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Questions and Answers Concerning Revised 1102 Qualification Standard

Questions and Answers Concerning Revised 1102 Qualification Standard

Please Note: These questions and answers supplement the revised qualification standard that went into effect for GS-1102 contract specialist positions in non-Defense agencies as of January 1, 2000. The standard was developed by the Office of Federal Procurement Policy under the authority of 41 U.S.C. 433.  

Issues that arise in implementing the standard should be addressed to the human resources specialists in your agency who will be able to seek the advice and assistance of OPM and OFPP, as necessary.

General Information

  • The Clinger-Cohen Act, issued in February 1996, amended the Office of Federal Procurement Policy (OFPP) Act to require that the Administrator of OFPP establish qualification requirements, including educational requirements, for positions at civilian agencies in the GS-1102 series (see 41 U.S.C. 433). Five years earlier, Congress had established requirements for 1102 positions in defense agencies through the Defense Acquisition Workforce Improvement Act (see 10 U.S.C. 1724, 1732). The Clinger-Cohen language stipulates that qualification requirements established by OFPP shall be comparable to the DAWIA requirements. In June 1997 the U.S. Office of Personnel Management (OPM) published a qualification standard imposing requirements established by OFPP pursuant to Clinger-Cohen.
  • The predecessor to this standard introduced educational requirements that were effective January 1, 1998 for new hires and January 1, 2000 for existing employees. The revised standard does not change the minimum educational levels defined by the former standard. However, it does make three changes. First, it expands the waiver authority related to filling GS-13 and above positions. The former standard only allowed the senior procurement executive to waive one of the two educational requirements, whereas the revised standard permits waiver of any or all requirements. Second, it removes language that permitted examinations to substitute for the 24-hour requirement since acceptable examinations have not been designated. With the exception of college course credit obtained through testing programs designed to grant credit by examination (such as the College Level Examination Program), you cannot take a test to qualify in lieu of the 24 hours. Third, it replaces the January 1, 1998 date found in the former standard with a January 1, 2000 date, meaning employees hired under the former standard have grandfathering rights as "current" employees.
  • This revised qualification standard was effective January 1, 2000. It applies to all new hires and to existing employees selected to fill GS-1102 positions in civilian agencies.

Educational Requirements

  • In order to qualify for positions at grades GS-5 through GS-12, you must possess either a bachelor's degree OR have completed at least 24 semester hours of coursework in certain business-related fields. In order to qualify for positions at grades GS-13 and above, you must possess a bachelor's degree AND at least 24 semester hours of coursework in certain business-related fields. The 24 hours may be included in, or in addition to, coursework taken to complete the degree program.
  • The phrase means you must possess a bachelor's degree conferred or approved by an accredited U.S. college or university based on a 4-year course of study. Simply being enrolled and working toward a degree does not meet the qualification standard. Furthermore, "honorary" degrees or other degrees with no basis in coursework do not satisfy the standard.
  • No. You can earn the bachelor's degree in whatever length of time is necessary and accepted by the college or university conferring the degree. The descriptive phrase relates to how the educational institutions characterize the degree program, not to how long it takes you personally to complete the program.
  • No. A qualifying bachelor's degree may be in any field of study and may be of any type, such as Bachelor of Arts, Bachelor of Science, and Bachelor of Business Administration. The 24 semester hours, however, must be in some combination of the eleven fields listed in the standard.
  • You need to check with your local human resource office to see what procedures they use. If you already had a degree when you were hired, you probably furnished a college transcript with your application and, if so, that information is included in your personnel records. If you have completed courses since being hired, you will probably need to furnish evidence to your human resource office, such as a new transcript and a copy of your diploma, as applicable. It may be necessary also to provide descriptive information on a course (e.g., course syllabus) to convince a human resource specialist that a particular course qualifies toward the 24-hour requirement. You should periodically review your personnel records to ensure information has been recorded accurately, and work with your human resource office to update the records as needed.
  • Yes, coursework could simultaneously count for the degree requirement and the 24-hour requirement. For example, if you earned a business degree, you should have completed sufficient credits in the required fields to satisfy the 24-hour requirement. However, if your degree is in another field, such as sociology, you might need to take some additional courses in the fields identified in the qualification standard to complete the 24-hour requirement.
  • The answer to this question first requires an understanding of the purpose of the 24-hour coursework requirement, which is to provide a person with a minimum amount of business knowledge. This is particularly important because the primary function of contract specialists is to negotiate and execute business relationships on behalf of the Government. The eleven fields listed in the standard are identical to those set forth by Congress in DAWIA, and presumably they were selected because they capture the types of knowledge and skills desired for members of the acquisition workforce to execute this function.

