6.511.1. Position Management and Classification Policy and Operational Guidance

(1) Position management is the assignment of work to positions within an existing or planned organization in a manner that will best achieve mission goals, efficiency of operations, and effective employee utilization within approved resource levels, while also promoting employee development.

(1) The purpose of position management is to ensure efficiency and economy in attaining the objectives of the Service through maximum use of human resources. However, in all cases, the cost of an action should be weighed in terms of the benefits derived. Long-range benefits may, in some instances, override considerations of immediate costs. Continual cooperation between line managers and PM/C specialists is vital to ensure that all aspects of position management principles and concepts are explored.

(2) The objectives of position management are:

1. To establish a position structure which will best serve organizational and program needs by providing optimum balance among such factors as economy, efficiency, skills utilization, employee motivation, and employee development;

2. To contribute to employee productivity by appropriate use of positions, including supervisory and administrative support positions;

3. To ensure that the duties and responsibilities of each position are clearly delineated, do not conflict with the duties of other positions, and serve as an effective aid in recruitment, placement, career progression, performance appraisals, and awards;

4. To eliminate unwarranted fragmentation of grade-controlling duties;

5. To ensure that jobs are accurately classified according to OPM position classification standards and supplementing IRS classification guides;

6. To abolish vacant positions if their duties can be redistributed or eliminated without seriously affecting the accomplishment of essential functions;

7. To lend maximum support to equal employment opportunity, upward mobility, and competitive merit placement programs through establishment of effective job structures; and

8. To accomplish effective analysis and ensure that PDs are current, specific, and accurate.

(3) Position management affects:

1. Work outcomes;

2. Customer satisfaction;

3. Cost of operations; and

4. Employee satisfaction.

(4) The position management program directly affects balanced measures outcomes.

(1) Division Commissioners (or equivalent level) have primary responsibility for the Position Management Program. They are responsible for ensuring that their subordinate managers, supervisors, and staffs coordinate efforts toward optimum staff utilization, and ensure adherence to the principles outlined in this manual.

(2) The IRS Human Capital Officer is responsible for developing, advocating, implementing, evaluating, and monitoring Position Management Program policies and operational objectives for the IRS.

(3) Other managers and supervisors have primary responsibility for the exercise of position management by determining the duties and responsibilities to be assigned to individual positions; determining whether positions should be established, abolished, or changed; determining the number and types of positions necessary to accomplish the work of the organization; and determining how to best organize the work and positions to achieve an optimal organizational structure. Position management decisions must take into consideration the availability of financial and human resources in addition to the utilization and development of employee skills.

(1) General principles that can be used as guideposts when making position management decisions are identified in the following:

(1) Position classification is the analysis of a position’s duties, responsibilities, and qualification requirements to determine the position’s title, series, and grade level according to classification standards issued by the OPM.

(1) The objectives of position classification are to:

1. Ensure pay is based on the principle of equal pay for substantially equal work; and

2. Ensure that positions are classified consistent with the criteria and guidance issued by the OPM.

(1) Position classification authority is the authority to determine and certify the proper pay plan, title, series, and grade of a position. Only an official who is delegated classification authority may certify the classification of a position by signing the Classification Approved section on the PD coversheet.

(2) The authority to classify positions is limited to those officials identified in the Servicewide Delegation Order 6-26, Classify Positions in the IRS. Specifically, Human Resources Specialists (Classification) in the PM/C Office have this authority and it may not be re-delegated. This authority pertains to all GS and associated supervisory paybanded positions and all FWS positions covered by this IRM.

(1) The position classification system is vital to the structure and administration of employee compensation. In this context, the IRS will classify the duties, responsibilities, and qualifications required to perform work in a manner which ensures that:

1. Pay is based on the principle of equal pay for substantially equal work; and

2. Differences in pay are in proportion to substantial differences in difficulty, responsibility, and the knowledge and skills required to perform the work.

