LETTER TO PATRICIAL SCHROEDER FROM WILLIAM J. ANDERSON

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP89-00066R000100040009-1
• Release Decision: RIFPUB
• Original Classification: K
• Document Page Count: 24
• Document Creation Date: December 22, 2016
• Document Release Date: February 22, 2010
• Sequence Number: 9
• Content Type: LETTER

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UNITED STATES GENERAL ACCOUNTING OFFICE
WASHINGTON, D.C. 20548
GENERAL GOVERNMENT
DIVISION
The Honorable Patricia Schroeder
Chairwoman, Subcommittee on Civil
Service
Committee on Post Office and Civil
Service
House of Representatives
Dear Madam Chairwoman:
In an August 8, 1983, letter, you asked us to obtain infor-
mation on appointments made to entry level professional and
administrative career (PAC) positionsl before and after the
abolishment of the Professional and Administrative Career
Examination (PACE). The Office of Personnel Management (OPM)
abolished PACE in August 1982 as a result of a consent decree
negotiated in the case of Luevano v,. Devine. The objective of
this consent decree was to eliminate adverse impact2 in the
hiring of blacks and hispanics for positions filled through
PACE.
As an interim replacement for PACE, OPM established a new
Schedule B3 appointing authority (Schedule B PAC) to be used in
.external hiring of employees for entry level PAC positions.
These positions were covered by PACE at the time it was abol-
ished. Thus far, no alternative competitive examining proce-
dures have been developed.
1PAC positions are nonclerical in nature and involve regulatory
and compliance work, administrative and management functions,
claims and benefit examining, investigative and law enforce-
ment duties, and social service work.
2Adverse impact is defined under the consent decree as a cir-
cumstance in which the percentage of minority applicants who
are hired in a job category is less than 80 percent of the per-
centage of white applicants who are hired.
3Schedule B authority covers positions for which OPM has deter-
mined that it is not practical to hold a competitive examina-
tion. Authorization to use Schedule B must be requested and
approved by OPM.
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You asked us to provide information on a number of ques-
tions related to PACE and the new Schedule B authority for fill-
ing entry level PAC positions. Our responses to these questions
are summarized below and presented in more detail in the appen-
dices to this letter.
We conducted our survey at OPM headquarters and four fed-
eral agencies--the Departments of the Navy and Health and Human
Services, the Defense Logistics Agency, and the Internal Revenue
Service. These agencies were selected because, as of October
1983 when we began our survey, they had authority to fill about
77 percent of the total number of PAC positions covered by the
Schedule B authority. A detailed description of the scope of
our review is presented in appendix I.
WHAT POSITIONS-WERE FORMERLY FILLED
THROUGH PACE AND HOW HAVE THEY BEEN
FILLED SINCE PACE WAS ABOLISHED?
Data on positions filled through PACE were not available
for each agency. Governmentwide, PACE covered GS-5 and GS-7
entry level positions in 120 different PAC occupations, but it
was only one of many methods used to fill PAC positions. Other
methods included internal promotions and reassignments and
transfers from other agencies. Although the principal method
for external hiring, PACE generally accounted for less than 10
percent of total PAC appointments. For example, total hires
from the PACE were 4,606 in fiscal year 1979 and 1,472 in the
last three quarters. of fiscal year 1982. They comprised about 8
and 6 percent of total PAC hires for those periods (58,483 and
26,451, respectively).
From October 1982 through June 1983,4 appointments were
made in all but 11 of the 120 PAC occupations that were formerly
covered by PACE. Approximately 26,000 GS-5/7 PAC positions were
filled during this time. Nearly three-fourths (19,194) of these
positions were filled by promoting or reassigning current
employees. Other methods included transfers from other federal
agencies, reinstatements of former employees, and placement pro-
grams for federal employees who had either been or were sched-
uled to be displaced from their positions through no fault of
their own. These methods have traditionally been used to fill
the majority of PAC vacancies. About 1 percent (354) of total
GS-5/7 PAC appointments were made under the new Schedule B PAC.
Appendix III shows how PAC positions were filled from October 1,
4At the time of our survey, October 1982 to June 1983 data were
the most recent detailed data available from OPM's Central
Personnel Data File on PAC positions filled after PACE was
abolished.
2
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1982, to June 30, 1983. Agency officials attributed the small
number of Schedule B PAC appointments in the 9-month period to
budget and personnel ceiling constraints and start-up delays
associated with the newness of the authority.
On July 24, 1984, OPM provided us with summary data showing
the number of Schedule B PAC appointments from July through
December 1983. During that period, 1,732 additional Schedule B
PAC appointments were made, bringing the total number of these
appointments from October 1982 through December 1983 to 2,086.
Limited demographic data on these appointments are contained in
the tables below and in appendix III (p. 17). More detailed
demographic data on total PAC appointments and the methods of
appointment were not available.
WHAT ARE THE DEMOGRAPHICS OF PAC
APPOINTEES SINCE PACE WAS ABOLISHED?
The tables below contain a summary of demographic data
obtained from OPM on all employees appointed to PAC positions
from October 1982 to June 1983.
Total PAC Appointments
26,349
Race and
national origin
Number
Percent
White
Bl
k
19,575
74.3
ac
4,478
17.0
Hispanic
O
h
1,433
X
5.4
t
er
863
Number
3.3
Percent
Female
M
l
16,419
62.3
a
e
9,926
37.7
Unspecified
4
.0
Age
Number
Percent
Under 25 yrs.
