identifiable, you know, where you are going to recruit your peopleif you are recruiting locally, that they are on a local basis-you relate these to your needs. We are not trying to say if this is being interpreted-it doesn't mean grade or number, it means organizational position, organizational unit.

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Mr. HAMPTON. In other words, if you had a regional office say given city and they had a hiring need for, say, 30 people, then their level of hiring for that year would be 30 people in that particular organization, and the skills needed out of those 30 positions would be so many clerk typists, so many budget analysts, whatever occupation it happens to be, so you set your goals on the basis of what your needs are at that particular level. This has the effect of broadening the scope of the affirmative action.

Mr. HAWKINS. I don't know why it should always be at the lowest practicable level, though.

Mr. HAMPTON. That is the section or a division or a branch.

Mr. HAWKINS. Still, I don't care, whatever the unit is, then the unit certainly must hire at some of the higher practicable levels as well as the lowest.

Mr. HAMPTON. We are not talking about that.

Mr. HAWKINS. I am getting a lot of answers, but I am not getting anything that makes any sense to me. The EEOC does exactly the opposite.

Mr. KATOR. I think this is consistent with EEOC and Department of Labor policy, as a matter of fact. I think our difficulty here is making clear what we mean by lowest practicable level. We mean the organizational unit for which you set your goals. One agency may have lots of different goals for example one for a regional office in St. Louis and one for an office in New York. What we are trying to say is, set your goals for that particular regional office and don't rely on some goal set in Washington. You have to set it at the regional level in this case because you know your hiring needs there and you know the skills in the recruiting area, what they are.

Mr. HAMPTON. It has nothing to do with the grade, grade 15's or whatever grade it may be, all grade 14's, all grade 13's, it has no relationship.

Mr. HAWKINS. Let me get back to this professional and administrative career examination. My understanding, in your general information in connection with that, is you require a college degree, or 3 years of professional experience, in connection with those who take that examination and yet you have, for example, over 340,000 women and about half of all of the minorities, in 17 low paying clerical occupations. I assume none of these could ever then apply to take this examination based on their experience unless some of them are Ph.D.'s and have other degrees that might allow them to do so. Just how then would these people have any upward mobility?

Mr. KATOR. Of those persons in the Federal service, they need not take the PAGE examination for upward mobility purposes. In fact, we don't even permit the use of that examination for promotional purposes.

Mr. HAWKINS. How would those in these lower clerical occupations benefit from an upward mobility program? Would you simply explain the mechanism for getting them into professional positions?

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Mr. KATOR. By training programs, restructuring jobs, setting up aide positions, and by developing new career ladders for people in deadend jobs. This is a significant part of our upward mobility program. It works, I believe.

Mr. HAMPTON. That is the whole thrust, to get away from the credentials idea.

Mr. KATOR. And the test.

Mr. HAWKINS. Have you any statistics then on the results of that training and that upward mobility mechanism which justifies the type of thing you are doing and what results you have been able to obtain? I think it would be good if you would provide it for the record. We don't have to go into it.

Mr. HAMPTON. We will give you the figures we have.

Mr. HAWKINS. I think any results would be of interest to the committee if you would file them, we would appreciate it. [Information referred to follows:]

AGENCY UPWARD MOBILITY ACTIVITIES

I. Examples of activities resulting in Upward Mobility for lower level employees (below GS-9 and equivalent).

As part of their EEO Affirmative Action plans, agencies are required to submit a summary narrative of Upward Mobility actions achieved for lower level employees (below GS-9 or equivalent) during the previous year. These reports show progress made toward goals established by each agency and describe, in a general way, the nature and level of efforts to provide meaningful, resultsoriented opportunities for lower level employees to advance in accordance with their potential.

The following are examples of such activity reported by agencies during 1974: Naval Material Command reported over 950 lower level employees in Upward Mobility programs.

Naval Air Systems Command Headquarters moved 68 non-professional employees into trainee positions leading to qualification for higher level target positions.

Army's White Sands Missile Range established specific target positions for nearly 200 employees and Redstone Arsenal enrolled 150 employees in Upward Mobility training toward jobs in 80 occupational series.

Department of Commerce reported 5,677 lower level employees enrolled in Upward Mobility programs.

GAO designated 89 positions for lower level employees to become qualified as management analyst assistants and claims adjudicator assistants.

Agriculture designated over 1,300 positions in 20 occupational series for Upward Mobiilty.

NIH entered 90 employees into technician or paraprofessional jobs leading to psychologist and physical therapist positions.

GSA, through a formal training agreement, selected 80 employees for training into accounting, computer, legal, archival, personnel and statistical career fields.

HEW's Audit Agency, through job restructuring, created new bridge positions in the Management Analyst and Management Assistant series for 24 lower level employees.

