-an SESposition-and the functions of the Office of Federal Assistance.The new position retained responsibil- ity for supervising another unit headed by a GM-16.None of the docu- ments we received from Commerceto describe and support the reclassifications explain why the job serieswas not kept in the 610 series or why the position was not put into the SW.This latter action is puzzling because(1) the new position retained most of the significant responsibilities of the abolished SESposition (Director for Finance) and (2) the holder of the position would be responsible for supervising a subordinate who would also be a grade 16. It seemsunusual to us to reorganize and end up with a director’s position that is graded no higher than a unit being supervised. Of the six program directors who reported to the Assistant Secretary for Administration in 1984, only the OFFA director was not an SESmember. September 2, 1984: The Director, Office of Federal Assistance,was later- ally reassignedto the position of Director, OFFA. October 16, 1986: A position description for Director, OFTA, was approved upgrading it to the SESlevel. The functions of the executive position, which was placed in the 301 series,were the sameas the grade 16 position. April 28, 1986: The SESposition of Director, OFFA, was advertised. Page 9 GAO/GGD-90-41CommerceJob Cla8~ificatio~ I/ : * B-225428 - December7,1986: The Director, OFFA, GM-301-16,was promoted to the senior executive position of Director, OFFA, ES-301.According to Com- merce personnel officials, records showing how Commerceconsidered applicants’ qualifications were no longer available; the retention period had expired. As a grade 16, the employee would not have been eligible to move later- ally into an sESposition. If the position of OFFA director had been placed into the 610 Accounting Series,the employee would not have qualified for it. Therefore, by making the original OFFA director’s position a grade 16 position and by classifying the new position into a nonaccounting series,Commercewas able to noncompetitively reassignthis employee to it. While in the grade 16 position, this employee, by virtue of the experiencegained in the position and the similarity of the two jobs, appeared to have gained a competitive advantage for promotion to the executive level position. Such an advantage, which federal personnel law prohibits, would have prevented or significantly restricted fair and open competition. Regarding the actions surrounding the OFFA director’s position, we are unable to make a conclusive determination as to whether Commercevio- lated federal personnel laws. Such a determination would have required an investigation that is more appropriate for the Office of the Special Counsel.This independent office investigates allegations of prohibited personnel practices and requests that the Merit SystemsProtection Board take corrective or disciplinary action as appropriate. Accordingly, we are referring our findings on the filling of the OFFA director’s position to the Office of the Special Counsel for its consideration. Stipervision Over The last allegation we addressedconcerns“position management.” According to the allegation, Commerceis too large and too complex to Abcounting Should Be have as its highest ranking accountant someoneat the grade 14 level. at a Higher Level The allegation was premised on Commerce’suse of the 301 and 346 job series for OFF'Amanagementpositions. The allegation implies that OFFA’S accounting responsibilities are too technical and significant to have nonaccountants in charge. Commerce has reclassified the two 346 series positions since the Subcommittee received the allegation. However, the top 610 accounting position at OFFA, which is to provide accounting policies to all of Commerce’sorga- nizational units and to review and approve Commerce’saccounting sys- tems, remains at the grade 14 level. Page 10 GAO/GGD-ml CommerceJob Ch&f¶cations ‘, ; According to Commerceand the July 1989 reclassifications, supervision of the technical aspectsof the accounting function is not with the posi- tion of Director, OFFA, or the position of Director, Office of Financial Management,a grade 16 position. Rather, it is with the next lower orga- nizational level, the Chief of the Accounting Systems and Review Divi- sion, a grade 14 position. In making this organizational change,Commerce,in our view, inappro- priately deemphasizedthe importance of technical supervision over accounting matters. From a governmentwide perspective, we have been stressing the need for the government to make a major effort to rebuild its financial managementstructure.’ This is becausethe government’s financial managementsystems too often are antiquated and do not pro- vide neededinternal controls or the information required for effective management,program, funding, and revenue-generating decisionmaking. A vital element of the financial managementstructure in any agency is its accounting systems and the technical competenceof the personnel charged with managing them. Commercehas seven accounting systems, and these systems must be designedand operated in a manner to account for and control Commerce’sannual budget of over $2 billion. Neither the Director, OFFA, nor the Director, Office of Financial Manage- ment, possessthe necessaryqualifications to provide technical supervi- sion over the Department’s accounting systems. The grade 14 position at OFTA overseesthe technical aspectsof the seven accounting systems. According to the design of the federal classification system, a position should be graded in a manner that is consistent with the level of responsibility assignedto it and in a manner that would reflect the level of technical knowledge, skills, and abilities necessaryto carry out that responsibility. In addition, generally acceptedposition managementprinciples suggestthat the position should be graded con- sistently with the supervisory level afforded accounting in subordinate components. In our opinion, the grade 14 level is inconsistent with the level of responsibility assignedto Commerce’stop accounting position. It is also Y Page 11 GAO/GGD-9041CommerceJob claesiflcations . B-236439 - inconsistent with the supervisory level afforded accounting in other Commercecomponents,componentsthat look to OFFA for accounting pol- icy and systems oversight. For example, the head of the Financial Man- agementDivision in the National Oceanicand Atmospheric Administration is a grade 16 accountant (610 series) as is the head of the Finance Division in the Bureau of the Census. While Commercedid misclassify certain positions and placed persons into those positions who did not have the accounting qualifications neededto do the work contained in the position descriptions, the issue of whether Commercemisclassified the positions to enable it to fill them with unqualified persons is more complicated. Becauseof insufficient documentation, we could not conclusively determine whether Com- merce’s actions constituted merit system violations or prohibited per- sonnel practices. However, evidencethat is available in connection with Commerce’sreclassification and filling of the OFFA director’s position indicates that merit system violations and prohibited personnel prac- tices may have occurred. Taken together, the inappropriate detail, reclassifications, lateral reassignment, and position upgrade appear to have given an employee an advantage for promotion and could have prevented open and fair competition for the SESposition that this person filled. The appearanceor fact of providing an employee with an unfair advantage undermines the credibility of Commerce’smerit selection program. Regardlessof whether Commercecommitted merit system violations or prohibited personnel practices in reclassifying or filling the positions in question, we believe that supervision of the technical aspectsof accounting is sufficiently important to require placement at a higher grade level than what resulted from the reclassifications. We believe this becauseof our overall goal of improving the government’s financial managementsystems and becausethe person in the position must pro- vide technical supervision over the CommerceDepartment’s seven accounting systems that control over $2 billion annually. Given this level of responsibility, we do not believe it is unreasonableto expect that the position be at the SESlevel. We also believe that filling the posi- tion should be on the basis of the candidate’s demonstrated ability in accounting, budget execution, financial and managementanalysis, and Y systems development. Therefore, in keeping with OFFA'S level of accounting responsibility within the CommerceDepartment, we believe the current organizational placement of technical supervision over accounting should be reevaluated. Page12 GAO/GGD-9041Commerce Job Classifications We recommendthat the Secretary assign responsibility for technical Recommendationto supervision over the Department’s accounting function to a higher- the Secretary of graded position. In assigningthis responsibility, we urge the Secretary Ccmmerce to consider placing the position at the SESlevel and to specify require- ments for the position that include the knowledge, skills, and abilities necessaryto provide competent technical supervision over accounting matters. 