Delegation of Classification Authority (DCA)

Commander’s Briefing

•Enable the Commander to delegate and oversee classification processes

•Publicize Army classification policies

•Explain impact of Fair Labor Standards Act requirements

Purpose

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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

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

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Regulatory Base

Local Regulations & Union Agreements

Army Command Regulations

Army Regulations & Policy Memoranda

DOD Regulations/Manuals/Instructions

OPM Operating Manuals

Code of Federal Regulations (5 CFR)

Title 5, USC

Executive Orders

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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

CPAC Classification Functions

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Classification Decisions

DCA Manager Classification 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?

CPAC HR Classification Advisor Decisions

• 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

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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

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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

Balancing Economy & Efficiency

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

About Job Design

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Good Design

Enhances organizational effectiveness

Aids in retaining employees

Bad Design

Increases employee turnover

Reduces productivity

Increases personnel costs

Why is Job Design Important?

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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

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Characteristics of Federal Wage System

Covers “blue collar work”

WG for non-supervisory

positions

WL for leaders

WS for supervisors

Locality rates

FWS

•Both include 2-grade interval work

Professional/ Administrative

•Both include 1-grade interval work

Technician/Assistant

•Includes 1-grade interval work

Clerical

•Includes 1-or 2-grade interval work

Other

GS Career Patterns

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PATCO

Position Descriptions

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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

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

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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

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Job EvaluationWhat 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

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Job Evaluation

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

Published by OPM at http://www.opm.gov

Based on Title 5

Describe work covered by the standard/guide

Provide for determination of pay system, title, series, and grade

About Classification Standards

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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)20

Why Should You Care?

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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

•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

FLSA Provisions

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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

Example: Employee works late or on the weekend and puts completed work in supervisor's "in box"

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FLSA Quick Tests

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Positions that are always Nonexempt

GS-8 and below Trainee positions (GS-5/7/9)

Wage Grade and Wage Leaders

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%