PROPOSED LEGISLATIVE EXEMPTION FOR CIA FROM THE PERFORMANCE RATING ACT OF 1950
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
CIA-RDP80-01826R000400100039-9
Release Decision:
RIPPUB
Original Classification:
S
Document Page Count:
33
Document Creation Date:
December 12, 2016
Document Release Date:
December 14, 2001
Sequence Number:
39
Case Number:
Publication Date:
February 5, 1952
Content Type:
MEMO
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Body:
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5 February 1952
*DOE Review Completed*
Assistant Director (Personnel)
Proposed Legislative cemption for CIA from the Performance
Rating Act of 1950
This will confirm the agreement reached in the neeting of the
ervice Com ittee on 4 February on the above subject.
29 The General Counsel and the Acting Personnel Director will discuss
with the Civil Service Commission the establishment of administrative pro-
cedures by means of which CIA can comply in a completely secure way with the
provisions of P. L. 873,e The Performance Rating Act of 1950.E The good
offices of the Bureau of the Budget will be used as appropriate as you
suggested yesterday. The Civil Service Commission should be asked to
satisfy in all respects the security requirements of CLt and to give
written undertakings to this effect.
3. Should the Commission not be able to -provile the necessary waivers
with respect to sec !tty# it is understood that the Bureau of the Budget
will support CIA x s request to the Congress for legislative exemption from
the Act.
4. It was agreed by the Committee that any proposed form or forms
that might be used by CIA would not enter Into the discussion at this stage
since a.) exemption hinges on our security requirements and b.) no final
decision has been reached on a form or forms to be used by CIA.
X.TRUM DAVISON
Members of the Career Service Committee
Acting Personnel Director
Security Officer
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Personnel
P40/41
icy
The
UNITED STATES
ATOMIC ENERGY
COMMISSION
Washington, D. C.
January 1951
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Preface
We have examined carefully the Federal Em-
ployee Personnel Policy which has been in effect,
and have reviewed suggestions for its modifica-
tion. Few changes have been suggested as a
result of the experiences of the organization
during the past three years, and we have found
only minor points to suggest for revision.
It is the kind of personnel policy with which
we fully agree. We believe that it contains the
principles which must be put into practice if
our management is to meet the test. We want
these principles to he applied with increasing
skill by all of us in the AEC at all levels of
management throughoui the critical days ahead.
A-comic ENERGY COMMISSION
November, 1950
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CONTENTS
Page
FOREWORD ........................... V
ORGANIZATION, SUPERVISION AND COM-
MUNICATION ....................... 1
EMPLOYEE PARTICIPATION ............. 2
t
PERFORMANCE REVIEW ,.....j , .......... 3
..a
TRAINING ............... ._ ~........ 3
NON-DISCRIMINATION ......... F.,^?y .... 4
EMPLOYMENT ........................ 4
SEPARATIONS ......................... 5
GRIEVANCES ......................... 5
SAFETY AND HEALTH .................. 6
SALARIES AND WAGES ................. 6
BENEFIT PLANS ....................... 7
CONCLUSION ......................... 7
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Foreword
The people of the United States, through the Congress,
have entrusted to the Atomic Energy Commission the vital
and urgent task of developing atd utilizing atomic energy
for the purpose of "improviti#, they public welfare, increasing
the standard of living, strengths6ng free competition in
private enterprise, and promoting Wlxld, peace." During
the past several months it has become' increasingly clear
that the growing defense effort of the, nation is expanding
the manpower needs of the nation and thereby placing
greater emphasis than ever on the importance of accomplish-
ing the most with as few people as possible. We believe
that the successful application at all levels of management
of the principles contained in this personnel policy will go
far toward assuring that the AEC successfully recruits, re-
tains, and utilizes the personnel needed as manpower be-
comes more scarce. The carrying forward of this mission
is "subject at all times to the paramount objective of
assuring the common defense and security." The achieve-
ment of these objectives requires a high order of skill,
ingenuity, patience, loyalty, and perseverance in meeting
and resolving many new and complex problems.
All of us serving in this task should be proud to be able
to contribute so directly to the welfare of the nation.
Every job is a vital part of our over-all program. Our
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objectives cannot be met unless each individual employee,
whatever his duties or responsibilities, is pulling his full
weight. Whatever his particular assignment, every em-
ployee of the Atomic Energy Commission can derive special
satisfaction and inspiration from the knowledge that he
works in a unique enterprise of great importance to the
national well being.
