COMMENTS ON PROPOSED(Sanitized) EMPLOYMENT OF CONSULTANTS AND EXPERTS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP78-04718A001300030016-9
• Release Decision: RIPPUB
• Original Classification: S
• Document Page Count: 2
• Document Creation Date: December 9, 2016
• Document Release Date: June 20, 2001
• Sequence Number: 16
• Publication Date: June 23, 1954
• Content Type: MF

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Approved For Release 2001/089ECRIEtDP78-04718A001300030016-9
ER 5-6479
MEMORANDUM FOR: Chief, Regulations Control Btsff
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Comments on Proposed EMPLOYMENT OF 25X1A
CONSULTANTS AND EXPERTS
1. Paragraph 1. of this RegulationAitates that it is not appli-
cable to covert consultants engaged on a special contract basis for
security or operational reasons. Unless there is to be a separate
and comparable regulation governing covert consultants, the infer-
ence is that none of the processing procedures, employment restric-
tions, compensation limitations, travel expense limitations, and
leave and retirement policies are applicable to covert consultants.
It is doubtful if this complete exemption is in fact Agency policy,
or whether it is even legally permissible. Possibly the intent is
to sake inepplicable certain of the provisions of the Regulation.
In any event I believe the intent should be thoroughly explored
and determined prior to publication.
2. I believe a certain amount of ambiguity is caused by the
inconsistent terminology used with respect to the engagement or
employment of consultants. In many paragraphs (2.a., 2.b.? 4.a., etc.)
we refer to ti&y*flt. ID 6.d.(/) we refer to appointment. In
6.d12) we say "engaged through a contract instrument." In paragraph
8.a. 5)(d) we refer to "Personal Service Contract - Form 37-53." Par-
ticularly in view of the fact that paragraph 1. attempts to exclude
covert consultants who are engaged on a special contract basis, I
believe we should avoid the use of the word contract in this Regula-
tion or use more specific language in excluding "special contract"
consultants. In reviewing the many differing words used for employ-
ment, engagement, etc., I believe the vords "am:Axiimmmit" and "employ-
ment* might be used more discriminitely to achieve maximum clarity
and precision.
3. Paragraph 6.c.(3)(b) needs editorial revision. As worded, the
pronoun 'he" used twice in the second sentence could refer to either
the Assistant Director for Personnel or the General Counsel.
4, Paragraphs 6.4., (1) and (2), would be greatly improved by
dividing the text as between the leave provisions and t ial
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Approved For Release 2001/08/1Q.' RDP78-04718A001300030016-9
Security and/or Civil Service retirement provisions As presently
written, paragraph 6.d.(1) appears to set forth the complete policy
regarding both leave and retirement, but then paragraph 6.d.(2) comes
along and modifies the entire picture. It would be more clear to
state all there is to be said about leave in one paragraph and in
the second to cover the matter of retirement and Social Security.
5. In connection with paragraph 6.d.(2), I do not understand
the last sentence. If, by any chance, it refers to covert consult-
ants engaged under special contract, we have already eliminated such
persons in paragraph 1. If we are referring to some other group or
possibly all consultants, the differentiation is not clear in vidir
of our lame language as to "employment," "engagement," and "Personal
Service Contracts."
6. In addition,to the above, I have made notations on pages 8
and 11 which reflect editorial suggestions pertaining either to
grammar or clarity.
25X1 A9a
Special Assistant to the
Deputy Director (Admin.)
SA/DECE
1 - DCA chronic
1.4
subject
Approved For Release 2001/08/10 : CIA-RDP78-04718A001300030016-9