Some of these programs did not exist eighteen months ago. A number of other agency programs are operational or are evolving which are committed to real opportunities for lower level employees. Several other agency Upward Mobility programs are in earlier stages of development and are being reviewed by our staff to strengthen and expand such opportunities.

One major step toward improved Upward Mobility programs has been the development of more definitive guidelines which emphasize the critical role of effective planning. A copy of FPM Letter 713-27 is attached here for the Committee's information.

II. Formal training in support of Upward Mobility.

During FY 1974, Federal agencies reported 34,728 instances of developmental skills training conducted for employees who are below grades GS-9 and wage

grade equivalents. This activity reflects only formal training of eight hours or more duration. It represents approximately 30% of all Upward Mobility training offered by agencies. Not reported is a wide range of on-the-job training experiences which provide Upward Mobility trainees with qualifying skills knowledges and abilities within the work setting.

III. Nature of Upward Opportunities.

Of nearly 20,000 Upward Mobility opportunities recently reported by seventeen agencies, over 75% are directly related to actual or anticipated vacancies. In this mode of Upward Mobility, the employee is moved directly into a position by virtue of a training agreement or into a bridge position for which he or she qualifies and then trained to qualify for the target position. Some 4,200 other Upward Mobility opportunities provide training and developmental experiences toward skills for which the agencies have continuing need but for which there may be no specific target job.

FPM Letter No. 713-27

UNITED STATES CIVIL SERVICE COMMISSION,
Washington, D.C., June 28, 1974.

Subject: Upward Mobility for Lower Level Employees

PURPOSE

HEADS OF DEPARTMENTS AND INDEPENDENT ESTABLISHMENTS: Substantial progress has been made by Federal agencies to provide employees opportunities for Upward Mobility. Guidance to assist agencies in these efforts has been issued in such areas as training, job restructuring, skills utilization, testing and evaluation. This FPM Letter brings together pertinent provisions of these issuances and provides further assistance to agencies in planning and implementing Upward Mobility programs. It supplements EEO Affirmative Action planning and reporting requirements related to Upward Mobility contained in FPM Letter 713-22, dated October 4, 1973.

BACKGROUND

The Federal Government has its greatest investment in people. As an employer each Federal agency seeks to carry out its mission through people and thereby reach its established goals and purposes. People as employees also have goals and aspirations. When these two sets of goals can mesh and complement each other, mutual satisfaction results.

One of the areas in which employer and employee goals meet is Upward Mobility. It is through Upward Mobility that the agency and the worker move toward common goals.

Historically, the Federal career service has provided advancement opportunities for those who enter it. The career service is a comprehensive system including many career ladders, and provides for career counseling, career development and training opportunities, and merit competition for placement of qualified employees to move to higher level positions. Therefore, Federal employees have traditionally had certain Upward Mobility opportunities.

Upward Mobility opportunities must, of course, be available to all employees on a non-discriminatory basis. There are, however, direct implications for an agency's EEO program. By assisting employees, including minorities and women in lower graded positions to gain skills and thus advance within the system, Upward Mobility programs will have a positive impact on an agency's overall EEO posture.

AGENCY REQUIREMENTS

As a part of the affirmative actions to be included in their Equal Employment Opportunity plans, Federal agencies are required to develop and submit specific plans which will assure a continuing results-oriented, Upward Mobility effort. The recognition of Upward Mobility as an agency requirement is supported by two significant pronouncements. The President in Executive Order 11478 states that agencies must . . . "utilize to the fullest extent the present skills of each employee . . . and . provide the maximum feasible opportunity to employees to enhance their skills so they may perform at their highest potential and advance in accordance with their abilities."

The Equal Employment Opportunity Act of 1972 (P.L. 92-261) requires agencies to include in their annual EEO plan ". . . provision for the establishment of training and education programs designed to provide maximum opportunity for employees to advance so as to perform at their highest potential."

The law does not specify any minimum or maximum grade levels for Upward Mobility efforts. Generally, however, the greatest opportunity for impact is at the lower grade levels. Most agency programs, therefore, should focus on providing Upward Mobility opportunities for employees below the GS-9 (or equivalent) levels.

DEFINITION

To implement this concept of Upward Mobility for lower level employees in the Federal service, the following definition is established:

"Upward Mobility is a systematic management effort that focuses Federal personnel policy and practice on the development and implementation of specific career opportunities for lower level employees (below GS-9 or equivalent) who are in positions or occupational series which do not enable them to realize their full work potential."