    Colleges and universities do not use a standard convention for course numbering aligned to the eleven fields. For example, one institution identifies its accounting curriculum as "AMIS" courses, standing for "accounting and management information systems." Therefore, it is neither practical nor reasonable to restrict interpretation of the word "fields" to institutional programs using precisely the same language. Instead, it is appropriate to consider the identified fields as general subject areas. If the content of a course arguably fits within the general subject area represented by one of the fields, it should qualify toward the 24-hour requirement. A human resource specialist, or whoever in your organization credits completion of the 24 hours, may need to review the course syllabus whenever it is not obvious from the course title that content fits the field. Consider these examples: a sociology course in statistics; a public administration course in quantitative techniques; a psychology course in organizational behavior. If the content of these courses is comparable to, or perhaps is recognized by the academic institution as a substitute for, courses clearly resting in the listed fields, you should receive credit toward the 24-hour requirement. It is your responsibility to furnish supporting descriptive information if credit for a course is being questioned.

  • Not unless a college actually gives you credit under its curriculum. Education and training are separate components of agency career development programs. Training courses are designed to build job-specific knowledge and skills, complementing and supplementing the general level of knowledge and skills acquired through formal college education. The 24-hour requirement is intended to be satisfied through coursework taken at colleges and universities. A college may give credit for certain on-the-job training courses, or teach a course that has been determined "equivalent" to a prescribed training course. In such cases, you may be satisfying educational and training requirements simultaneously. However, unless a college specifically awards you course credit, your training courses do not count toward the 24-hour requirement. This is at the discretion of the college, and you do not have an automatic entitlement to the credit.

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"Grandfathering" -- The Exception Provisions

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The Waiver Provision

  • For purposes of this qualification standard, the "senior procurement executive" is the highest career civil servant having responsibility for the procurement function within an agency (e.g., policy, procedures, workforce, etc.). Typically, this person is located in the agency headquarters office. This person may be different from the person designated as a "senior procurement executive" pursuant to the OFPP Act (41 U.S.C. 414(3)) and as defined in the Federal Acquisition Regulation, who is a political appointee in some agencies. OFPP established the requirements of this standard with the intention that senior career procurement officials would possess the waiver authority.
  • No. The waiver authority is not delegable. The contracting office desiring to hire an applicant who needs a waiver would probably have to provide justification to the senior procurement executive to aid the waiver decision, but only the senior procurement executive can grant waivers.
  • No. All new entrants into the GS-1102 career field at grades 5 through 12 must meet the qualification requirements. The requirements cannot be waived. However, if you are already an 1102 below grade GS-12 as of January 1, 2000, the "exception" language of the standard allows you to be promoted through GS-12 even if you do not have the education specified by the standard.
  • No. A waiver is not necessary for promotions under grade GS-13 because all promotion candidates would either meet the standard or qualify for the "exception" at those lower grades. Waivers only exist for the requirements that apply to positions at GS-13 and above.
  • No. The senior procurement executive of the hiring agency must grant a waiver only if the agency wants to select you to fill a position. If the vacancy announcement indicates that waivers may be granted, you can apply for the position. The human resource office will forward your application for review, along with the other applications, with a note that one or more applicants may need a waiver.
  • When drafting vacancy announcements, human resource offices extract information from relevant qualification standards. In the case of 1102 positions, if an agency has decided for a specific vacancy that it will consider applicants who need a waiver, the vacancy announcement will state that candidates who do not meet the qualification requirements may be considered for a waiver in accordance with the standard. At the agency's option, the waiver may be applied to any of the educational, training, or experience requirements, or combination thereof, as specified in the vacancy announcement.
  • No. A waiver is the prerogative of the hiring agency and would be granted based on the unique circumstances of a hiring action. "Blanket" waivers do not exist.
  • Yes. Waivers are specific to a selection action, so any selection for a future promotion would require another waiver if you still did not meet the qualification requirements.
  • The answer depends on the circumstances. A "lateral" is a reassignment into a position at the same grade. If you meet the qualification requirements, obviously you can lateral into positions within your own agency or other agencies without a waiver. If you do not meet the qualification requirements, the rules vary by grade and circumstances as described here. There is no waiver provision applicable to grades GS-5 through GS-12, only for grades GS-13 and above. Below GS-13, the "exceptions" language of the standard permits you to lateral into a position at any agency and then to continue to be eligible for promotions through GS-12. For grades GS-13 and above, the "exceptions" language permits you to lateral into positions at your agency or other agencies at the grade you occupy as of January 1, 2000 without a waiver. These "exceptions" are "grandfathering" features afforded to the existing workforce.