(2) Current OPM policy stipulates that the grade of a position may be determined by the performance of higher-graded duties which constitute at least 25 percent of an employee’s work time. However, work assignments must be made according to sound position management principles and within the grade level of the current position as described in the PD. Human Resources Specialists (Classification) will ensure positions are classified consistent with this policy and will seek management input to validate the extent to which higher-graded duties are performed relative to the overall duties performed.

(3) Position classification recognizes/acknowledges the duties, responsibilities, and qualifications inherent within a position, and not those of an individual. Rare circumstances may exist whereby an individual distinguishes himself/herself by bringing to the job a greater set of skills and knowledge that enables management to recognize the position’s true value at a higher grade level (refer to 6.511.1.6.4.11, "Impact of the Person on the Job" ("Incumbent-Only Positions"). In those situations, the added duties and qualification requirements will be classified by reference to the appropriate classification standard(s) and guidelines, and the position will be identified as "incumbent only" on the PD coversheet. Once vacated, the position will revert to its original classification or be abolished.

(1) The HCO has a significant role to play in support of organizational change initiatives and requirements are found in IRM 1.1.4, Organizational Planning.

(2) Human Capital support may involve labor relations, recruitment, retirement counseling, use of strategies to mitigate impact on employees, classification of positions, advisory services for position management, and a variety of other support activities. Organizational change initiatives are subject to coordinated reviews by various program areas to determine impact.

(3) Business units should work closely with the PM/C Office during the planning stages for optimum results. The PM/C Office will review proposals and provide advisory and consultative services in areas such as:

1. Organizational and position design and grade structures;

2. SOC and related position management issues;

3. Use of higher graded positions;

4. Analyst/administrative staffing;

5. Appropriate use of PDs, including modifications or development of new PDs;

6. Workload studies; and

7. Other related program areas as needed.

(1) Reserved

(1) Performing workload studies will determine the adequacy of an organization’s staffing given past, current, and projected workloads. These studies identify the changes needed to the grade structure of an organization in order to match the appropriate number and grade levels of positions performing the work with the volume and complexity of work to be accomplished.

(2) Workload studies will serve as a basis for reviewing a proposed increase to the FWL of a position.

(3) Each business unit is responsible for conducting workload studies as necessary, and preparing paperwork/documentation according to functional guidelines and requirements as well as those outlined in this IRM. At the very least, a workload study must involve:

1. Determining the staff years (or FTEs) of work to be accomplished and the skill (grade) levels required; and

2. Determining the ability of the current staff to perform current/projected work, given the staff’s current size and skill (grade) levels.

(4) The PM/C Office will provide guidance and support if needed.

(1) It is the policy of the IRS to establish and maintain an effective SOC, with particular emphasis on first-level and second-level managers. An effective SOC entails, to the extent possible, assigning the maximum number of individuals to the fewest number of managers while ensuring achievement of organizational goals and program objectives.

(2) Management is responsible for maintaining appropriate spans of control according to the guidance outlined in this document as well as in line with sound position management and position classification principles.

(3) Every effort should be made to establish a minimum of 10 subordinates for a first-level manager, where feasible.

(4) No organizational entity with a first-level manager will be established or maintained with less than five (5) subordinates unless exceptions are approved by the Division Commissioner or equivalent.

(1) A PD is the official description of management’s assignment of major duties, responsibilities, and supervisory relationships to a position. The description of each position must be kept up to date and include information about the job which is significant to its classification. Position descriptions serve as the primary authorization document for the expenditure of appropriated Federal funds.

(2) All positions in the IRS must be established by means of an appropriately classified PD that is regularly reviewed and recertified every five (5) years through the PM/C Office.

(3) The PM/C Office is the only office authorized to maintain and update the IRS repository of PDs as well as master record information in related personnel systems. The PM/C Office controls the content of the IRS PD Library and will make updates/changes as needed.

(1) A desk audit is an interview process conducted on site or by phone (and may be supplemented by written documentation) to gather information necessary to validate the accuracy of a PD, including title, series, grade, and pay plan.