2
3,839
14.6
5-40 yrs.
41
16,424
62.3
-64 yrs.
5,990
22.7
65 yrs. or older
96
.4
Veterans Preference
Number
Percent
Vet. Pref.
N
-V
5,225
19.8
on
et. Pref.
U
21,112
80.1
nspecified
12
.1
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Appendix III (pp. 16 to 20) provides a detailed breakdown of the
appointment methods used and demographic data on the PAC employ-
ees appointed during the period October 1982 to June 1983.
DO SCHEDULE B PAC PROCEDURES MEET
REQUIREMENTS OF MERIT SELECTION?
Section 2301 of Title 5 of the United States Code specifies
that federal personnel management should be implemented con-
sistent with merit system principles. These principles, which
are broad guidelines for agencies to follow in carrying out
their personnel management activities, cover all aspects of per-
sonnel management, including the selection of employees. The
merit principle for selection of candidates for vacant positions
requires that selection be based
solely on the . . . relative ability, knowl-
edge,~and skills (of the candidates] after fair and
open competition which assures that all receive equal
opportunity."
As indicated on page 2, most of the PAC positions filled
since the PACE was abolished were filled by methods other than
Schedule B PAC. These methods, such as promotions and reassign-
ments, were also used to fill PAC positions prior to the abol-
ishment of PACE. Agencies must follow standard, OPM prescribed
procedures in making appointments under any of these methods.
We therefore did not review the selection procedures used under
these methods to determine if they complied with the merit prin-
ciple for employee selection. However, since Schedule B PAC is
new, we reviewed the descriptions of the procedures used by our
four survey agencies to select candidates for Schedule B PAC
appointments. We found no indication that these selection pro-
cedures violate the requirements of merit selection under 5
U.S.C. 2.301. They all provide for what appears to be open com-
petition and a means of determining qualified candidates. It
should be noted, however, that simply because a selection proce-
dure conforms to merit requirements, there is no guarantee that
during the actual selection process merit abuses will not
occur. Still, personnel officials from the agencies we contact-
ed and OPM told us that, to their knowledge, no complaints or
grievances relating to.Schedule B PAC selection practices had
been made.
The Merit Systems Protection Board, which is responsible
for safeguarding the merit system against abuses, reported on
Schedule B PAC in its annual report on the significant actions
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of OPM during calendar year 1982.5 The Board concluded that
there may be an increased opportunity for merit abuse because of
the "multitude" of agency-developed procedures that will be used
to examine and select applicants. OPM waived the standard
Schedule B requirements to allow agencies more flexibility in
complying with the consent decree. Similarly, in a report on
PACE and the consent decree, a panel of the National Academy
of Public Administration concluded, among other things, that the
use of Schedule B PAC invites abuse, such as vulnerability to
personal and political influence in appointments. Personnel
officials of the agencies we visited believe that their selec-
tion practices conform to merit principles, but they also
believe that the variety of selection procedures increases the
opportunity for abuse.
IS SCHEDULE B PAC AN
ADEQUATE REPLACEMENT FOR PACE?
Since use of the Schedule B PAC has been relatively limited
to date, we believe that its overall impact will not be known
for some time. However, in the opinion of personnel officials
from the agencies we visited, the Schedule B PAC provided by
OPM, while having advantages, such as more flexibility in re-
cruiting, will not be an adequate replacement for PACE unless a
procedure is provided for converting Schedule B PAC hires to the
competitive service.8 Schedule B PAC appointments are in the
excepted service9, and appointees do not have competitive
5Report on the Significant Actions of the Office of Personnel
Management Durin 1982, U.S. Merit Systems Protection Board,
December 19 3.
60PM's regulations (5 C.F.R. Part 302, Subparts C and D) uniform procedures that agencies must follow in acceptingrandde
rating applications for employment and in selecting and
appointing employees.
7The Selection of College Graduates for the Federal Civil
Service: The Problem of the "PACE Examination and the Consent
Decree, Panel of the National Academy of Public Administration,
March 1984.
8The competitive service consists of all civilian positions in
the federal government
hi
w
ch are not specifically excepted from
the civil service laws by statute, by the President, or by OPM.
9The excepted service consists of those civil service positions
which are not in the competitive service.
5
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status1? and cannot be noncompetitively promoted beyond'the
GS-7 level or reassigned to positions not covered by the author-
ity. Schedule B PAC employees may be converted to a competitive
service appointment only after successfully competing through a
competitive examining process. The agency personnel officials
believe that the competitive registers will be blocked by pref-
erence eligibles11 who are not in Schedule B PAC positions.
The officials believed they may, as a result, be unable to con-
vert and promote large numbers of their Schedule B PAC employees
to competitive service GS-9 positions. OPM, on the other hand,
believes that because of the experience gained in their PAC
positions, most Schedule B PAC employees will be able to compete
successfully through the competitive examining process. OPM
therefore sees no need for a special conversion procedure.
Whether problems will occur in promoting the Schedule B PAC em-
ployees is not known-at this time since, according to an OPM
official, the majority of the initial Schedule B PAC appointees
are not expected to be eligible for promotion until late in
calendar year 1984.
WHAT ARE OPM'S PROCEDURES FOR OVERSIGHT
OF AGENCY USE OF SCHEDULE B PAC AUTHORITY?