1 Commerceagreed with our recommendation. In a letter dated December A$ency Comments 16,1989, the Assistant Secretary for Administration said that the Department is establishing a new chief financial officer position and, by the end of March 1990, expected to work out the organizational issues associatedwith the new position. The Assistant Secretary also agreed that the lack of documentation prevented a conclusive determination of merit system violations. Appendix II contains the full text of Com- merce’scomments. OPM comments addressedthe classification issuesfor which the Office of Classification provided assistance.In a letter dated December18, 1989, the Director of OPM indicated that the report accurately reflected the classification advice they provided. Appendix III contains the full text of o&s comments. The Office of the Special Counselprovided oral comments on December 6, 1989. Regarding the possible prohibited personnel practice, the Dep- uty Associate Special Counselfor Prosecution said that from the facts contained in the report the matter meets the Office’s threshold criteria for investigation, and the Office would undertake such an investigation when the referral is made. As agreed with the Subcommittee,unless you publicly announceits con- tents earlier, we plan no further distribution of this report until 30 days from the date of this letter. At that time, we will send copiesto the Sec- retary of Commerce;the Director, OPM; the Special Counsel,Office of the Special Counsel; and to others upon request. Page 13 GAO/GGD-90-41CommerceJob Classifications 02854a9 Pleasecontact me on 276-6074if you or your staff have any questions concerning the report. Other major contributors are listed in appendix IV. Sincerely yours, Bernard L. Ungar Director, Federal Human Resource ManagementIssues Page 14 GAO/GGNO-41 CommerceJob Claseificationa l Page 15 GAO/GGD9O-41CommerceJob Classiflcationa 1 18 Appendix II 19 Comments From the of Abpendix III 20 C&unents From the Office of Personnel Management Appendix IV 21 Major Contributors to This Report Abbreviations OFFA Office of Finance and Federal Assistance OPM Office of PersonnelManagement Wt.3 Senior Executive Service Page 16 GAO/GGD90-41CommerceJob Claasifkatiom 4 - II - 1 I I : I Page 17 GAO/GGIMO-41CommerceJob Classiflcatione i/ A$pendix I drganization of the Office of F’inmce and ” Assistance (Effective May 12,1987) Assistant Secretary for Administration Deputy Assistant Secretary for Administration Office of Finance and Federal Assistance I Financial Accounting 7 Management Systems and Division Review Division I Page 18 GAO/GGD9O-41CommerceJob Classifl~tions Ap$endix II From the Department of Commerce UNITED STATES DEPARTMENT OF COMMERCE The Asaietant Secretary for Administration Washmgton. D.C. 20230 Mr. John MI Ols, Jr. Director, Housing and Community Development Issues U.S. General Accounting Office Washington, D.C. 2054% Dear Mr. 01s: Thank you for your letter and draft of a proposed report regarding the reclassification of certain managerial positions at the Commerce Department. In response to your recommendation , we have decided to establish a new chief financial officer position. The organizational iseues associated with that decision have not been completely worked out yet, but we expect to complete the process within 90 days. We agree that there is not sufficient documentation to support a conclusive determination of merit system violations. The lack of documentation ie made even more difficult by the fact that key officials associated with the case are no longer employed by the Department. I appreciate your report and the constructive suggestion regarding the accounting program. We will provide you with copies of the new position description and organization order when completed. Sincerely, bake Assistan; Secretary . for Administration Y Page 19 GAO/GGD-90-41CommerceJob Classincatione Appendix III Canments From the Office of 4ersonnel Management UNITED l4TATR8 / OFFICE OF PERSONNEL MANAOEMCNT WA8NINOTOl’f. D.C. 10416 ofT,ce OP THE DlHECTOH DECI 8 1989 Mr. Richard L. Fogel Assistant Comptroller General U. S. General Accounting Office 441 G Street, NW Washington, DC 20548 Dear Mr. Fogel: Thank you for the opportunity to comment on your draft report entitled, Federal Employees: Reclassification of Certain Managerial Positions at the Commerce Department. The report accurately reflects OPM's role in advising you on the classification questions presented, and I am happy to have been of assistance. Sincerely, c!4AJd~~ Constance Berry wman Director Page 20 GAO/GGD-SO-41 CommerceJob Cla~~sificationa T +j l &p+ndix / IV MBor Contributors to This &port I Thomas A. Eickmeyer, Assistant Director, Federal Human Resource General Government ManagementIssues Diyvision,Washington, Anthony Assia, Assignment Manager Don D. Allison, Evaluator-in-Charge DC. b (966377) Page 21
Federal Employees: Commerce Department's Reclassification of Three Managerial Positions
Published by the Government Accountability Office on 1990-01-18.
Below is a raw (and likely hideous) rendition of the original report. (PDF)