The Atomic Energy Act requires the Commission to
assure itself that the character, associations, and loyalty of
workers in atomic energy is of a high order. Conduct and
self-discipline, both on and off the job, must measure up to
unusual standards. The exchange of information and the
handling of equipment, materials, and documents must be
precise and within established procedures. In short, many
phases of the daily job that are "ordinary" ' in most organ-
izations become "extraordinary" in the Atomic Energy
Commission.
Rapid progress in scientific achievement is the most vital
factor in "assuring the common defense and security."
Such progress and the forward movement of our own
responsibility necessitates a work environment in which
each of us has an opportunity to put forth his best effort at
the work for which he is best, fitted. In developing such
an environment it is essentiat that selection of employees,
work assignments, and promotions are on the basis of merit
and productivity. Political affiliation, family or other
personal relationships or other extraneous criteria cannot
be given consideration except as necessitated by security
requirements. An essential factor in maintaining an en-
vironment that encourages each employee to work enthu-
siastically and willingly to the best of his ability is an
organization which encourages and recognizes initiative in
taking the right action promptly and improving the way
in which things are done.
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The basic personnel policies which are set forth here
constitute the broad framework within which our manage-
ment job will be performed. In their application due con-
sideration will be given to the requirements of national
security, but "secrecy" must not be allowed to become a
cover for bad management practice.
The policies have been formulated through the partic-
ipation of the employees and staff officials throughout the
organization; giving reflection to their views and indicating
acceptance of the underlying principles involved. A sound
basis has been thereby provided foI the kind of personnel
job that is essential to the effective and economical accom-
plishment of the work goals of the',aency.
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Organization, Supervision and
Communication
The General Manager and all other employees who
direct the work of others will assure that those under their
supervision know their jobs, to whom each is responsible,
the authority that goes with their jobs, the relationships
of their jobs to other jobs in the organization, and the
channels of communication. Each major geographical area
will so organize its activities as to `provide continuing
leadership, guidance, and assistance 0to supervisors and em-
ployees in achieving proper applicatici of the principles
set forth in this policy.
The structure of the organization will be the result of
careful planning designed to meet specific program needs,
and to permit independent action to be taken within the
limitations of established policies and the minimum of
uniform standards and procedures essential for effective
operation. The desirability for freedom and informality
in staff communications and working relationships at and
between all organizational levels is emphasized; always
recognizing, however, the single line of authority necessary
in taking official action.
The Commission feels strongly that certain sound orga-
nization practices such as the following are too often for-
gotten and therefore they are set forth below as part of
this policy.
1. Assignment of responsibility will carry with it com-
mensurate delegation of authority.
2. Any change in duties and responsibilities of a position
or a group of positions will be preceded by a definite under-
standing on the part of all concerned.
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3. An employee will not be required to report directly
to more than one supervisor.
4. Instructions and directions relating to work assign-
ments will be communicated to him, only through, or with
the agreement of, the immediate supervisor.
5. Changes in an employee's work assignment or em-
ployment status will be communicated to him, after proper
approvals, only by his immediate supervisor.
Employee Participation
The widest practicable opportunity will be afforded to
employees for consultation and explanation in the formula-
tion and developmentof policies affecting their employment
status, working conditions, and productivity. This oppor-
tunity will be effected through positive encouragement of
a free exchange between supervisory and supervised em-
ployees of points of view and ideas in their daily work
together and in regular departmental staff meetings, super-
visory conference$., cor}ferences of management and em-
ployee representatives, and other effective means.
Employees are urged to avail themselves of these oppor-
tunities for participation. Employees have the right to
join or refrain from joining employees' organizations of
their own choosing without coercion or fear of discrimina-
tion. This right, of course, must be exercised in a manner
which is consistent with applicable law and the security
responsibilities of the Commission.
It is recognized that employee organizations can make a
positive contribution in furthering the atomic energy
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program. Accordingly, the participation of employee
organizations in the program is welcomed. The promotion
of sound employee-management relations is a mutual con-
cern and benefits employees and the Commission alike.