Before approving agency requests for Schedule B PAC, OPM
reviews the adequacy of the information submitted, requests
clarification or additional information when necessary, and
checks with its area offices to verify whether the agencies con-
sidered hiring federal employees who had been or are scheduled
to be displaced from their jobs. According to OPM procedures,
agencies' use of Schedule B PAC will be monitored and evaluated
by reviewing agency reports required by the consent decree, data
from OPM's Central Personnel Data File, and its evaluations of
agency personnel management operations. OPM officials informed
us that OPM does not plan to separately study Schedule B PAC.
Schedule B, as well as other hiring authorities, was reviewed as
part of a broad personnel management evaluation study relating
to federal government staffing practices which was conducted by
OPM's Office of Agency Compliance and Evaluation in the second
"Competitive status is a person's basic eligibility for noncom-
petitive assignment to a position in the competitive service
without open, competitive examination for the position.
"Preference eligibles are individuals who have been honorably
discharged from a period of active military service; also
included are wives, husbands, inlaws, widowers, and mothers of
certain veterans. These individuals receive additional points
on competitive examinations depending on their veteran's
category.
A
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quarter of fiscal year 1984. This office is responsible for
conducting evaluations of agency personnel management prac-
tices. A report on the results of the study is due at the end
of calendar year 1984.
As requested by your office, we did not obtain agency com-
ments on this report. Also, as arranged with your office, un-
less you publicly announce its contents earlier, we plan no
further distribution of this report until 30 days from the date
of the report. At that time, we will send copies to interested
parties and make copies available to others upon request.
Sincerely yours,
William J. Anderson
Director
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APPENDIX I
APPENDIX I
FILLING PROFESSIONAL AND ADMINISTRATIVE
CAREER POSITIONS BEFORE AND AFTER PACE
OBJECTIVES, SCOPE, AND METHODOLOGY
The Chairwoman, Subcommittee on Civil Service, House Com-
mittee on Post Office and Civil Service, asked us to obtain in-
formation on appointments made to PAC Positions before and after
the abolishment of PACE. As requested, we directed our efforts
at answering five sets of questions. r
--How many and what types of positions in each agency used
to be filled through PACE? Have those same types of jobs
been filled since the PACE was ended? How many have
filled, by agency? What selection devices have been been
used?
--What is the demographic makeup of employees hired under
successor authorities to PACE?
--For each procedure currently in use for filling which used to be filled by PACE, does the selection de-
vice vice meet the requirements of merit selection under 5
U.S.C. 2301?
--Is the Schedule B hiring authorit
regulation adequate to replace PACEArovided by OPM
--How does OPM insure that agencies
(a) comply with the
to receive Schedule B hiring authority, (b) once that authority is received, carry out their and
appointment responsibilities consistent with applicable
laws and regulations?
In conducting our work, we reviewed laws, regulations,
OPM's and selected agencies' guidance relating to a
methods, as well as agencies' selection procedures curreentlyt
used to fill PAC Positions formerly filled through PACE.
reviewed past GAO reports on related subjects such as
the PACE and the Uniform Guidelines on Employee Selection
Procedures.l We also reviewed reports by the Merit Systems
1Federal Em to ment Examinations: Do The Achieve
tunity and Merit Princi e Goals? ual 0 and
form Guidelines on Em o ee(Selection6, May ures ;
Be Reviewed and Revised (GAO2FPCD-82-26 May 15, 1979);
Should
July 30, 1982),
1
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Protection Board and the National Academy of Public Administra-
tion2 that discussed the advantages and disadvantages of the
Schedule B PAC hiring authority.
Further, we interviewed officials at OPM and four selected
federal agencies--the Departments of Navy and Health and Human
Services, the Defense Logistics Agency, and the Internal Revenue
Service--about the questions raised by the Chairwoman. These
four agencies were selected because, as of October 1983 when we
began our survey, they had authority to fill about 77 percent of
the total number of approved Schedule B PAC positions. We also
discussed Schedule B PAC with officials at the Department of .
Defense and the Merit Systems Protection Board's Merit Systems
Review and Studies Office.
At OPM, we reviewed the files containing agency requests
for Schedule B PAC and other related documents to determine and
verify OPM procedures for granting approvals to make appoint-
ments to PAC positions under Schedule B. We also obtained sta-
tistics from OPM, without independently verifying their accu-
racy, on (1) the number and type of PAC positions filled, by
agency, (2) how these positions were filled before and after the
PACE was abolished, and (3) demographic data on employees hired
after PACE was abolished. Most of these data were taken from
OPM's Central Personnel Data File and, according to an OPM offi-
cial, were the most current and accurate information available
as of March 1984.
As requested by your office, we did not obtain agency com-
ments on this report. Our survey, conducted from October 1983
through March 1984, was performed in accordance with generally
accepted government auditing standards.
BACKGROUND
The federal government uses a variety of methods to fill
vacancies in GS-5 and -7 entry level PAC positions. These
include internal promotions and reassignments, transfers from
2Report on the Significant Actions of the Office of Personnel
Management During 1982, U.S. Merit Systems Protection Board,
December 1983; and The Selection of College Graduates for the
Federal Civil Service: The Problem of the "PACE" Examination
and the Consent Decree, Panel of the National Academy of Public
Administration, March 1984.