(2) Business unit management is responsible for initiating desk audit requests to the PM/C Office that include all pertinent information.

(3) PM/C Office will conduct desk audits on work that is currently being performed on a permanent and on-going basis.

(4) Human Resources Specialists (Classification) from the PM/C Office are responsible for conducting desk audits.

(5) Any IRS employee may request a desk audit because of a formal classification appeal and/or grievance filed by the employee.

(6) Desk audits are not to be used as a promotional tool and the following does not constitute a request for a desk audit:

1. Volume of work;

2. Length of service;

3. Quality of work;

4. Efficiency of performance;

5. Unusual qualifications; or

6. Diligence or overtime work.

(1) The Treasury Department’s Human Resources Issuance System (HRIS) Transmittal Number 18-002, requires all Treasury Department bureaus, offices, and organizations to establish and conduct a program which periodically reviews position classification and position management.

(2) The Position Review Program (PRP) implements the provisions of the Treasury Department’s HRIS Transmittal Number 18-002.

(3) The overall objective of the PRP is to assess and provide recommendations relative to position classification and related position management issues within an organizational entity. In this vein, the program is not intended as a "policing" process. Rather, it is intended to be a partnership process for evaluating current PM/C issues and practices, coupled with ideas and approaches designed to enhance and improve those program areas that would benefit from further management action. As such, the potential payoff resulting from a collaborative PRP process can be substantial in such areas as increased employee satisfaction and morale, improved organizational effectiveness, reduced labor costs, and expanded upward mobility opportunities, among others. Specific PRP objectives may include:

1. Enhancing management’s awareness of the importance of the accuracy of PDs, ensuring the existence of a current, adequate, and accurate PD for each employee;

2. Ensuring managerial accountability for accuracy in assigning work commensurate with assigned PDs;

3. Periodic management monitoring of the match between workload and grade structure, and redesigning positions accordingly;

4. Establishing bridge positions for career progression purposes;

5. Maintaining the consistency of position classifications with appropriate standards;

6. Identifying problem areas or positions requiring classification action;

7. Increasing the understanding of managers and employees of the principles, uses, and objectives of position management and position classification;

8. Reviewing incumbent-only positions with the objective of ensuring their continued accuracy; and

9. Eliminating questionable positions and structures.

(4) The IRS Human Capital Officer has responsibility for:

1. Effectuating the PRP within the IRS; and

2. Developing and issuing general guidelines and reporting requirements to ensure attainment of the objectives of the PRP.

(5) The PRP includes targeted reviews focused on individual business units, desk audits, special studies, PD reviews, and reviews of Requests for Reorganizations (ROC). No numerical or percentage qualifiers will be officially established or required as part of any PRP process, however, areas of special interest include:

1. GS-14 and GS-15 non-supervisory positions;

2. GS-301 and GS-343 positions;

3. Unusual or precedent-setting position;

4. Position established within the past twelve months;

5. Deputy/assistant chief positions;

6. Confidential and management official positions;

7. PDs older than five (5) years;

8. Span of control and position management concerns;

9. Impact of the person on the job (incumbent only) positions;

10. Grade structures and appropriate career paths; and

11. Overall adherence to proper position management principles and classification law.

(6) In all cases, the PM/C Office will document findings and work closely with the business units to address concerns and provide viable options.

(1) The PM/C Office reviews and provides IRS’ comments to the OPM on all draft position classification standards. The PM/C Office will ask for and consolidate comments from affected business units or equivalent functions, for inclusion in final response(s) to Treasury/OPM as appropriate.

(2) When the OPM issues new or updated classification standards for implementation, the PM/C Office will notify all impacted business units and establish action plans according to OPM prescribed timeframes. This includes beginning application of new standard(s) to all covered positions within one to three months from the official release date and completing within twelve (12) months from the official release date.