Performance Review
Formal periodic review of the performance and capabil-
ities of employees will be made against realistic and under-
stood performance standards to determine any merited
recognition, need for their further development, or change
in job status. Each supervisor will record and use current
information on the experience, qualificks, and perform-
ance of each individual under his directiot',,as a basis of
planning for the training and further development of such
employees or other appropriate personnel action. Each
supervisor will discuss any evaluation and the basis for it
with the employee affected to develop mutual under-
standing.
Training
Consistent with definite needs which arise or are antic-
ipated, employees will be provided with opportunity to
improve their knowledges, skills, or attitudes in order to
enable them to perform the tasks assigned to them in the
best known ways and to prepare for advancement. This
will include programs for orientation and induction before
assignment of work, training on the job, upgrading and
understudy programs, and training in supervision and
management practices.
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Non-Discrimination
There will be no discrimination against an employee
because of race, color, sex, religion, physical handicap, or
national origin.
Employment
The far-reaching significance and scope of the atomic
energy program requires high standards of employment
which will attract and maintain an adequate organization
of capable and well-qualified people.
Accordingly:
1. Adequate "sources from which employees may be
recruited will be developed and maintained.
2. Each job will be filled on a merit basis by selecting
the available individual best qualified in terms of the care-
fully determined requirements of the particular position
and in accordance with the Veterans' Preference Act of 1944,
as amended.
3. Opportunity for transfer and promotion will be pro-
vided in order to make full use of demonstrated skills and
abilities. Therefore, well-qualified employees will be
given first consideration in filling vacancies.
4. The appointment or promotion of individuals or other
personnel actions will be made without consideration of
political affiliation.
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Separations
When it is necessary to reduce employment, the selection
of employees for retention within an appropriate geograph-
ical area will be on the basis of relative qualifications for
the work remaining to be done, and in accordance with the
requirements of the Veterans' Preference Act of 1944, as
amended, including veteran status, and length of Federal
service. Reasonable notice will be given to employees
whose services are to be terminated and their availability
will be made known to other AEC offices. Employees
notified of their planned separation shall have an oppor-
tunity to appeal such determination.
,,?discharged for cause
An employee will be demoted 6r
only after he has. been given (1) a, stateient of the reasons
for the proposed action, (2) an opportunity to reply, and
(3) an opportunity to appeal any determination to dismiss.
An employee may be put in suspension status without pay
pending final determination.
Grievances
Supervisory and supervised employees have an obligation
to make every effort to resolve employment relations
problems as they arise. Failing prompt and satisfactory
adjustment of any grievance, including those relating to
separation, appeal may be made by employees at any work
level to higher authority. Employees may designate repre-
sentatives of their own choosing to assist them in presen-
tation of grievances. In presenting grievances employees
will be free from any interference, restraint, or reprisal.
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Safety and Health
Each supervisor will take the initiative in the establish-
ment and maintenance of safe and healthful practices and
work places for every employee under his supervision, and
in assuring that the manner of performance of all operations
will minimize personal injury and disease and damage to
equipment, materials, and property. Safety is an integral
part of each job, and each employee is responsible for the
safety phase of his work just as much as he is for any
other phase.
Salaries and Wages
Salaries and wages shall be administered so as to com-
pensate employees equitably with due regard to the relative
value of the positions, to provide for increases in pay on
the same job after reasonable periods of satisfactory service,
and to provide for recognition by increases in pay for espe-
cially meritorious services.
Determination of the relative value or grade of positions
will be based upon systematic analysis of the differences in
the requirements of the positions and upon comparison
with approved standards.
Salaries for positions, except those noted below will be
established in line with the pay scales of the Classification
Act of 1949, in accordance with the requirements of the
Appropriation Act for the current fiscal year.
Wages for laborer and mechanic positions will be estab-
lished after consideration of rates paid for similar work by
other government and private employers in the appropriate
geographical area.
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Certain scientific and technical positions which the
Commission finds must be exempted from the salary scales
of the Classification Act of 1949, will receive salaries which
are arrived at after consideration of the rates paid for
similar work by other government and private organiza-
tions.
The method by which the rate of pay for his job is
determined will be explained to each employee.
Benefit Plans
Employees will be granted the same benefits"with respect
to leave, workmen's compensation, holidays, And retire-
ment as are granted to other Federal employees. Informa-
tion on the details of these plans will be given to employees.