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APPENDIX I
APPENDIX I
other federal agencies, priorit
ing new employees. PAC a y placement programs,3 and hir-
tions have ranged from 58p483ninefiscal these entry level
the last three quarters of fiscal year 1979 posi-
year 1982. , to 26,451 in
From 1974 until its abolishment in August 1982, the princi-
pal device for examining and selecting new l
for GS-5 and GS-7 entry level PAC g government Cmpoyees
was a written positions was the PACE. It
u a w, competitive ivsexamintion. The number of PAC hires
three quarters of fiscal year 1982. 1979 and 1,472 in the last
ent career occupations were covered bone hundred twenty differthe -
tions are nonclerical in nature and involveeregulatorse occupa-
compliance work, administrative and management functions,ldclai
and benefit examining, investigative and law enforcement duties,
ms
and social services work. See appendix
for a list of pACes,
occupations formerly filled through PACE.
The PACE was abolished as a result of a consent decree
negotiated in the case of Luevano v. Devine. The eti of
this consent decree was to 'eliminate adadse impactbincthee hir-
ing of blacks and hispanics for
The decree required positions filled through PACE.
, in
development of tipea
ret,xamithneiphout of PACE and the
idly and fairly test the relative capacitydofea which would val-
val-
form
form in PAC occupations. PPlicants to per-
abolished PACE in August 1982
Schedule B4 appointing authorit and established a new
external hiring of employees for entrydlevel PAC) to do in
These positions were covered by y positions.
PACE ished. Thus far, no alternative competitivetexaminings roce-
g ce-
dures have been developed. OPM decided that the Schedule Positions should be excepted from the competitive service
because 1 B PAC
( ) there were no alternative written tests; (2re-
strictions in federal employment would result in substantially
aexternal hires in many ally
the cost of develo former PACE occupations;
sistent with the consentadeareedwouldebetirohexaminationsa
ndcon3)
for occupations where relatively few hires arebexpected. OPM
ally
PM
3Priority placement
programs federal employees whohaveeeithernbeenoorearefschcdedduelwed to
s
be displaced from their positions through no fault of jobs
own. their
4Schedule B authority covers
mined that it is not positions for which OPM has deter-
tion. Authorization to a usecSchedulelB mustmbetreque usteded from
and approved by OPM. om
m
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APPENDIX I I . . APPENDIX I
believed that agencies could fill most vacancies that arise
either through internal placement, reinstatement of individuals
with civil service status, or through priority placement pro-
grams. When external hiring is considered necessary, agencies
may be granted Schedule B authority if they demonstrate to OPM
that the positions cannot be filled through the other sources.
Employees hired under Schedule B PAC do not have competi-
tive status and cannot be noncompetitively promoted beyond the
GS-7 level or reassigned to positions not covered by the author-
ity. Schedule B PAC appointees may be advanced to the GS-9
level and converted to a competitive position only after they
undergo some form of competitive examining procedure and suc-
cessfully compete with other applicants for a position vacancy.
Pay, retirement, health benefits, life insurance, and leave
accrual provisions for Schedule B PAC employees are the same as
for competitive service employees. Also, agencies must observe
veterans preference in making Schedule B PAC appointments.
RESPONSES TO QUESTIONS
CONCERNING FILLING PAC POSITIONS
This section identifies the Chairwoman's questions relating
to appointments to PAC positions and provides details on the in-
formation we developed.
How many and what types of positions in each agency used to be
filled through PACE? Have those same types of jobs been filled
since the PACE was ended? How many have been filled, by
agency? What selection devices have been used?
What is the demographic makeup of employees hired under
successor authorities to PACE?
According to OPM officials, data showing the number and
types of PAC positions in each agency formerly filled through
the PACE were not available. However, governmentwide data on
PAC positions formerly filled through PACE were available along
with selected demographic data on PAC employees. Summaries of
this information are contained in appendix III.
For each procedure currently in use for filling positions which
used to be filled by PACE, does the selection device meet the
requirements of merit selection under 5 U.S.C. 2301?
Title 5 U.S.C. section 2301 enumerates the merit system
principles which are intended to serve as guides to federal
agencies in conducting their personnel management activities.
The principles apply to the full range of personnel processes
and decisions including recruitment, selection, advancement,
pay, and training.
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APPENDIX I
With respect to the requirements of merit selection, sec-
tion 2301(b)(1) provides that:
. . selection . . . should be determined solely on
the basis of relative ability,
after fair and open competitionwhichdassures thatlall
k
receive equal opportunity."
Most of the PAC positions filled since the PACE was
abol-
ished were filled by methods other than Schedule B PAC. Thes
methods, such as abol-
met1 d promotions and reassignments, were also usedeto
mist PAC positions prior to the abolishment of PACE. Agencies s
ard mppoifo o mlots t tandr do
y of these OPM prescribed procedures in making
therefore did not
review the selection procedures used under We these m
determine if they complied with the merit et fors to
selection. However, we did review descriptionslofethe for employee
dures used by the four agencies surveyed to select candidates
for Schedule B PAC P e
for Schell Positions and discussed the Schedule B PAC
seletion practices with officials at these agencies. We found
no indication that these selection
requirements of merit selection underTitlee5 U.S.C.v2301. the
o
all provided for what appeared to be open competition and They
a
means of determined cg from the agencies we contacted anddOPMtssOffice o
Compliance and of oweedy
Compliance aEvaluation told us that, to F their thek r, oofficials
ge,
grievances relating to Schedule BPAC selectiono
practices had been made.
