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)

                   United States
                   General Accounting Office
                   Washington, D.C. 20548

                   General Government Division

                   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
                                                                  .“. ,”_..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)
                   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
                             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

                            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

                          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

                          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.

                          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
                          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
                     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
                     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

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~


                       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
    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
    In our opinion, the grade 14 level is inconsistent with the level of
    responsibility assignedto Commerce’stop accounting position. It is also

    Page 11                              GAO/GGD-9041CommerceJob claesiflcations

-       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
        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

                   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-
                   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

Pleasecontact me on 276-6074if you or your staff have any questions
concerning the report. Other major contributors are listed in appendix
Sincerely yours,

Bernard L. Ungar
Director, Federal Human Resource

Page 14                             GAO/GGNO-41 CommerceJob Claseificationa

    Page 15   GAO/GGD9O-41CommerceJob Classiflcationa


Appendix II                                                                                    19
Comments From the

Abpendix III                                                                                   20
C&unents From the
Office of Personnel
Appendix IV                                                                                    21
Major Contributors to
This Report


                        OFFA      Office of Finance and Federal Assistance
                        OPM       Office of PersonnelManagement
                        Wt.3      Senior Executive Service

                        Page 16                             GAO/GGD90-41CommerceJob Claasifkatiom




: 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
                                  Deputy Assistant
                                   Secretary for

                                 Office of Finance
                                    and Federal

                   Financial                        Accounting

                  Management                       Systems and
                    Division                      Review Division

                               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
                   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
                   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.

                                                 Assistan; Secretary
                                                 . for Administration

                           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.

                                                                           Constance Berry         wman

                            Page 20                                          GAO/GGD-SO-41
                                                                                         CommerceJob Cla~~sificationa
       +j   l

   /    IV

MBor Contributors to This &port

                        Thomas A. Eickmeyer, Assistant Director, Federal Human Resource
General Government        ManagementIssues
Diyvision,Washington,   Anthony Assia, Assignment Manager
                        Don D. Allison, Evaluator-in-Charge


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