Conclusion
The Atomic Energy Commission looks forward to the
application of this policy; first, through the wholehearted
and effective execution of the principles of sound employee
relations by the Commission members, the General Man-
ager, and all the employees who direct the work of others;
second, through the wholehearted acceptance by all em-
ployees of the obligations that attach to their employment
in the atomic energy program; third, through the develop-
ment of effective employee-management cooperation.
Application of the principles underlying this policy must
be an integral part of the daily activities of supervisors at
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all levels and of all other employees. The General Man-
ager, aided by'the Director of Organization and Personnel,
will take such action as is appropriate to implement the
policy, to evaluate the adequacy with which the policy
meets current program needs, and to assure performance in
accord with the policy.
Many of the principles have been implemented through
the development of more detailed policies and procedures.
As additional experience is gained with the policy and
principles and as the continuous task of implementing them
goes forward, it is expected that employees will continue
to make known their views.
ATOMIC ENERGY COMMISSION
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SECURITY 1NF#RSt'p"?1
Chai
2. of ted
a. To terse
tion within t
out, This roendtion to cc `e ',
(1) i ti t of the paper
for Participation in the Cf
*1D"ombar 1951) to state
e red.bilittes of t see
s of the Boards,. mid t)
the h...nios of
selection
the Boards will exercise their responsibilities.
(2) Co wrz tion with sera. Counsel to ,r ee, a form
'
-.n
Ass's; rso n.e . File ct nt<
tent by the ell - y - e.
ice by the fio7
(b) Certification p3"o9'en sew
cw*er service Board (0).
To r
of the career Sergi
Service Boa
ompletes the bus
selection
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actin tim
Working
25X1A9A
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SECURITY INFORMATION
30 January 1952
MMORkNIUM FOR THE CHAIRMAN, CIA CAREER SERVICE CON! ITTE
SQHJ DCT: Report of the Working Group on Rotation
le We transmit herewith the report of your Working
Group on Rotation in accordance with the directive of the
Career Service Committee dated 15 October, as amended and
supplemented by subsequent actions.
29 The Working Group believes that its recomnendaP.
tions can be implemented immediately and concurrently
with or independently of such recommendations as the
Committee may adopt as a result of the proposals of the
other working groups. We would point out, however, that
a piecemeal presentation of various aspects of the overall
career service program would fail to make the impact on CIA
personnel which an omnibus presentation could achieve.
3. This Group stands ready to elaborate any aspects
of the program outlined here generally.
FOR THE WORKING GROUP ON ROTATIONt
25X1A9A
Ch- air-man
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SEGURITY fl ORM TION
B#mr-t W! the
R O T A T I O N
30 3amuarY 1952
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REPORT OF THE WORKING GROUP ON ROTATION
Ii., PROBLEM
To recommend to the Career Service Committee a policy
regarding intra.Office rotations inter-Office rotation and
extra-CIA rotation; to recommend policies and procedures
regarding rotation between overt and covert offices and
between domestic and overseas duty; to recommend the degree
to which the several types of rotation should be centralized
or doc oentra ized within CIA; to recommend procedures by which
the several types of rotation should be administered, scheduled
and controlled in order to advance the development of the
individual and contribute the greatest benefit to CIA and to
its component officesa
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Ho DEFINITIONS
to Rotation
The process of aystematio designation and redesignation
of an individual to various kinds of duty and training for the
purpose of improving his capacity to serve the Agencyo
The process of removing an individual from the rolls of one
office and his concurrent addition to the rolls of another Office.
This process is independent of the process of rotation though it
may be a consequence thereofo
3. Lxchan
The process of rotating an Individual by placing him
temporarily under the'operational control of another office
in return for another individual similarly attached.
)4o Loan
The process of rotating an individual by placing him
temporarily under the operational control of another office
without reciprocitys.or of attaching him temporarily to an
activity not a part of CIA,
50. Sponsoring Office
The administrative unit of CIA on whose rolls the rotatee
is carried and under whose administrative control the rotates
remains irrespective of where attached,
6a Receiving Office
The administrative unit to which the rotatee is attached
and under whose operational control the rotatee remains until
he is returned to the Sponsoring Officeo
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IIIe OBJECTIVES OF ROTATION
to For the Agency
(a) A more effective and more economical utilization of the
Agency's manpower,,
(b) A method of improving the selection and broadening the
experience of individuals to serve in key positions,
(c) The cultivation of an esprit de corps based primarily
on the reward for merit principle,,
20 For the Individual
(a) Assisting him to do his present job more effectively by:
(1) Increasing his knowledge in his field,,.