    Suppose you are promoted into grade GS-13 or above after December 31, 1999 on the basis of a waiver. The need for a waiver for a subsequent lateral in this circumstance depends on whether you are changing agencies. If another agency wants to lateral you into one of its GS-13 or above positions, that agency must grant a waiver in order to give you the lateral. If your own agency (the one that gave you the waiver for the position you now occupy) wants to lateral you into another position within the agency, it may do so without processing a new waiver, even if geographic relocation is involved. For example, if you were promoted to a GS-13 Contract Specialist position at NIH-Bethesda MD based on a waiver, you could be selected for a lateral into a GS-13 Procurement Analyst position at CDC-Atlanta GA without the HHS senior procurement executive granting another waiver (since both organizations are within HHS). However, you could not lateral from the NIH position into a GS-13 Contract Specialist position at EPA unless the EPA senior procurement executive granted you another waiver.

  • No. The waiver authority was created to provide flexibility to accommodate unique circumstances faced in each agency, but it is expected that waivers will be the exception rather than the rule. Waivers will be considered on a case-by-case basis within an agency and granted in those exceptional cases where the best candidate for a specific job does not meet some requirement of the standard. For example, an agency could benefit from this authority when hiring for hard-to-fill positions or duty locations where it is difficult to attract qualified candidates. Another case may be where a strong performer is on a career ladder but fails to meet the requirements for promotion. Hiring is an agency responsibility, and the decision to grant a waiver of the qualification requirements is at the discretion of the agency's senior procurement executive. Since you do not need a waiver to be considered for a position, and provided the announcement states waivers may be considered, hiring officials will review your qualifications and rate you against other applicants. If the hiring official considers you the best candidate for a position, presumably the official would seek a waiver to allow your selection.
  • Submittal of the application implies a request for waiver when the applicant does not meet the requirements of the standard. Although the standard specifically identifies the senior procurement executive as having waiver authority and responsibility, the likely practice will be that a selecting official prepares and submits a justification document to the senior procurement executive relating the applicant's background and characteristics to the performance requirements of the job being filled. It is the agency's responsibility to document its decision to issue a waiver.

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Relationship Between Civilian Agency and Defense Agency Positions

  • The qualification standard does not apply to defense agency positions; instead, applicable requirements are set forth in DAWIA. However, comparability exists between both sets of requirements. DoD positions through grade GS-13 require either a bachelor's degree OR 24 semester hours in identified fields, which is the same requirement the 1102 standard sets for civilian agency positions through grade GS-12. DoD has also created an "acquisition corps" to fill GS-14 and above positions, with GS-13s eligible for membership. The acquisition corps requires a bachelor's degree AND 24 semester hours, like the 1102 standard requires for GS-13 and above positions. If you meet the DAWIA educational requirements, you could qualify for DoD jobs. If you do not meet the educational requirements, but you have at least ten years of acquisition experience as of October 1991, you are grandfathered by DAWIA and could qualify for DoD jobs. If you do not meet the educational requirements or have enough experience to be grandfathered, you are not qualified for DoD jobs, even though you may be grandfathered for civilian agency positions under the qualification standard. However, DAWIA does allow DoD to waive the requirements to hire you.
  • Like anyone else competing for a civilian agency position, generally you would have to meet the educational requirements of the standard for the position you seek in order to qualify. Suppose you do not meet the educational requirements. If you were an 1102 as of January 1, 2000, the standard allows you to obtain a lateral or a promotion into a civilian agency position at grades GS-5 through GS-12. At grades GS-13 and above, you could lateral only into a position at the same grade that you held as of January 1, 2000. For promotions into civilian agency positions at grades GS-13 and above, you are not qualified if you do not meet the educational requirements; hence, you could only receive such a promotion if the hiring agency issued you a waiver. Your "DoD grandfathering" does not extend to civilian agency positions and does not give you access to promotions outside DoD. After you are placed in a civilian agency position, you are subject to the qualification standard for future civilian agency promotions. If you lateral into a civilian agency position below GS-12, you would be eligible for promotions through GS-12 even though you do not meet the educational requirements. For promotions to grades GS-13 and above, you would have to obtain a waiver if you do not meet the educational requirements.

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