Within this definition, Upward Mobility provides developmental opportunities to lower level employees which go beyond normal staff improvement practices. For example, the design of bridge and trainee positions which enable lower level employees to qualify for pre- or paraprofessional jobs is one means of providing Upward Mobility. Affording typing and related training to a GS-2 mail clerk who lacks qualification for an identified GS-2 or GS-3 clerk typist position, or providing required training for a typist to qualify for a targeted stenographic position are other examples of Upward Mobility. However, training and developmental efforts primarily designed to improve current occupational performance should not be regarded as Upward Mobility. Likewise, career intern, cooperative education, student employment, and other programs using outside recruitment are not examples of Upward Mobility for lower level employees. Each agency should apply these concepts to develop a variety of Upward Mobility opportunities adapted to its organizational and mission requirements.

PLANNING FOR UPWARD MOBILITY

Planning is critical to program success. It is essential that Federal Government organizations at every level follow a defined process to ensure that Upward Mobility plans will yield anticipated results. The recommended planning process is described in Attachment 1. A flow chart showing the sequence of the planning steps is appended as Attachment 2. Agency planners should review these two attachments carefully before developing their plans.

UPWARD MOBILITY PLAN REQUIREMENTS

Upward Mobility plans are submitted by agencies as an integral part of their EEO Affirmative Action plans. National Upward Mobility plans should describe the agency's total Upward Mobility effort and must contain instructions to field installations to plan for each of the following essential program elements: (1) identification of target positions

(2) application of merit procedures for selection of employees into Upward Mobility programs

(3) development and delivery of counseling services

(4) involvement of supervisors in program planning and implementation (5) design and delivery of required training (Attachment 1 of Appendix II to FPM Letter 713-22)

(6) development of evaluation and reporting procedures.

Additional assistance is available to agency planners through the Civil Service Commission's Office of Federal Equal Employment Opportunity.

Regional Upward Mobility plans submitted to CSC Regional Offices should contain the following specific information:

(1) total number of target jobs by occupational series and position title, to be filled through Upward Mobility during the plan year

(2) procedures for communicating with, counseling, selecting, and placing eligible employees

(3) descriptions of the training and developmental programs available to employees selected for Upward Mobility (Attachment 1 of Appendix II to FPM Letter 713-22 for format)

(4) evaluation and reporting procedures.

Further assistance to field installations is available through CSC Regional Offices.

The development and implementation of effective Upward Mobility is a team effort. As a system, Upward Mobility is made possible only through the involvement of all facets of agency management. To ensure an effective program, agencies should allocate sufficient resources and establish a central point of coordination. One way to do this would be to designate a coordinator and establish an Upward Mobility working group whose functions would include planning, implementing and monitoring program activities. Agencies might include in this group persons representing the following:

(1) Equal Employment Opportunity Director and staff, responsible for a comprehensive EEO Affirmative Action plan and program of which Upward Mobility is an essential part.

(2) Personnel Staffing Specialists, who analyze data essential to the identification of problem, target positions, job requirements and elements of career ladders.

(3) Budget and Finance staff, whose knowledge of the budget process can assist planners in estimating and accounting for agency dollar resources.

(4) Trainers, who can identify appropriate training sources and assist in developing meaningful developmental experiences both formal and on the job. (5) Counselors, who are trained to provide initial and ongoing career counseling for all employees and are especially qualified to meet counseling needs of those at the lower grades.

(6) Supervisors/Managers, within whose operational areas Upward Mobility may make the greatest impact and whose knowledge of job elements will assist in shaping meaningful developmental experiences.

(7) Employee Representatives, whose participation in planning can ensure an understanding of program goals and scope.

KEY REFERENCES

In implementing the planning requirements contained in this FPM Letter, agencies should refer to appropriate references listed in Attachment 3. A consolidated Upward Mobility Planning Guide, now in preparation, will treat each of the plan elements in greater detail with particular emphasis on conducting skills surveys, identifying target positions, designing selection systems, developing viable counseling programs, designing training plans, and setting criteria for program evaluation. This guide is scheduled for publication during third quarter, Fiscal Year 1975.

REPORTING REQUIREMENTS

Alternative means of obtaining Upward Mobility program information from agencies, including possible use of the Commission's Central Personnel Data File, are now under consideration. When a final decision in this regard is made, agencies will be furnished detailed reporting requirements and instructions and sufficient lead time will be provided for any automated systems modifications that may be necessary. Agencies should defer making any modifications until such instructions are issued, but should continue to comply with the reporting requirements contained in Part B, Appendix II to FPM Letter 713–22. BERNARD ROSEN, Executive Director.

Attachment.

THE UPWARD MOBILITY PLANNING PROCESS

A fundamental precept of Upward Mobility holds that employees with potential who lack qualifications may become qualified for current or projected higher level vacancies. Successful person-position matching, therefore, requires careful planning to ensure a results-oriented program-one which can be productive for both employee and manager.

The attached Upward Mobility Program Planning Chart outlines the process to be followed and the products which result from each planning phase. It is constructed to show the sequence of the essential steps to be taken as well as the continuing cycle of feedback for plan refinement.