(2) Providing him with new skills, techniques and methods
of performance.
(3) Improving his ability to plan his work and to direct
and supervise others in it*
(4) Increasing his understanding of the necessary r4lationships
of his job to those of collateral and higher echelons of the
Agency,,
(b) Preparing him to undertake jobs of increasingly greater
responsibility commensurate with his growth potential by:
(1) Broadening his understanding of the objectives of the
Agency and its mission,,
(2) Intensifying the development of his planning,
managerial and supervisory skills,, .
(c) Providing him more opportunity to find the field in
which he does best?
(d) Removing him from a "rut",
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~L
IV,, STATEM1 NT OF PRINCIPL:S SOV,LRNING ROTATION
I.. Personnel Covered
In general: any individual who has been in the employ or,
the Agency for a period of not less than two years is el.igid le for
rotationo
2 Positions covered
Any position within the control of the Agency to which the
assignment of personnel will serve the objectives of rotation
is regarded as covered by these principles,., These include executive.,
operational, intelligence, administrative and training positions,
either in the field or at headquarters., within the Agency or with
other public or private agencies or institutiionso
3o Job Groups Covered
The classes of individuals c-overid are inclusive rather than
activity of a
exclusiveo The professional
job typo class
of individuals mays by its
members,of such a class will rotateo
4, Normal Duration of Tour of Duty
Each individual rotation period may vary but will. not be less
than six months, and will probably average between 18 and 24 months,,
Thus a training assignment at the National War College will run
some 10 months while an assignment to a field position overseas may
well run '24 m 30 months o
5? Degree of Compulsio8 to Rotes
As a matter of principle., acceptance of a rotation assign nt
is compulsory' only for members of the Development Programo however
individual or sponsoring office, or receiving office, may, ,
show cause why a rotation assignment shall be carried outo The
ruling of the reviewing authority (the CIA Career Service Board)
in such cases shall be fifalc
6? Administrative Control
The rotatee will remain on the rolls of the sponsoring office
and under its administrative control for promotion and transfer
purpose a
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?o Operational Control
The?rotatee will be undor the operational control of the
receiving office for the duration of'his tour of duty with that
office, during which period evaluation reports will be prepared
by the receiving officeo
Bo Effect of Grade Differential between hobs from and to Which
an v u is r a e
Assignments given to individuals being rotated shall be gexrterally
commensurate with their abilities keeping in mind the purpose of
making the specific assignmento "Open" slots will be allocated to offices
to maintain flexibility in negotiating rotation
9o Changes in Grade
Promotions and other changes in grade shall remain under the
control of the sponsoring officeo The eligibility of the individual
for promotion shall not be prejudiced or overlooked by reason of his
status as a rotatee
l?o Duration of Rotational Pattern
It is premature at this time to formulate a policy covering.the
duration in years during which period the individual is subject to
rotation policies, or to attempt to prescribe an aLibiitrary ale limit
after which rotation policies will not be appliedo
llo Settlement of Disputes:
Divergence of views between offices or between an individual
and his : ffice Career Service Board which cannot be satisfactorily
resolved between the parties shall be referred in the first instance to
the Secretariat which will review the case and forward its recommendation
to the concerned offie Caar~er Service Board (s)o In the event the
recommendation of the Secretariat is not accepted, the case ,shall be
referred to the ' CIA Career Service Board for final disposition'
l2a Policy Governing Rotation within an Office4
IntraOOffice rotation policy shall be set by the fficZ7 Career
Service Board within the frame-work of policies prescr ed by the CIA Career
Service Boardo
l3o Policy Governing Rotation between Offices
Within the framework of policies prescribed by the CIA Career Service
Board inter-office rotation will be based largely on a series of bi-lateral
agreements between offices which agreements will. set forth in each case
the person being rotated, the expected duration of his assignment and
any other pertinent factso
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m5~
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!!d!!~
1. CIA Career Service Board
(a) Copition
Deputy Director of Central Intelligence, Chairman
Deputy Director/Plans
Deputy Director/Intelligence
Deputy Director/A,dininistration
Assistant Director (Personnel) in his capacity as head
of the Secretariat and the Director of Training in his capacity
as deputy head of the Secretariat will be non-voting members of
this Board.
