NASCOE News Flash: 2016 Negotiations Items and Responses

The 2016 NASCOE negotiations session was a great success! We appreciate the items submitted by membership and are proud to present your concerns to management on your behalf. The negotiations process requires extensive research and preparation by NASCOE representatives, but it is one of the most effective methods of addressing issues faced by COF employees. Please see the report below for official responses to this year’s negotiation items. If you have a concern that was not discussed in this year’s session, we encourage you to submit it for inclusion in the 2017 negotiations process. Thanks to all who participated in this year’s meetings!

ITEM 1: Workload Formula
Issue: The workload report showing numbers for each state has not been shared with counties. SED’s have the option of not using the WDC formula for staffing without having any oversight of their plan. Further, NACS and NASE were provided the opportunity to input ideas into the current workload formula and NASCOE was not.

NASCOE Position: This is an item that we discussed last and were told DAFO’s response would be forthcoming. While we were at the national convention in 2014 we were told that we were understaffed by approximately 2,500 people. This number came from the workload report that we refer to as the Juan Garcia workload report model. NASCOE was told by management that this report would be shared with us. As of now we have not seen the report. Some STO’s shared this report with their employee associations but most did not share. NASCOE would like to see these numbers at the county level. NASCOE also feels that making staffing decisions based on the old Farm Bill instead of the new Farm Bill has its issues. NASCOE would also like to request an update on where we are with the development of a new workload tool.

DAFO Response: In June of 2014, DAFO provided SED’s and employee associations a PowerPoint presentation that described the workload report model used to help distribute both GS and CO ceilings. Additionally, DAFO provided each SED with their state’s county level workload report model data and guidance on using the data as a tool when making staffing decisions. It was never the intent that workload report model data be the sole source used in making staffing decisions for county offices. SED’s were encouraged to apply their knowledge of the state’s agriculture and infrastructure and to solicit input from their management team and employee associations to arrive at final county office staffing decisions. We agree that making staffing decisions based on previous Farm Bill programs could skew staffing needs; therefore, assumptions were made to anticipate potential workload generated by new programs introduced in the 2014 Farm Bill.

FSA does not currently have a staffing model (workload tool) to allocate staff years; however, once a staffing model is developed, it will be used to make recommendations regarding staffing requirements and reallocations. Currently there is a study being conducted to assist FSA in finalizing a staffing model.

Agreement: NASCOE accepts the answer that there is a model in production at this point. The OBF numbers have not been released at this time. There is a demonstration on this issue tomorrow. The states will be encouraged to share their workload information with the state association. There is a need for transparency in any workload model that is used by the states. Ceilings are ultimately determined by budget, but should be reflected down to the county office level.

ITEM 2: Shared Management-Procedure
Issue: “Before STC approval of the establishment of a permanent shared management operation, the SED will consult the NASCOE state affiliate.” At present, many STO’s are not following this procedure.

NASCOE Position: NASCOE recommends that SED’s be reminded of applicable handbook procedures in 27-PM, paragraph 52C. SED’s are to consult in pre-decisional format before the establishment of a shared management operation.

HRD Response: We agree that the policy requires the consultation and defer to DAFO on any reminders to or reinforcement of the policy with the states. We do stand ready to assist if any clarifications or changes to the handbook need to be issued.

DAFO Response: States routinely send in requests for approval of shared management proposals. DAFO always ascertains if consultation has taken place. If this is not happening, we should be informed.

Agreement: NASCOE would like an official response from the state association attached to the decisions regarding shared management to ensure the NASCOE state affiliate is involved. DAFO will review this issue to come up with a solution to show a written NASCOE position accompanying the state request for permanent shared management. A response will be sent back to NASCOE within 30 days. This is to ensure the states are following current policy. NASCOE will provide feedback in the consultation. Written documentation of the consultation with the state association included in the submission to DAFO for permanent shared management. An email will be sufficient for a response. HRD can draft policy for DAFO review to be submitted to NASCOE.

ITEM 3: Temporary Shared Management-Upgrades
Issue: “For temporary shared management operations expected to last more than 30 days, upgrades for CED’s and lead PT’s shall be on the beginning of the first pay period following the effective date of the shared management operation. CED’s and lead PT’s in current temporary shared management operations where the arrangement has been effective for more than 30 days shall be immediately upgraded according to this agreement.” At present, many STO’s are not following this procedure.

NASCOE Position: NASCOE recommends that SED and STC’s be reminded of the applicable handbook procedures in 27-PM Exhibit 8. STO’s and CED’s shall follow procedure by grading applicable employees one level higher than their normal grade effective the first day of the pay period following the thirtieth day of shared management.

