Mr. Moss. This competitive promotion system is one of the most important we have in Government, is it not?

Mr. MACY. Yes, it is.

Mr. Moss. How closely does the Commission audit these systems in the various departments and agencies?

Mr. MACY. The Commission, through its regular inspection program, reviews the functioning of the merit promotion program in all of the agencies on roughly a 3-year cycle.

Mr. Moss. How adequate in your judgment are the present merit promotion programs?

Mr. MACY. I believe they are adequate, but I hasten to add, you can always improve programs of this kind."

Mr. Moss. In my office, they constitute one of the areas most frequently criticized by career employees because they are based frequently on performance ratings. Is that part of the Commission's judgment that they be so based?

Mr. MACY. I have not heard that criticism, but the Commission's standards call for the agency to develop measures that permit them to judge the relative merits of those who are qualified for promotion to a given position.

EMPLOYEE APPEAL RIGHTS

Mr. Moss. Is there a review, or appeal, or a grievance procedure available as a matter of course within the guidelines of the Commission in those instances where the employee feels the board has acted in a discriminatory manner?

Mr. MACY. There are appeal rights under every agency merit promotion program so there can be a review evaluation within the agency. Mr. Moss. Are those rights under the Executive order granting recognition to employee organizations broadened now?

Has the appeal procedure available under the Executive order, which became effective, I believe, on July 1 of this year, broadened the appeal right on promotion?

Mr. MACY. NO. My reference to appeal right on promotion is an appeal right to the agency, not to the Civil Service Commission. The appeal to the Commission is only on so-called adverse actions to the employee.

Mr. Moss. Denial of the opportunity of promotion is an adverse action, is it not, if it is a prejudiced action?

Mr. MACY. It may be in the eyes of the employee. However, the definition of "adverse action" has been demotion, discharge, or other actions that lead to loss of pay, grade, or status.

Mr. Moss. In view of the impact on morale, is the Commission satisfied with existing merit promotion procedures in the departments and agencies?

Mr. MACY. By and large, the answer is "Yes."

Mr. Moss. Are there any exceptions you can call to mind?

Mr. MACY. From time to time there appear to be cases where the plan as proposed is not administered as well as might be our desire. But I feel very strongly that the responsible manager should have the final decision with respect to the people who should be advanced in his organization.

Mr. Moss. Providing the standards are completely equitable?
Mr. MACY. Correct.

Mr. Moss. And insure equity to the employee?

Mr. MACY. And that the employee be given an opportunity to compete in terms of his capability for advancement to higher responsibility.

Mr. Moss. To what extent have you audited the effect of appeals taken to the agency on matters affecting promotion?

Mr. MACY. We review the agency operation. I do not believe our system is sufficiently detailed to go into the handling of individual

cases.

Mr. Moss. You can review the total of the appeals taken in an agency. Let's say a man's batting average is 100 percent and all appeals are denied, do you make that kind of review to determine what happens when an appeal is taken?

Mr. MACY. I do not have a conclusion definitive enough in my mind to give you a responsive answer. I would be happy to look into that if that would be helpful for the record.

Mr. Moss. You are familiar with my area?
Mr. MACY. Yes, indeed.

Mr. Moss. I have been interested for many years in some of these appeal procedures. You may recall I proposed a number of years ago to more nearly approximate some of the procedures used in my own State in the civil service, particularly in the area of promotion.

I have been impressed with the very high batting average of management on appeals. There is almost a uniform lack of merit in the employee case taken to appeal. I believe in one facility in my district I observed they really had a remarkable record because they were batting 100 percent. Regardless of how I tried, I could never quite equal that. I could not be right 100 percent of the time. Is the Commission concerned with this sort of thing?

Mr. MACY. Yes.

Mr. Moss. I think it has quite an impact on morale.

Mr. MACY. The Commission is concerned. The Commission periodically receives individual complaints from employees asking about this. I would say that since this program was launched in 1958 there has been marked improvement in the handling of competitive promotions within the Federal service.