(b) dons
(1) Oversee the CIA Rotation Program.
(2).Arbitrate Office Board impasses.
(3) Endorse or reject Office Board rotation recommendatio .
(4) Quarterly make final, binding decision on rotation
appointments.
(5) Levy requirer..ents on Office Board for rotatees to
prepare then to fill key Agency positions.
2. Office _Career Service board
(a) Composition
Assistant Director (or Staff Chief), or his Deputy, and
at least two members of his Office designated by him.
(b) PMc' oxs
(1) Sponsor, develop, and execute an intra-office rotation
system.and report on it periodically to the CIA Board via the
Secretariat.
(2) Sponsor, develop, and execute an extra-office rotation
system.
(3) Submit rotation recommendations for extra-office appoint-
ment to the Secretariat in accord tirith Jnnex A.
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V. OUTLINE PROCEDURE
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3.
(4) Review circular announcement of recommendations
and negotiate with other Office Boards to effect agreement
on rotation appointments.
(5) Interview if necessary prospective rotatees.
(6) Report concurrence or rejection to the Secretariat.
(7) Execute the decisions of the CIA Board.
(8) Submit semi-annual evaluation report on each
rotation appointee from another Board; recommend promot'on,
cancellation or continuance of appointment.
(9) Ensure that the rotates is not overlooked for
warranted promotion.
(10) Ensure that wort: of rotatees received is productive
and commensurate with the purpose of the appointment.
Secretariat of the CTA. Career Service Board
(a) Composition
As appropriate to its task. The Assistant Director
(Personnel) will be head of the Secretariat. The deputy
head will be the Director of Training.
(b). Functions
(1) Perform all administrative functions for the CIA
Career Service Board. These include:
The maintenance of master files on a
current basis of all rotation nominations
and appointments.
The allocation of rotation appointment
slots to Office Boards.
c. The submission of unresolved inter-office
Board problems to the 01k Board for decision.
(2) Rotation Recommendations
a. Assist Office Boards in formulating rotation
recommendations.
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b. Verify qualifications submitted with each
recommendation.
c. Issue circular announcement to Office Boards
listing approved rotation nominations. (The
list will contain full data on the individual
plus the rotation appointment recommendation
of the sponsoring Board.)
d. Transmit recommendations to CIA Board for
approval, and prepare agenda for its meetings.
(c) Rot tion b yE hangs
(1) The exchange procedure authorizes Office Boards
to recommend the "swapping" of rotation approved candidates.
This will be used tuhen the two positions in question are of
corresponding responsibility. Respective grades of the posi-
tion or incumbents need not be exactly the same.
(2) The sponsoring Office Board will pay the rotatee
from home office funds at his home office grade.
(3) The receiving Office Board will outline to the
rotatee the responsibilities of the new position.
(4) Exchange appointments will last for a minim=++
period of six months.
(5) Rotatees will be under the operational control
supervision of the receiving Office Board.
(d) Rotation bar Loan
(1) The Loan procedure authorizes Office Boards to
recormend the temporary assignment of rotation approved
candidates to another Office or to outside activities for
the purpose of broadening an individual's knowledge of his
field.
(2) The sponsoring office Board will pay the appointee
from home office funds at his home office grade. Rotation
slots, allocated by quota outlined in Annex nAsn will be
available to each Office Board. These slots will be allotted
by the CIA Board and will be "open" positions to accommodate
any grade.
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(3) The receiving Office Board will outline to the
appointee the responsibilities of his new assignment. The
appointee is "on loan" to the receiving Office and will
therefore not tie up authorized T/O positions. He will
be assigned to a logical unit in the receiving Officers
organizational structure.
(4) Loan appointments will last for a minimum period
of six months.
(5) Appointees will be under.the operational control
of the receiving Office Board.
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25X1A9A
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Approved For Release 2002 / , 01826R000400100039-9
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SECURITY INFORMATION
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Approved For Release 2002/05/20 CIA-RDP80-01826R000400100039-9
Approved For Release 2002/0
OF 3rd CAi
8 October 19
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) decided that the Deputy Director (AftViistration) aid
of tam di Mon would be wed app:
by CIA to the Congress for a ption from the
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CONFIDENT IAL
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