It should be noted
tion
ion procedure appears , however, that simply because a selec-
no to conform to merit requirements, there
guarantee that during the actual selection
abuses will not occur. Some concern has been expressed tat
under Schedule B PAC, process merit
abuses because differing selection opportunity exists forhmerit
OPM waived the Schedule B regulatoryrrequirements5boin
for Schedule B PAC appointments g used.
eiity on sr
fxSchedul iB PAC anto give agencies ge t
decree. As a plying with thte requirements oftheconsent
resultr agencies procedure(s) they believePwould best meet e to use wheirvp
ticular needs.
arr-
p
The Merit Systems Protection Board and a panel of the
National Academy of Public Administration expressed concern
about the potential for merit abuse under Schedule B PAC.
In
55 C.F.R., Part 302, Subpart C--Accepting, Rating, and Subpart D--Selection and Appointment. T
n~ and Arranging
provisions set out uniform procedures that agencies must follow
in selecting and appointing employees.
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its annual report on the significant actions of OPM for calendar
year 1982, the Board reported on the establishment of Schedule B
PAC and concluded that:
of
the weakest link in this newly formed segment
of the merit system chain is likely to be contained in
the multitude of agency-developed recruitment and
selection strategies or procedures that will be used
under the new Schedule B authority."
In the Board's view, the weakness is caused by the dispersion of
responsibilities and the wide variety of formal and informal
agency selection procedures. The Board concluded that this sit-
uation increases the opportunity for and the potential incidence
of merit abuses and the commission of prohibited personnel
practices. Similarly, in a report on the PACE and the consent
decree, the Academy panel concluded, among other things, that
the use of Schedule B PAC invites abuse, such as vulnerability
to personal and political influence in appointments. The Board
plans to continue monitoring the effects of the abolishment of
PACE and will report again on the use of the new Schedule B PAC
in its next annual report, which will focus on the significant
actions of OPM in calendar year 1983.
Is the Schedule B hiring authority provided by the OPM regula-
tion adequate to replace PACE?
Since the use of Schedule B PAC has been relatively limited.
to date, we believe that its overall impact will not be known
for some time. We did, however, obtain the views of selected
agency officials on the use of Schedule B PAC as a replacement
for the PACE. In the opinion of the personnel officials from
our survey agencies, Schedule B PAC, while having advantages,
will not be an adequate replacement for PACE unless a viable
procedure is provided for converting the Schedule B PAC hires to
the competitive service. The agency officials cited the
inability to noncompetitively convert Schedule B PAC employees
to the competitive service or promote them beyond the GS-7 level
as the major disadvantage of Schedule B PAC. On the other hand,
these officials indicated that a major advantage of Schedule B
PAC is the increased flexibility it allows in recruiting and
selecting PAC employees.
According to OPM regulations, Schedule B PAC employees may
be converted to a competitive service appointment after success-
fully competing through a competitive examining process. Agency
personnel officials with whom we spoke believe that the competi-
tive registers will be blocked by preference eligibles who are
not in Schedule B PAC positions. These officials believed they
may, as a result, be unable to convert and promote large numbers
of their Schedule B PAC employees to competitive service GS-9
6
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APPENDIX I
APPENDIX I
Positions. That is, the Schedule B PAC employees may not be
within reach on competitive registers because the preference
eligibles will likely be at the top of most register certifi-
cates. OPM, on the other hand, believes that most Schedule B
PAC employees will be able to compete successfully through the
competitive examining process because of the specialized experi-
ence and training gained in their PAC positions.
Because of the concern about potential conversion problems,
the Department of Defense (DOD) developed a proposed executive
order which would allow the non-competitive conversion of its
Schedule"B PAC employees to the competitive service. Conversion
would be predicated, in part, on satisfactory demonstrated possession of the skills, knowledge,andaabilities
required to perform successfully at the GS-9 level; and the
agency's recommendation for conversion. However, we were told
by a DOD official that after several unsuccessful attempts to
obtain OPM's support, the Department decided not to pursue the
matter further. OPM's position is that a special conversion
procedure should not be considered unless there are actual
problems. Since, according to an OPM official, the majority of
the initial Schedule B PAC appointees will not be eligible for
promotion to the GS-9 level until late 1984, it is not known at
this time whether problems in promoting them will occur.
Several other problems associated with Schedule B PAC were
also cited by agency officials we interviewed. These included
the following.
--The lengthy process of requesting and obtaining aP
to make appointments under Schedule B PAC. Under thisal
authority, an activity must submit the request through
its agency headquarters to OPM's central office.
--The lack of a governmentwide application point for
applicants wishing to either obtain information about or
be considered for a PAC position vacancy.
--The increased potential for abuse because agencies have
developed and are using varied recruiting and selection
procedures. For example, there could be increased
opportunity to make appointments on the basis of personal
or political patronage.
According to personnel officials at the surveyed agencies,
Schedule B PAC allows increased flexibility to recruit and
select individuals to fill PAC positions.
this increased flexibility as the major advaThese ntageoof1ScheduleeB
PAC. Agencies are allowed, within the guidelines set by OPM and
in accordance with applicable regulations, to establish recruit-
ment and selection procedures to suit their particular needs.
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APPENDIX I APPENDIX I
Agency officials stated that they can establish recruitment pro-
cedures which will give them more flexibility in meeting their
hiring goals. For example, agencies can direct their recruiting
efforts to schools which are likely to yield qualified minor-
ities and women. The result, according to these officials, is a
more diverse work force.
