1. Delegation of Classification Authority (DCA)
Commander’s Briefing

2. Purpose
Enable the Commander to delegate and oversee classification processes
Publicize Army classification policies
Explain impact of Fair Labor Standards Act requirements

3. The Pendleton Act of 1883 created the first true U.S. civil service
History
The Pendleton Act of 1883 created the first true U.S. civil service
Fundamental Concept - Equal pay for work of equal value
It is one of the merit principles and is based in law
[Title 5 of the United States Code (5 USC) & Code of Federal Regulations (5 CFR)]
The challenge
Assure sufficient internal equity while still assuring pay comparability with industry and
non-profit employers
Underlying Assumption and Expectation
Classification decisions are fair, equitable and demonstrate adherence to the highest levels of professional and ethical standards
Instructor: You may decide to provide additional background on the historical events leading up to the Pendleton Act of 1883.
It was created during the aftermath of the death of President Garfield who was shot by a disgruntled applicant who felt he deserved a government job because he had helped with Garfield’s campaign. At that time, government jobs were usually filled by people who had political connections with the current administration. It truly was a system based on primarily who you knew, rather than qualifications. This was known as the “spoils system.” The Pendleton Act established a new U.S. civil service system that was based on merit.
Classification systems aid managers in designing and transitioning to high performance organizations
- Increase organizational effectiveness – Identify process improvements - Improve competitiveness in contracting-out studies - Minimize potential for pay abuses - Establish opportunities for employee growth, job enhancement, and/or career development

4. Regulatory Base Executive Orders Title 5, USC
Code of Federal Regulations (5 CFR)
OPM Operating Manuals
DOD Regulations/Manuals/Instructions
Army Regulations & Policy Memoranda
Army Command Regulations
Local Regulations & Union Agreements
Note that if Bargaining Unit Agreements are in conflict with other regulations, the negotiated contract takes precedent. However, the union contract cannot contradict what is based in law.

5. CPAC Classification Functions
Classification processing (at least 90% accurate)
Classification advice to managers
Application of new standards
Review of appeal packages
Pay administration (FLSA, premium pay, etc.)
Advice to employees (appeals, grievances)
Train managers
Some managers have said “If I’m doing the classification, what does the CPAC Classifier do?” This slide shows the various classification functions that are performed by the HR Classification Advisor.

6. Classification Decisions
DCA Manager Classification Decisions
CPAC HR Classification Advisor Decisions
Are duties accurately described in the PD with estimates of the percentage of time
Is the PD in the proper format?
What is the proper pay system?
What is the proper series?
What is the proper grade?
What is the proper title?
Ensure PDs are in the proper format, verifies accuracy
Advise managers on pay system, series, grade, title
Fair Labor Standards Act
Competitive levels and position other codes
The left hand column lists the kinds of decisions the DCA Manager must make.
The right hand column lists the kinds of decisions and activities carried out by the CPAC classification advisor.

7. About Delegation of Classification Authority
Memo dated November 17, 1997
Delegation to commanders who may delegate through management chain to the lowest practical level
Managers must complete required training
DCA managers must follow the law, published classification standards, OPM/DoD appeal decisions, etc.
Certain restrictions (i.e., cannot classify your own position)
When manager does not have authority, CPAC classifies position
The 1997 memo establishes the Army policy regarding delegated classification within the agency. Some of the memo’s key points are reflected beneath
The DA memo also outlines some restrictions. For example, a supervisor may not upgrade the base level of his/her employees in order to force an upgrade of his/her own position.

8. Organizational design considerations
Balancing Economy & Efficiency
Organizational design considerations
Use the lowest grades feasible to accomplish the mission
Normally provide for career progression
Eliminate excessive layers of supervision
Avoid assignment of employees to position descriptions that do not match the work assigned and performed
Supervisors and managers have always had responsibility for accomplishing their missions by designing their organizational structures and assigning duties and responsibilities to their positions. It has always been, and will continue to be, a balancing act between the most efficient organizational design versus the most economical design.
This slide identifies some of the issues that should be considered when designing organizations and position structures.