HRD Response: The current policy and agreement published in 27-PM does indicate that that PT promotions shall occur IF the applicable PT is delegated responsibility for all activities in the office when the CED is absent. We agree that if the authorities (and therefore the responsibilities) are delegated to the PT then promotions should not be denied. The promotions are not absolute as they are dependent on delegation of the authorities. From an HR perspective, if the authorities are not delegated, the criteria for promotion is not met. However, with the proposed change to 27-PM Paragraph 133 the situations in which the authority is not delegated will be limited but does still allow for local management discretion where needed. We defer to DAFO on any reminders to or reinforcement of the policy with the states. We anticipate the amendment to 27-PM will be issued within the next 90 days.

DAFO Response: The following are proposed changes to Paragraph 133, Handbook 27-PM, which has been discussed with the NASCOE President and Vice President in a recent meeting in Washington DC:

One Program Technician position in the headquarters office and the suboffice in a shared management operation shall be:

  • designated by the CED as the lead Program Technician
  • graded 1 level higher than the grade determined by applying the criteria paragraphs 128 through 131, up to the CO-8 level, if all of the following conditions are met:
    • the Program Technician is designated as being responsible for all activities in the headquarters office of the suboffice when CED is absent
    • CED is absent at least 40 percent of the time
    • time-in-grade requirements are met
    • the candidate for the lead position has at least a fully successful performance rating
    • there are sufficient administrative and program activities to support a lead position

Note: CED shall document reasons for selecting a particular employee for a lead Program Technician position in the COC executive minutes.

We agree with HRD that such promotions are not a right unless all the criteria are followed.

Agreement: Suggested “sufficient management” rather than “sufficient administrative” language in the last bullet in Paragraph 133A. DAFO agreed that the language should be revised. DAFO agreed to change the wording to “management” rather than “administrative,” and still give the states the ability to review if this position is justified in the COF. NASCOE would like the opportunity to review the results of the change in the wording and review the process next to determine the success in this; the review will take place within 6 months of implementation.

ITEM 4: Temporary Shared Management-Length of Time
Issue: Provisions in 27-PM paragraph 53C “temporary shared management operations shall not exceed 120 calendar days.” At present, many STO’s are not following this procedure.

NASCOE Position: NASCOE recommends that SED’s be reminded of applicable handbook procedures. Procedures shall be followed in instances where shared management operations exceed 120 days by SED’s meeting with COC’s to “work out a permanent solution. Any exceptions to the 120 calendar day limitation shall be approved in advance by DAFO.”

HRD Response: We concur with the statement of the policy and defer to DAFO on any reminders to or reinforcement of the policy with the states. We do stand ready to assist if any clarifications or changes to the handbook need to be issued.

DAFO Response: All extensions are approved by DAFO after it is determined how long the shared management operation will continue and what plans the state has to end it. As we have reiterated many times, budgetary and current Congressional restrictions prevent us from taking necessary steps to ease the situation of so many shared management offices.

Agreement: DAFO agreed to have temporary defined as 6 months and the review will have attached COC minutes showing the consultation with the state affiliate of NASCOE was completed.

ITEM 5: DCP/Overpayments
Issue: County offices are required to check twice a week the DCP Submitted Overpayment Report and Pending Overpayment Summary Report for 2009-2013 to verify if any new producers have been added to the reports due to SCIMS or ID changes that are made in 2015 and future years. These changes are triggering DCP overpayments in years 2009-2013.

NASCOE Position: NASCOE feels that payments were legitimately earned by producers in those years and any change made in Farm Records for years 2014 and beyond should not affect previous payments. NASCOE suggests that a software change be made in Farm Records to prevent pending overpayments.

DAFP Response: Changes in the system need to be recognized by the payment software to ensure producers are being paid properly as well as for the system to identify when producers are overpaid. Changes to information in Farm Records for 2014 and future years don’t affect the 2009 – 2013 DCP/ACRE payment calculation since the information used in the payment calculation is year specific. Since SCIMS is not year specific, changes to the ID in SCIMS will result in an overpayment for the old ID number and a new payment to the new ID which will be offset by the receivable created for the old ID number so, in this situation, the producer isn’t even aware of the overpayment.

Agreement: Accept DAFP response. It was noted that a comment can be put in the common name field and the handbook is being revised, so this information will be communicated to the field. The reports should be checked at least once a week.

ITEM 6: IT/Computer
Issue: Given the relatively slow internet connections in most of our field offices, connection to ArcGIS through Citrix is extremely slow. The slow GIS connection reduces efficiency and prevents CO employees who are skilled in GIS from fully utilizing their talents to produce/revise maps, analyze soils and other natural resources, extract individual parcels to assist with tract revisions in MIDAS and other sister agencies and customers. FSA is losing time and failing to take full advantage of employee skills by continuing this system. The primary issues county offices are experiencing are long delays when accessing and editing in CITRIX and Terra. Users are also experiencing timeouts while printing and the system takes even longer when trying to bring the system back up after being timed out. This is not user friendly for county office personnel.