Agency officials cited two other advantages of Schedule B
--There should be fewer declinations after job offers are
made since applicants are applying for a specific job. in
a particular agency.
--Line managers will be more directly involved in the
actual recruitment and selection process.
OPM has also expressed some concern about the use of Sched-
ule B PAC as a replacement for PACE. In announcing the abolish-
ment of PACE and the planned establishment of the new Schedule B
PAC, the Director, OPM stated that:
"This is not an ideal solution for filling profession-
al administrative positions in the Federal Government
Nevertheless, this is the best available so-
lution, given the very tight constraints imposed by
the decree."
It was OPM's opinion at the time PACE was abolished that the
development of alternative examinations to PACE would be both
extremely costly and time-consuming.
OPM officials informed us that job specific examinations
are being developed for five PAC occupations which have large
numbers of hires: tax technician, social insurance claims rep-
resentative, social insurance claims examiner, customs inspec-
tor, and internal revenue officer. These examinations are at
various stages of development, but OPM officials could not pro-
vide any firm estimates as to when they might be implemented.
In addition, OPM officials stated that OPM has no definite plans
on the type of examining procedure(s) that may be developed for
the remaining PAC occupations. According to an OPM official,
the development of the alternative examinations has been and may
continue to be hindered by a lack of sufficient staffing. (The
size of the staff working on the development of the examinations
was reduced by about 50 percent in a 1982 reduction in force.)
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rAP .
PENDIX I
How does OPM insure that agencies comply with the requirements
to receive Schedule B hiring authority?
In its Federal Personnel Manual instructions on Schedule B
PAC, OPM specified certain conditions that agencies must meet
before it will grant Schedule B PAC. Prior to requesting the
authority, agencies are required to make maximum use of internal
priority placement programs as well as the two priority place-
ment programs administered by OPM--the Displaced Employee Pro-
grain (DEP) and the Interagency Placement Assistance Program
(IPAP)--and give appropriate consideration to available and
qualified candidates with civil service status (candidates
available for promotion, reassignment, transfer, or reinstate-
ment to PAC positions).
As a means of ensuring adherence to these requirements, OPM
requires that all requests for Schedule B PAC be submitted
through the agency's headquarters to OPM's central office.
According to OPM officials, after the requests for Schedule B
PAC are received, OPM reviews them and other related documents
submitted by the agencies to make sure that the agencies have
provided the required information. Agencies must indicate the
position(s) for which authority is needed; the use made of DEP
and IPAP lists, merit promotion programs, reemployment, and
repromotion priority lists; and other sources of candidates with
civil service status. They must also state how veterans pref-
erence will be applied.
OPM does not, however, verify that agencies have met all
the requirements to receive Schedule B PAC. OPM's policy is to
accept the agency's statements with regard to consideration
given priority placement eligibles and other status candidates
unless those statements contain obvious conflicts or information
that appears implausible or inconsistent. Although they are not
required to, some agencies will submit various other documents,
such as merit promotion vacancy announcements, to demonstrate
that they have pursued internal sources before requesting
Schedule B PAC. OPM verifies that agencies have contacted the
appropriate OPM area office for DEP/IPAP candidates. If consid-
eration of DEP/IPAP and status candidates or the provision for
veterans preference appears inadequate, OPM requires the agency
to take further action or provide clarification or additional
information before the Schedule B PAC request will be approved.
For example, an agency could be required to check with one of
OPM's area offices for DEP/IPAP candidates or to provide infor-
mation regarding how it plans to apply veterans preference in
making Schedule B PAC appointments. On the basis of its review
of the request and the agency's demonstration that external
hiring is appropriate, OPM then authorizes the use of Schedule B
PAC.
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Our review of the 79 agency requests for Schedule B PAC,
received by OPM as of the end of October 1983, confirmed that
agencies provided the required information and OPM verified the
agencies' use of the DEP and IPAP lists before approving
appointments under Schedule B PAC.
How does OPM insure
that
agencies, once Schedule B authority is
received, carry out
their
appointment responsibilities consis-
tent with applicable
laws
and regulations?
According to OPM procedures, Schedule B PAC monitoring and
evaluation activities include reviewing agency reports required
by the consent decree, data from OPM's Central Personnel Data
File, and its evaluation of agency personnel management opera-
tions. OPM officials informed us that there are no plans to
conduct any separate studies or evaluations regarding the use of
Schedule B PAC. Rather, Schedule B PAC was reviewed in the
second quarter of fiscal year 1984 as part of a broad personnel
management evaluation study relating to federal staffing prac-
tices conducted by OPM's Office of Agency Compliance and Evalu-
ation (ACE).
OPM's current personnel management evaluation program is
designed to provide information on the current status of
governmentwide personnel programs and related personnel policy
issues. Under its revised evaluation approach and methodology,
ACE developed a 5-year plan which it believes will permit OPM to
generalize governmentwide about the results of ACE's evaluation
work. Previously, ACE's work was basically limited to evaluat-
ing the personnel management programs of individual agency in-
stallations. Over a 5-year period, fiscal years 1984 to 1988,
ACE plans to gather baseline information on five personnel
management issues: position classification; position manage-
ment; staffing (which includes appointing authorities such as
Schedule B PAC); performance management; and personnel adminis-
tration. This will be accomplished through 1 day, on-site
visits at approximately 4,000 government installations over the
5-year period.