9. About Job Design
Job design is a supervisory responsibility. It is essential for Delegated Classification Authority
Job design involves deciding how the work of your organization will be distributed among the positions you are authorized
Grouping duties and responsibilities in different ways can result in differences in the classification of those positions (e.g., pay system, title, series, and grade
The key point on this slide is that job design is a management responsibility. This is because supervisors are responsible for assigning duties and responsibilities to each position. Knowing the principles underlying job design is important for those who have Delegated Classification Authority.

10. Why is Job Design Important?
Good Design
Enhances organizational effectiveness
Aids in retaining employees
Bad Design
Increases employee turnover
Reduces productivity
Increases personnel costs
This slide reflects some of the benefits of job good design and the disadvantages of poor job design. For example, a job design that involves challenging work and some decision making authority can not only aid in employee retention, but also improve organizational effectiveness.

11. Characteristics of General Schedule (GS)
Covers “white collar” work
Grades 1-15; 10 steps per grade
Single worldwide base salary
Locality differentials
Annual general increase
General
Schedule
Characteristics of General Schedule.

12. Characteristics of Federal Wage System
Covers “blue collar work”
WG for non-supervisory positions
WL for leaders
WS for supervisors
Locality rates
FWS
Characteristics of FWS.

13. GS Career Patterns P A T C O Professional/ Administrative
Both include 2-grade interval work
Technician/Assistant
Both include 1-grade interval work
Clerical
Includes 1-grade interval work
Other
Includes 1-or 2-grade interval work P A T C O
These are the 5 PATCO categories displayed by the their career patterns. Understanding how OPM categorizes work is important in the classification process.

14. Position Descriptions
Decisions made about job design are documented in Position Descriptions (PDs)
Managers use FASCLASS (Fully Automated System for Classification) to create PDs
FASCLASS is a library housing all civilian PDs in the Army
Use caution when relying on FASCLASS PDs; some contain classification errors
FASCLASS can be accessed through: CPOL/References & Tools/ Position Classification
You may want to demonstrate FASCLASS if time permits and a PC is readily is available.

15. Typical GS Grading Patterns
Prof/Admin
Grades 5/7/9/11/12/13/14/15
Referred to as 2-grade interval work
GS-13/14 usually found at HQs/Command levels
Tech/Asst
Grades 4/5/6/7/8
Referred to as 1-grade interval work
GS-8 is unusual
GS-4/5 typically involve information gathering
GS-6/7 typically support 2-grade interval specialists
Clerical
Grades 1/2/3/4/5/6
GS-1/2/3 involved in filing, processing forms
GS-4/5 involved in problem solving
GS-5/6 involve clerical specialization, leading other clerks

16. Job Evaluation Major Duty
Represents the essential and basic reason for the position, either:
25% of the employee’s time (GS only), OR
Requires a significant knowledge, skill, or ability that would influence recruitment
Work is regular and recurring
Give some emphasis to major duty.
Note: a major duty can be less than 25% if it controls KSAs. A good example is a Secretary (Stenography), who uses steno skills only 10% of the time, or Spanish language requirement for an Hispanic EEO Coordinator.

17. Job Evaluation What is Regular and Recurring?
Not emergency
Not acting in the absence
Typically scheduled (every day, every week, etc.)
Grade-controlling for FWS, but use caution when low % of time
Explain what is meant by regular and recurring. It’s also referred to as regular and continuing.
Formal work schedules or production logs provide evidence for regular and recurring.
Regular and recurring is NOT acting in the absence of employees who randomly use AL or SL. However, performing duties every other Friday because of an alternate work schedule would be considered regular and recurring.
For FWS positions, there is no % of time required for a major duty. The only requirement is that the work be regular and recurring. However, low % of time, like 5% or less, should be examined carefully. More than likely the duty is a task rather than a major duty and could be absorbed in a larger major duty paragraph in the PD, or not described at all.