You would be interested to know during my tenure as Executive Director we worked on the original development of this plan. Mr. Irons, my successor, claims the principal reason I left Government in 1958 is because I did not want to be around to implement the merit promotion plan as it is obviously fraught with problems.

In the final analysis, these have to be judgments of other individuals by supervisors. It is important that there be equity and it is important the system function so the most able people advance in Government and we do have a quality emphasis.

Mr. Moss. And the basis for this is to provide guidelines for the agency?

Mr. MACY. Yes.

Mr. BROOKS. Is the Commission satisfied with the present minimum qualifications for secretaries and typists?

Mr. MACY. The standards as written for the examinations for typists and stenographers represent the judgment of the Commission. I believe we constantly are striving to improve those standards, but based upon labor-market conditions at the present time, we feel the standards are as appropriate as they can be.

Mr. BROOKS. Despite the fact we find three agencies in this past year sent employees to non-Federal facilities for refresher training in stenography?

Mr. MACY. My view on that, Mr. Chairman, is this-I think we have to recognize that in many instances these skills, particularly the stenographic skill, requires refreshing in order to increase productivity, and particularly refreshing skill to deal with certain technical language that may be new to a particular stenographer.

ARE GRADE STRUCTURES IN NEW AGENCIES MORE LIBERAL?

Mr. BROOKS. Is there any basis, Mr. Chairman, for the belief that we find in many of the old line Government departments that the grade structures in Defense and other new agencies are more liberal? You hear this often. I am wondering what is the basis for this.

Mr. MACY. This is frequently alleged, and I think it is easily understandable that those who are in agencies that are fairly static feel that there are special advantages accruing to those in the newer agencies. But my feeling is, it is extremely difficult to compare with any degree of accuracy the grade structure of various departments and agencies because of the vast difference in the nature and complexity of the program responsibilities that they have.

One of the characteristics of a new agency is that it must be hiring people at all levels, whereas the agency that is fairly well-established is primarily advancing people from within and doing most of its hiring at the career entry point.

So this is an understandable complaint, but our feeling is that the agencies, both old line and new line, are to a very substantial extent adhering to the Commission's standards which, after all, do cut across agency lines.

I also think we have to recognize that in some of the new agencies like the Space Agency, a vast number of the jobs involve technical and scientific considerations which under our standards justify higher grades. This will tend, if you compare a distribution by grade level for a new agency of this kind and one of the older agencies, to show some difference apparently in favor of the newer agency. Mr. BROOKS. That is helpful.

One other thing on this matter of comparisons.

Are the grades of secretaries assigned supervisory personnel uniform throughout the Government?

Mr. MACY. Mr. Chairman, I think you are touching on what we frequently have referred to as the "halo" theory where the secretary's grade tends to reflect the level of her superior. Actually, the standards for secretaries are enunciated by the Commission, and the grade level of the secretary is dependent upon the actual content of her job. In some instances, a secretarial position for a high level position may be relatively restrictive as far as the duties and responsibilities are concerned, whereas on the other hand, a secretarial assistant may have rather broad responsibility for a lower level official. So I would say that again it is dependent upon the individual job as to what the classification level is.

Mr. BROOKS. Am I correct in the statement that these job classifications are written by the bosses?

Mr. MACY. Yes, sir.

89028-62-pt. 4

Mr. BROOKS. By the employers, so to speak?

Mr. MACY. The description of what the job contains is basically the responsibility of the person directing that job; that individual provides the information. The job description is written up and an evaluation is made by the person who has delegated responsibility for making such evaluations.

Mr. BROOKS. I have a copy here of a two-page job description for a GS-5 and a GS-6 secretary. It is one and a half pages, to be more accurate. It is a pretty involved analysis and if you compare this with the responsibilities of the President of the United States, according to articles 1 and 2 of the Constitution, which is only one page, it looks to me like it is a pretty detailed explanation of what one fairly attractive girl is going to be able to accomplish in an average week's work.

Off the record.

(Discussion off the record.)

Mr. BROOKS. On the record.

On the basis of this comparison, are you really generally satisfied with the system of determining classifications?