As part of this new evaluation approach, ACE will conduct
quarterly studies of aspects of the five personnel management
programs. In this respect, one study, which was conducted in
the second quarter of fiscal year 1984, addressed how the fed-
eral government appoints and promotes its employees. Specifi-
cally, the study examined the various ways hiring authorities
(including Schedule B PAC) are administered, the results they
achieve, the costs they incur, and whether they are in com-
pliance with applicable laws and regulations. A report on the
results of the study is due at the end of calendar year 1984.
According to ACE's evaluation program plan, a more detailed,
compliance type review would be conducted in any area, for
example, the use of Schedule B PAC, if systemic problems are
identified during the general evaluation phase of a study.
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APPENDIX II
APPE;NT'i?X II
PAC OCCUPATIONS FORMERLY FILLED THROUGH PACE
Series Title
Series
011 Bond Sales Promotion 222
018 Safety Management 223
020 Community Planning
023 Outdoor Recreation 230
Specialist
025 Park Management 233
*027 Crop Insurance 235
Administration 244
(except for field man
and field specialist 246
positions)
028 Environmental 249
Protection
080 Security Administration 301
101 Social Science
105 Social Insurance *334
Administration
106 Unemployment Insurance 341
*110 Economist 343
120 Food Assistance Program 345
130 ForeignaAffairs 346
131 International Relations 393
132
Intelligence
140 Manpower Research and
Analysis
142 Manpower Development 526
150 Geography
170 History **570
0
180 P
h
syc
ology
184 Sociology
187 Social Sciences
190 General Anthropology 685
193 Archeology
201 Personnel Management 950
205 Military Personnel 962
Management 965
212 Personnel Staffing 967
221 Position Classification
Title
Occupational Analyst
Salary and Wage
Administration
Labor Management and
Employee Relations
Labor Relations
Employee Development
Labor Management
Relations Examining
Contractor Industrial
Relations
Wage and Hour
Compliance Specialist
General Clerical and
Administrative
Computer Specialist
(Trainee)
Administrative Officer
Management Analysis
Program Analysis
Logistic Management
Communications
Specialist
General Accounting
Clerical and
Administrative
Tax Technician
Budget Administration
Financial Institution
Examininga
Hospital Housekeeping
Management
Public Health Program
Specialist
Paralegal Specialist
Contact Representative
Land Law Examining
Passport and Visa
Examining
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PAC OCCUPATIONS FORMERLY FILLED THROUGH PACE
Series Title Series
987 Tax Law Specialist
990 General Claims
Examining
991 Workmen's Compensation
Claims Examining 1150
993 Social Insurance 1160
Claims Examining 1163
994 Unemployment Compen- 1165
sation Claims 1169
Examining
996 Veterans Claims 1170
Examining 1171
997 Civil Service Retire-
ment Claims Examining 1173
1001 General Arts and 1176
Information (Fine *1410
and Applied Arts
positions are
excluded)
1015 Museum Curator
1035 Public Affairs 1420
1081 Public Information 1421
1082 Writing and Editing *1654
1083 Technical Writing 1701
and Editing
1101 General Business and 1715
Industry
1102 Contract and
Procurement
1103 Industrial Property */**1810
Management 1811
1104 Property Disposal
1130 Public Utility
Specialist
1140 Trade Specialist
1145 Agriculture Program
Specialist
1146 Agriculture Marketing
1147 Agricultural and
Title
Fisheries Marketing
Reporter
Wage and Hour Law
Administration
Industrial Specialist
Financial Analysis
Insurance Examining
Loan Specialist
Internal Revenue
Officer
Realty
Appraising and
Assessing
Housing Management
Building Management
Librarian (for certain
trainee positions at
GS-5)
Technical Information
Services
Archivist
Archives Specialist
Printing Management
General Education
and Training
Vocational Rehabili-
tation (GS-7 only)
Education Research and
Program Specialist
General Investigation
Criminal Investigation
(except for Treasury
Enforcement Agents)
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APPENDIX II
APPENDIX II
PAC OCCUPATIONS FORMERLY FILLED THROUGH PACE
Series
*1812
**1816
1831
1854
*1860
1864
1889
1RAn
2001
2003
Title Series
Game Law Enforcement
(GS-5 only)
Immigration Inspectionb
Securities Examining
2010
2030
Compliance 2032
Alcohol, Tobacco, and 2050
Firearms Inspection 2101
Public Health *1135/2110
Inspection
Public Health 2111
Quarantine
Inspection
Import Specialist
Customs Inspection
Customs Marine Officer
Quality Assurance
Specialist
General Supply
Supply Program
Management
Title
Inventory Management
Distribution Facilities
and Storage
Management
Packaging Specialist
Supply Cataloging
General Transportation
Transportation Industry.
Analysis
Transportation Rate and
Tariff Examiner
Highway Safety
Management
Traffic Management
Cargo Scheduling
Transport Operations
*These PAC occupations which were abolished or removed from
coverage of PACE prior to the effective date of the consent
decree were not subject to Schedule B PAC at the time of our
survey.
**These PAC occupations which are competitively filled by
agencies having delegated examining authority were not subject
to Schedule B PAC at the time or our survey.
aThe Federal Deposit Insurance Corporation and Federal Home
Loan Bank Board have delegated examining authority for GS-5
positions and GS-5/7 positions, respectively.
bThe delegated examining authority for this PAC occupation
covers GS-5 positions only.
