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Memorandum

Purpose

In accordance with the Clinger-Cohen Act of 1996, the Office of Federal Procurement Policy (OFPP) and the Office of Personnel Management (OPM) implemented a qualification standard for the GS-1102 contracting series for application in civilian agencies.  This standard has gone through several iterations.  The purpose of this memorandum is to clarify the current standard and establish a Departmentwide process to request waivers to the standard.

Background

OPM issued a revised qualification standard for the GS-1102 Contract Specialist Series, effective January 1, 2000, which applies to all new hires and to existing employees selected to fill GS-1102 positions at civilian agencies.  A copy of the qualification standard, along with a set of “Questions and Answers Concerning Revised 1102 Qualification Standard” prepared by OPM, is included as Attachment 1.  The revised standard supercedes an earlier version issued January 1, 1998.  A list of the mandatory agency training requirements for these positions at the Department of the Interior is included as Attachment 2.

Implementation of the standard was coordinated through an intra-agency working group comprised of representatives from acquisition and personnel, and information was provided to Bureau Procurement Chiefs and Bureau Personnel Officer by a memorandum signed by the Senior Procurement Executive (SPE) and the Director of Personnel in November 1997.

The standard applies to all civilian agencies and is comparable to a standard already established in the Department of Defense by the Defense Acquisition Workforce Improvement Act.  The new standard will prepare employees in the 1102 series to be more competitive when they apply for new positions or promotions.

Grandfathering and Exceptions to the Standards

Every GS-1102, regardless of grade, is considered to meet the standard for the position and grade held as of January 1, 2000.  The standard only applies to promotions and new hires.

The original standard included a two-year grandfathering clause (in-service placement provision) that allowed then current employees in the GS-1102 series to be promoted based on specialized experience until January 1, 2000.  After that date, promotions to the GS-13 and above required all employees meet the new qualification requirement.  The standard was phased in to provide a reasonable opportunity for employees to acquire the needed educational background for promotions.  There is no grandfathering provision that allows experience to substitute for education in order to qualify for promotions.

If an employee was already a GS-1102 between GS-5 through GS-12 as of January 1, 2000, the “exception” language of the standard allows that employee to lateral into a position at any agency and then to continue to be eligible for promotions through GS-12 without having to meet the educational and training requirements.  This includes positions at other agencies.  Employees must continue to meet any specialized experience requirements when seeking another position.

The “exceptions” language permits GS-1102s at the GS-13 level and above to lateral into positions within their agency or at other agencies at the grade occupied as of January 1, 2000 without a waiver and without having to meet the education and training requirements if the specialized experience requirements are met.

Waivers

Waivers only exist for the requirements that apply to positions at GS-13 and above.  All new entrants into the GS-1102 career field at grades 5 through 12 must meet the education qualification requirements; these requirements cannot be waived.  For GS-13 and above, in order to qualify for a promotion to a higher grade, one must meet the basic requirements and specialized experience requirements or receive a waiver from the SPE of the hiring agency.

The standard permits an agency’s SPE to waive the basic requirements for positions filled at the GS-13 and above when an applicant possesses significant potential for advancement to levels of greater responsibility and authority based on demonstrated analytical and decision making capabilities, job performance, and qualifying experience.

The waiver authority provides agencies the flexibility to accommodate unique situations.  However, OFPP has indicated that in order to uphold the intent of the Clinger-Cohen Act’s contracting workforce professionalism requirements, they expect waivers to be issued by exception rather than the rule.

It is in the best interest of the Department’s acquisition program to ensure that employees in positions at grades GS-13 and higher meet the basic qualification requirements.  For that reason, the Department of the Interior SPE will consider waivers on a case-by-case basis.  It is the Department’s policy, however, that no waivers will be granted to exempt a candidate from meeting the basic experience requirements.

Waivers will be granted only in rare, exceptional cases such as 1) recruiting situations when hiring for hard-to-fill positions or duty stations where it is difficult to attract fully qualified candidates or 2) when a high-quality performer fails to meet the basic educational or training requirements and is considered by the selecting official as the best candidate for the job.  A candidate’s ability to demonstrate good-faith progress toward meeting the standards will weigh heavily in any waiver decision.

1. Recruitment Waiver.  If no applications are received from fully qualified candidates and the bureau can demonstrate that they made a reasonable attempt to solicit qualified candidates for the position (i.e., advertised for 30 days Government-wide, etc.) the bureau may request a waiver for a candidate that meets the experience requirements, but does not meet the education and/or training requirements.  The selecting official must obtain a waiver according to the process outlined in Attachment 3 prior to placing that candidate in the position.  The candidate does not need to be within 24 months of completion of the education requirements or within one year of completion of the mandatory agency training requirements, but must agree to an Individual Development Plan that will promote attainment of those education or training requirements over a reasonable period of time.

 
2. Education Waiver:  In all recruiting actions resulting in a candidate’s appointment or progression to a position at grades GS-13 and higher, the candidates will be evaluated to ensure they meet the basic qualification requirements.  In the event the selected candidate does not meet the basic educational requirements, but is within 24 months of completing those requirements, the selecting official must obtain a waiver according to the process outlined in Attachment 3 prior to placing that candidate in the position.  No waivers of the basic educational requirements will be granted to individuals who are not within 24 months of completing those educational requirements.

 
3. Training Waiver.  In the event the selected candidate to a position at grades GS-13 and higher does not meet the mandatory agency training requirements (see Attachment 2) the selecting official must obtain a waiver according to the process outlined in Attachment 3 prior to placing that candidate in the position.  The waiver will be a conditional waiver that clearly identifies the length of time the waiver is in effect (up to one year) and training requirements the individual must meet if selected for that position.

No offer may be extended to a selected candidate, for whom a waiver to the training or education requirements is needed, until the waiver is approved by the SPE.

If an Education Waiver or Training Waiver is granted, the selectee must sign a “Conditions of Employment” statement, agreeing to complete the basic education or training requirements within a specified period of time.  The statement will stipulate that failure to fulfill that condition of employment will result in either (1) reassignment to a job outside of the 1102 occupation series and ineligibility to hold Level III or IV warrant authority, or (2) return to the grade and series held prior to promotion.

When recruiting for a GS-1102 vacancy for a Grade 13 or higher, if the selecting official will consider applicants for a waiver, they should work with the human resources specialists to ensure that the vacancy announcement incorporates language to:

• Alert potential applicants to the fact that waivers will be considered
• Request college transcripts
• Indicate that selection and tendering of an offer will be contingent on SPE approval of any applicants not meeting education and/or training requirements.

Questions related to this process should be directed to Gayle Fischetti, Office of Acquisition and Property Management, at (202) 208-6705.

Attachments

Attachment 1 - GS-1102 Contracting Series Qualification Standards:

• Basic Requirements for GS-5 through GS-12
• Basic Requirements for GS-13 and Above
• Questions and Answers Concerning Revised 1102 Qualification Standard

Attachment 2 - Mandatory Agency Training Requirements

Attachment 3 - Waivers to the GS-1102 Contracting Series Qualification Standard