Mr. MACY. Yes. I think that the Federal classification system is one of the best job evaluation systems now in use.

Obviously, when you are dealing with 2 million jobs, there are going to be individual instances that can be scrutinized or satirized. I think we need constantly to work to improve the system and, in fact, one of our programs in the Civil Service Commission at the present time is to declare war on excess verbiage in these descriptions to see if we cannot put down just the essential language that gives us the necessary clues to permit proper evaluation.

There is a certain amount of mythology that grows up with respect to writing job descriptions. We have tried through our inspection program to liquidate that mythology and to train qualified individuals to prepare the descriptions so that they will accurately portray the responsibilities of the job and permit an accurate evaluation.

Mr. BROOKS. Regarding the 2,500 supergrade positions, do you ever disapprove any?

(Subsequently the agency furnished the following information, exhibit 4:)

EXHIBIT 4-DISAPPROVAL RATE ON REQUESTS FOR CLASSIFICATION OF POSITIONS IN GRADES GS-16, GS-17, AND GS-18, AUGUST 20, 1962

In connection with the increase of the number of positions in grades GS-16, GS-17, and GS-18 authorized by Public Law 87-367 (451), we evaluated 1,138 positions. Of this number 396, or 34.8 percent were evaluated at grades less than those proposed by the agencies.

Mr. MACY. Excuse me. May I supplement my comment on this? Mr. BROOKS. Surely. Go ahead.

Mr. MACY. I think it is important also that we recognize there is a requirement under this system that every year jobs be audited to determine whether or not the individual is actually performing what the job description says. This is a requirement. The agency has to certify that this has been done so that this is an important means of control.

Further, in the instance of the individual who just copies his job description, usually someone comes back and audits the job to make

sure that that is accurate before the final decision is made with respect to the classification.

Mr. BROOKS. That is the question. Is this always done?

Mr. MACY. The certification has to be given annually that there has been a review made.

Mr. BROOKS. Is it a routine, rubberstamp operation or is it actually accomplished?

ANNUAL REVIEW OF JOBS

Mr. MACY. I can say for the Civil Service Commission this is actually done every year. Every job is reviewed.

Mr. BROOKS. I thought earlier, as to determining the correctness of classifications, you said they only examined 3 to 4 percent of the positions.

Mr. MACY. May I clarify that?

Mr. BROOKS. Yes.

Mr. MACY. The Commission examines 4 percent of all positions as a part of its inspection. The agency head, however, is required to make an annual review of all jobs in his organization and certify that that has been done.

Mr. BROOKS. Do they give you a list of those they have found in error?

Mr. MACY. No.; they do not give that to us. They file a certification that this has been done.

Mr. BROOKS. I think it would be interesting to find out if any of them ever submitted they had 5,000 errors, 200 errors, or 50 errors in their classifications. I think when they make that certification, it might be interesting and the Commission might sort of get an estimate as to the accuracy of these classifications for them to give you an idea of the number of errors they found in classifications of these agencies when they do it, or since they do it, as you say.

Mr. MACY. In our own review, the 3 or 4 percent that we made, we find a very small percentage are in error and that, in some instances, the error is on the low side rather than on the high side.

Mr. Moss. The certification is made to the Civil Service Commission?

Mr. MACY. No, the certification is made by the personnel office to the head of the agency.

Mr. Moss. Only to the head of the agency?

Mr. MACY. That is correct, insofar as any certification to the Commission or elsewhere in the executive branch is concerned. However, each department and agency is required to make such a certification to the Post Office and Civil Service Committees and Appropriations Committees of the Senate and House of Representatives, in accordance with the Whitten amendment (sec. 1310 of the Supplemental Appropriation Act, 1952).

Mr. Moss. Not beyond that point?

Mr. MACY. That is correct.

Mr. Moss. Have you any responsibility in this matter of reviewing other than your 3 or 4 percent?

Mr. MACY. Again, in the course of our regular inspection, we review not only the 3 or 4 percent of the jobs, but we review the entire classification system. We check to see if this certification has been filed. We check to see the manner in which the classifica