13
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PAC APPOINPMENTS UNDER PACE
FISCAL YEARS 1979 THFOUGH 1982
Fiscal Year 1979 Fiscal Year 1980
Fiscal Year 1981
Fiscal Year
1982
Number of Number of
Number of
Number of
Occupational Series and Group
Appointments
Percent Appointments
Percent
Appointments
Percent
Appointments
Percent
000
Miscellaneous Occupations
Group
75
1.6
89
2.1
76
2.5
15
1.0
100
Social Science, Psychology,
and Welfare Group
796
17.3
652
15.7
136
4.5
15
1.0
200
Personnel Management and
Industrial Relations Group
125
2.7
137
3.3
73
2.4
13
.9
300
General Administrative, Clerical,
and Office Service Group
628
13.6
766
18.4
361
11.9
106
7.2
500
Accounting and Budget Group
553
12.0
530
12.8
198
6.5
37
2.5
600
Medical, Hospital, Dental,
and Public Health Group
26
.6
49
1.2
10
.3
24
1.6
900
Legal and Kindred Group
823
17.9
592
14.3
1,100
36.2
433
29.4
1000
Information and Art Group
68
1.5
66
1.6
55
1.8
13
.9
1100
Business and Industry Group
776
16.8
615
14.8
582
19.1
698
47.4
1400
Library and Archives Group
36
.8
19
.5
8
.3
6
.4
1600
Equipment, Facilities, and
Service Group
3
.1
0
.0
0
.0
0
.0
1700
Education Group
10
.2
1
.0
9
.3
0
.0
1800
Investigation Group
306
6.6
281
6.8
108
3.5
22
1.5
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PAC APPOINVENTS UNDER PACE
FISCAL YEARS 1979 THPOUM 1982
Fiscal Year 1979
Fiscal Year 1980
Fiscal Year 1981
Fiscal Year 1982a
Number of
Number of
Number of
Number of
Occupation Series and Group Appointments Percent
Appointments
Percent
Appointments Percent
Appointments Percent
1900 Quality Assurance, Inspection
and Grading_Group 129 2.8
142
3.4
127 4.2
4 .3
2000 Supply Group 229 5.0
179
4.3
173 5.7
84 5.7
2100 Transportation Group 23 .5
32
.8
- 25 .8
2 .2
Total 4,606 100.0
4,150
100.0
3,041 100.0
1,472 100.0
aIncludes only those appointments made in the last three quarters of fiscal year 1982.
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APPOINPMENTS'a BY RACE AND NATIONAL ORIGIN
b
AFTER THE ABOLISHMENT OF PACE
ro
OCTOBER 1, 1982 TO JUNE 30, 1983
Z
White
Black
Hispanic
Other
ointment Method
A
Number
Percent
Number Percent
Number
Percent
Number Percent
Total
pp
Promotion
8,630
73.3
2,145
18.2
653
5.5
353
3.0
11,781
H
H
H
Reassignment
5,509
74.3
1,322
17.8
359
4.9
223
3.0
7,413
Reinstatement
519
73.6
111
15.8
56
7.9
19
2.7
705
Transfer
271
75.7
55
15.3
21
5.9
11
3.1
358
OPM Alternative Competitive Exams
401
84.4
40
8.4
16
3.4
18
3.8
475
PACE b
384
85.5
43
9.6
16
3.6
6
1.3
449
Schedule B PAC Authority
185
52.3
95
26.8
53
15.0
21
5.9
354
Veterans Readjustment Authority
177
71.1
47
18.9
13
5.2
12
4.8
249
Delegated Examining Authority
166
75.5
28
12.7
22
10.0
4
1.8
220
Direct Hire Authority
75
81.5
9
9.8
5
5.4
3
3.3
92
Cooperative Education Program
49
69.0
16
22.6
2
2.8
4
5.6
71
Bicultural/Bilingual Program
0
.0
0
.0
1
25.0
3
75.0
4
Outstanding Scholar Program
0
.0
0
.0
0
.0
0
.0
0
Federal Junior Fellowship Program
0
.0
0
.0
0
.0
0
.0
0
Other
3,209
76.8
567
13.6
216
5.2
186
4.4
4,178
Total
19,575
74.3
4,478
17.0
1,433
5.4
863
3.3
26,349
ro
z
aCovers appointments to GS-5 and GS-7 entry level positions only. Includes promotions, reassignments, reinstatements,
or transfers occurring when an individual moves from either a non-PAC occupation or another PAC occupation.
bPACE certificates could be used for a 60-day period after OPM announced the abolishment of PACE on September 9, 1982.
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SCHEDULE B PAC APPOINTMENTS
BY RACE AND NATIONAL ORIGIN TER
THE ABOLISHMENT OF PACE
OCTOBER 1, 1982 TO DECEMBER 31, 1983
Oct. 1, 1982 to June 30, 1983 July 1, 1983 to Dec. 30, 1983 Total
Number Percent Number Percent Number Percent
White 185 52.3 1,171 67.6 1,356 65.
Black 95 26.8 414 23.9 509 24.4
Hispanic 53 15.0 147 8.5 200 9.6
Other 21 5.9 - - 21 1.0
Total 354 100.0 1,732 100.0 2,086 100.0
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