(3) Should changes to positions occur based on application of a new standard (i.e., title, series, or grade), the PM/C Office will work closely with impacted business units to explore options/alternatives before final action is taken.

(1) A position classification appeal is a formal written request initiated by any IRS employee asserting an inaccuracy in the title, series, grade, and/or pay plan of the position to which the employee is officially assigned.

(2) An employee may file a classification appeal either to the IRS or directly to the OPM. Appeal decisions given by OPM are final and binding for all incumbents and similarly situated positions are to be reviewed. An appeal to OPM is an employee’s final appeal right.

(3) Appeal requests must be submitted according to established IRS and/or OPM criteria. Refer to IRS criteria under Filing a Classification Appeal at 6.511.1.8.9.1. OPM criteria can be found at: http://www.opm.gov/classapp/index.asp .

(4) The Associate Director, PM/C Office (HCO), will adjudicate all classification appeal decisions within the IRS.

(1) The HCO, through the PM/C Office, is authorized to mandate corrective position classification actions for all positions in the IRS under its authority when the exercise of classification authority has been inconsistent, incorrect, or otherwise inappropriate.

(2) Corrective actions result from management inquiry, desk audits, position reviews, application of new classification standards, classification appeals, grievances, or reorganizations.

(3) HCO directed corrective actions must be achieved within established timeframes.

(1) An authorized position upgrade via a non-competitive promotion action occurs only when a position has been officially reclassified to a higher grade level and clearly meets the accretion of higher graded duties criteria.

(2) The PM/C Office or the OPM reclassification of a position is the only official means for a position to be upgraded. In those instances where a position is upgraded, the PM/C Office will issue a memorandum to the impacted business unit along with appropriate implementing instructions.

(3) The following are considered appropriate non-competitive promotion actions:

1. Upgrade of a position due to assignment of additional higher-graded duties and responsibilities (i.e., accretion of higher-graded duties);

2. Upgrade of a position because of the implementation of a new or revised OPM classification standard; or

3. Upgrade of a position because of the correction of an initial classification error.

(1) Accretion of higher-graded duties is the gradual addition of duties and responsibilities to a position over a period of time which results in re-classifying the position to a higher grade. Initiation of a non-competitive promotion action based on higher-graded duties may occur only when all of the following criteria are met:

1. The position is encumbered, and the affected employee gradually assumed and performed higher-graded work at least 25 percent of the time for a minimum period of six (6) consecutive months;

2. The PM/C Office performed a desk audit which documents the performance of higher-graded work by the employee;

3. The proposed promotion is to a new position which replaces the former position, and which does not fall within the criteria outlined below under Exclusions (6.511.1.8.12(2);

4. The proposed upgrade is in conformance with provisions of the National Agreement between IRS and NTEU, the IRM, and all other applicable statutes, rules, and regulations;

5. The impacted employee(s) meet(s) all qualification and time-in-grade requirements;

6. The proposed upgrade will not have an adverse impact on any other encumbered position; and

7. A PD is classified for the new position.

(2) Exclusions – The following situations are excluded from qualifying for non-competitive promotion based on accretion of higher-graded duties:

1. An additional position is created which does not supersede or is not the clear successor to the affected position;

2. There are multiple incumbents in the same organizational entity who perform like work and/or are on the same PD with the intent to promote only a specific individual(s);

3. The major duties of the incumbent’s current position are not absorbed into the new position;

4. The incumbent’s current position changes from a one-grade interval series to a two-grade interval series (e.g., GS-592 to GS-526);

5. The incumbent’s current position changes occupational series (e.g., GS-343 to GS-201);

6. The incumbent’s current position changes from a non-supervisory to a supervisory position, or vice versa;

7. The incumbent’s current position changes from a non-lead to a lead position, or vice versa;

8. Reassigning non-supervisory positions from one organizational entity to another to upgrade a specific supervisory position;

9. Assigning a specific set of higher-graded work all at once or within a short period of time (a few months) to an employee for the purpose of upgrading a specific employee’s position (i.e., planned management action); or