18. Job Evaluation Grade Controlling
Work which supports the grade or pay level of the position
In GS, must be at least 25% or more of the employee’s time
In FWS, must be regular and recurring
Grade Controlling
Spend a little time contrasting FWS and GS grade-controlling rules.
Make the basic definition of grade-controlling work is understood: Work performed that represents the overall grade of the position . For example, if a position performs a combination of GS-5 and GS-6 level work, then the duties performed at the GS-6 level represent the grade-controlling work. This is because we classify to the highest level of work performed that is at least 25% of the time (GS) or regular and recurring (FWS).

19. About Classification Standards
Published by OPM at
Based on Title 5
Describe work covered by the standard/guide
Provide for determination of pay system, title, series, and grade
Point out that OPM publishes all federal classification standards and guides. DoD and DA publish a few agency references such as DCIPS, certain COE classification standards, or NAF guides.

20. Fair Labor Standards Act (FLSA)
Passed in 1938 for private sector
Applied to Federal Government in 1974
OPM administers FLSA for Federal employees
Two categories:
Exempt: not covered by FLSA overtime and minimum wage provisions (see 5 CFR Ch 550)
Nonexempt: covered by FLSA overtime and minimum wage provisions (see 5 CFR Ch 551)
Quickly go over the background of FLSA. Point out that FLSA is primarily concerned with OT computation, but there are other provisions in the law as well (e.g., child labor restrictions).
Emphasize that all supervisors, including DCA managers, need to understand the fundamentals of FLSA. The primary outcome of FLSA is the determination of whether or not a position is covered or not covered by the provisions of FLSA.

21. Rules for Exempt and Nonexempt employees differ in:
Why Should You Care?
Rules for Exempt and Nonexempt employees differ in:
Rights/options of employees
How OT payment is calculated
What counts as “hours of work”, especially travel and training activities
Latitude of management in directing comp time in lieu of OT payment
This slide highlights the major reasons why supervisors and managers should care about how the FLSA is applied.

22. FLSA Provisions
Overtime provision (1.5 X regular rate )
GS employees can request compensatory time;
Nonexempt employees cannot be ordered to take comp time
FWS employees: may earn comp time, but check your labor agreement
Suffer or permit doctrine
Point out that OT under FLSA is calculated as 1.5 times the employee’s regular rate of pay.
All GS employees may request comp time in lieu of OT. However, supervisors/managers CANNOT order nonexempt employees to take comp time. For example, a supervisor may have a limited OT budget. He/she may order his/her Exempt employees (e.g., GS-11 Budget Analysts) to work comp time for a particular project, but must offer OT to his/her Nonexempt employees (e.g., GS-5 Budget Assistants) who support the project. It is permissible to approve comp time for Nonexempt employees if they request it.
One on of the most important provision of FLSA concerns the “suffer or permit doctrine.” The following slide will go into more detail about this doctrine.
Be careful with FWS employees. Prior to changes in 2007, FWS employees were not permitted to request comp time. Some labor agreements have not been renegotiated to reflect that change.

23. What is “Suffer and Permit”?
Any work the supervisor allows a Nonexempt employee to perform is counted as work:
Supervisor need not order or authorize
Sufficient that supervisor has reason to believe work was performed
Nonexempt employees are entitled to OT compensation, unless they request comp time
Spend a little time on this slide to ensure it is understood that managers can’t simply allow Nonexempt employees to perform work that goes beyond their normal tour of duty without being compensated. This includes knowingly letting them work through their lunch hour. To do so leaves the supervisor vulnerable to FLSA back pay claims at a later date.
Example: Employee works late or on the weekend and puts completed work in supervisor's "in box"

24. Positions that are always Nonexempt
FLSA Quick Tests
Positions that are always Nonexempt
GS-8 and below
Trainee positions (GS-5/7/9)
Wage Grade and Wage Leaders
Here are some quick rules that can be used to determine Nonexempt positions.

25. Bottom Line…… Commanders/Directors delegated classification authority:
must assure compliance with statutory and regulatory requirements for accurate description and grading of civilian positions
take action to correct inaccurate classification, misassignment of employees to inappropriate position descriptions, or other error conditions
Establish procedures for assessing program trends
Approving the classification of a position has the effect of approving the expenditure of funds
Army requires classification programs maintain a position description and job grading accuracy rate of 90%