10. Changing the FWL/target grade of any position which crosses organizational and/or functional lines.

(3) The PM/C Office will conduct a desk audit of the affected position. At a minimum, the desk audit will determine:

1. If the incumbent is performing any higher graded duties;

2. Is the incumbent performing the higher graded duties at least 25 percent of the regular and ongoing work time;

3. Why was the work assigned to the position;

4. How long has the incumbent been performing the higher graded work;

5. What other positions exist in the organizational entity that could perform the higher graded work other than the affected position;

6. Should an upgrade occur, could/will that affect other identical/similar positions that exist in the organizational entity; and

7. Should an upgrade occur, could/will that affect management position(s) that exist within the organizational entity.

(4) The PM/C Office will issue desk audit findings and provide guidance for final resolution.

(1) It is the policy of the IRS to ensure that employees are correctly designated as management official or confidential.

(2) Management Official is defined as "…an individual employed by an agency in a position the duties and responsibilities of which require or authorize the individual to formulate, determine, or influence the policies of the agency."(5 USC. §7103(a)(11))

1. The Federal Labor Relations Authority (FLRA) has defined the critical terms in Section 7103(a)(11) as having the following meanings:

1. "Formulate" means to create, to establish, or to prescribe;

2. "Determine" means to decide upon or to settle upon;

3. "Influence" means to bring about or to obtain a result; and

4. "Policies" are general principles, plans, or courses of action.

2. The FLRA has further interpreted the statutory definition of management official as "…an individual who is identified with management and who, by virtue of his or her stature and level of responsibility within the agency, must have the interests of agency management as his or her primary concern in the context of a collective bargaining relationship." (FLRA 172, October 30, 1981)

3. The FLRA has further expounded on two key concepts relative to the role of a management official:

1. The person goes beyond being solely a technical expert or "resource" person in creating policy; and

2. The person is a KEY PLAYER and actively participates in the decision-making process to commit the agency to a specific course of action (i.e., establishing policy).

3. Both of the above key concepts must be met in order to be defined as a management official.

(3) The definition of a confidential employee is defined as "…an employee who acts in a confidential capacity with respect to an individual who formulates or effectuates management policies in the field of labor-management relations." (5 USC. §7103(a)(13)

1. The Federal Labor Relations Authority (FLRA) has further determined that an employee is "confidential" if:

1. There is evidence of a confidential relationship between an employee and the employee’s manager; and

2. The manager is significantly involved in labor-management relations.

2. The manager must be involved in additional labor relations’ activities other than the normal grievance process routinely encountered in a managerial position. The manager would need to have significant workload in:

1. Advising upper management on or developing negotiation positions concerning proposals;

2. Preparing arbitration cases for hearing; and

3. Consulting with upper management concerning the handling of unfair labor practices.

3. A manager’s involvement with personnel matters such as appraisals, disciplinary actions, promotions, grievances, and commenting on matters on contract negotiations does not constitute significant involvement in labor relations activity.

4. A confidential employee routinely maintains files containing confidential employee/labor relations material, has advance notice of personnel actions, has access to management recommendations on contract negotiations, attends regularly-scheduled management meetings on labor relations problems and grievance responses, and answers unfair labor practice (ULP) charges.

5. An employee is not confidential if he/she accesses information of a non-labor relations nature, e.g., maintaining files containing taxpayer returns, handling communications regarding work regularly assigned to the area, screening mail for a manager who does not effectuate management policies in the field of labor-management relations, operating equipment by which personnel data is extracted, or attending only those meetings where bargaining unit employees are in attendance. These examples do not extend to issues about labor relations policies.

(4) Responsibilities for ensuring the accurate designation and use of management official and confidential positions:

1. HCO – The HCO is responsible for ensuring that PDs contain the appropriate language, including the necessary duties and responsibilities that support the PD’s designation as management official or confidential .

2. Business units – Each business unit is responsible for ensuring that employees placed on these PDs are assigned duties commensurate with that designation.

3. The designations will be recorded on the PD. Form 14119 , Validate Management Official or Confidential Positions Within the IRS will be used to document information regarding the designation.

4. A management official will be assigned Form 12450-B Performance Plan for Management Officials, while employees designated as “confidential” will be under the appropriate CJE’s or Form 12450-D for confidential GS-343 management/program analysts.

5. Management is responsible for assigning performance plans according to position designations.

(1) Developmental or trainee positions are typically established for non-supervisory positions.

(2) There is no mechanism to legitimately document lead positions as "trainee" or "developmental." Per the OPM General Schedule Leader Grade Evaluation Guide, classification of a lead position is one (1) grade above the highest non-supervisory grade level of the work led. Subsequently, this is not subject to further interpretation and/or manipulation.

(3) Classification of management positions are based on a combination of factors. In general, management positions are classified one or more grades above the base level of technical work performed within the organizational entity they manage. Therefore, “career ladder” supervisory positions are not allowed as they are in opposition to classification regulation.

(4) As an alternative to creating a career ladder management position, consider using the Frontline Manager Trainee template. This template uses the "manager-in-training" approach through the use of various training techniques, including on-the-job training, details, formal and informal training classes, and other methods as part of a formal training agreement process. Coordinate all requests with the PM/C Office.

(5) Use of a trainee management PD must be in conjunction with a competitive, formal leadership program (i.e., FLRP). During the official program, management trainee PDs can be used for temporary promotion/detail assignments. Management trainee PDs may not be used for permanent placement (competitive or non-competitive).

(1) For positions established above the first FWL or "senior" positions, establishment of developmental or career-ladder positions is not permitted since the notion of a "trainee" senior position runs contrary to the concept for which the senior position was originally established, i.e., the position serves as a program authority and technical expert which operates with a high level of independence. Creating a developmental or "trainee" senior position is a contradiction in terms, as well as in performance expectations and sound position classification.

(1) Collateral duty assignments are official duties and responsibilities assigned to an employee in addition to the primary duties of the position the employee occupies. Examples include: Contracting Officer’s Technical Representative (COTR), Taxpayer Advocacy Liaison, Integrated Data Retrieval System (IDRS) Security Representative, Functional Office Automation Coordinator, etc.

(2) Collateral assignments have the following characteristics with respect to position classification:

1. The collateral assignment is distinct and separate from the primary duties and responsibilities of the affected position, and does not constitute the primary purpose for establishing or continuing the position;

2. The assignment does not constitute a grade-controlling duty or responsibility;

3. The assignment is not a primary duty of the position (it constitutes less than 25 percent of the employee’s work time); and

4. The collateral duties are specific to the affected individual employee(s), not to all incumbents of the same PD.

(3) Management is responsible for initiating and completing Collateral Duty statements. The PM/C Office is available to provide guidance and assistance.

(4) The approved collateral duties will become part of the official PD of the impacted employee(s).

(5) An official change to a PD is required when the collateral duty requires specific skills that are different from those in the original PD and are paramount in influence and weight, or when the collateral duty results in a change to the series, grade, and/or job elements and performance standards of the original PD.

(1) Unclassified Duties are those tasks and responsibilities to which an appropriate classification authority has not yet assigned an occupational series, title, and grade level.

(2) An employee may be detailed to unclassified duties but not officially assigned to unclassified duties. When necessary to detail an employee to unclassified duties, management is responsible for describing duties and responsibilities that will be performed.

(3) Make details to unclassified duties only on rare occasions. When such a detail is necessary, see IRM 6.300.1.9.1, Detailing Employees without Regard to the 120-Day Limitation for information on processing details.

(1) Key OPM/IRS Web Sites containing position management and position classification information:

1. http://hco.web.irs.gov/posclass/index.html

2. http://www.opm.gov/a-z-index

3. https://www.opm.gov/fedclass/index.asp