NASCOE Position: At least one computer in each county office should have ArcGIS on the hard drive, allowing CRP and/or GIS PT’s to more efficiently use this incredible resource. Additional ArcGIS licenses should be purchased for the STO’s and distributed equitably to the county offices. At minimum, a testing period could take place under which STO’s get a few extra software licenses and COF’s with skilled/experienced GIS staff or high CRP workload offices receive these licenses.

DAFP Response: FSA participates in an ESRI Enterprise License Agreement (ELA) with other USDA agencies. The ELA provides FSA with unlimited license authorization for ArcGIS desktop software. STO GIS Specialists have been instructed for the last several years to identify individuals that want/need the software and to submit a Remedy ticket to request the software installation as appropriate. However, because the software is considered an “out of the box” application when accessed in this manner (as opposed to TERRA and Maintenance Tool, which are FSA custom software accessed only through CITRIX) it is also up to the STO GIS Specialist to ensure that appropriate training and support is provided to their State and County office users. It should also be noted that, as part of the ELA, FSA has access to online training that ESRI offers at no cost. Both of these topics will be covered at the National Training in Charlotte, NC March 14-18.

Agreement: The IT issue will be addressed more on Thursday when Darren meets with NASCOE. NASCOE accepts the response.

ITEM 7: IT/Computer-LincPass
Issue: Routinely county office computer users experience instances of their LincPass cards getting the message “your certificate has expired” or “your card is invalid”. Additionally, FSA application software is often non-functioning and accessible during the workday. Submission of Remedy tickets often do not result in any resolution of these daily IT outages in the county office. Appointments are often already made and, as a result, producers experience decreased customer service and many times have to come back to the office.

NASCOE Position: Agency CIO should develop comprehensive plan of action to identify and solve the system-wide IT failures, whether the inability of LincPass cards being read to regular sporadic outages of FSA application software. Employees must have reliable automation tools to enable them to provide top customer service and most importantly get their job done each day. Continued calls for more submission of Remedy tickets with no recognizable results are not the answer. IT problems continue to be the Achilles heel in the daily work of our county employees.

ITSD Response: The ITSD Information Security Office (ITSD/ISO) will leverage the State Offices’ Security Liaison Representative network to identify the root cause and systems being used when the “your certificate has expired” or “your card is invalid” error messages appear. ITSD/ISO will report back to the CIO the root cause and recommended corrective actions.

Agreement: NASCOE accepts the response.

ITEM 8: Staffing/Personnel-Grades
Issue: For years now, NASCOE has expressed concern that CO PT maximum grade levels should be higher. NASCOE still believes that both PT’s and CED’s have increased responsibility and complexity due to demands created by new programs and technology. Decreases in staffing levels now have PT’s individually responsible for 4 or 5 programs instead of 2 or 3 programs. CED’s are now doing shared management with two grade 12 offices where in the past grade 11 offices were expected to be shared management. It is the opinion of NASCOE that the job of CO employees has evolved and changed requiring more diverse skills than ever before considering the staffing challenges and IT tools needed to be successful on the Farm Program side of FSA.

NASCOE Position: NASCOE requests a desk audit for both the CO PT and CED positions using private industry professional classification specialists that have knowledge of the Federal classification process.

HRD Response: HRD agrees that is time for a classification review of the CO positions but we believe that what is needed is a review of the positions as a whole, not a desk audit which deals with one individual position. We have no objections to a third party review subject to funding availability, however, please note that CO classification is not accomplished under the federal classification standards and therefore they do not apply. However, the comparison of what the classification would be IF they were reviewed under the federal classification standards could be helpful in formulating any changes to the Agency CO classification standards.

DAFO Response: DAFO agrees with HRD’s position.

Agreement: Suggest putting together a work group to review the position descriptions and determine what would or could be changed in this process. NASCOE can discuss the options on a study, but a work group will be formed in the near future. The work group would include: AO, DD, PT, CED, COC. NASCOE agreed to the creation of a work group to review the position descriptions and determine if there is a need for revision.

ITEM 9: COT Hiring Process
Issue: Currently COT’s are hired, trained and then apply for county office openings. During 2015 negotiations, NASCOE proposed hiring COT’s for the county office where the COT would be permanently placed and then training would take place. NASCOE noted that this proposal would increase applications from individuals who wanted to be in that specific county which would lead to a stable county office into the future. Management expressed openness to NASCOE’s suggested changes and NASCOE provided a white paper with concepts on how these changes might benefit county committees looking for stability and provide more opportunities for county office employees.

NASCOE Position: Just like the FLOT position, NASCOE feels that a COT should be hired for the county office where the CED position is needed. Further, this proposal is of high priority for our membership. Management has not formally responded to NASCOE’s suggested changes to the COT program hiring process. NASCOE requests that management respond in writing to the concepts submitted after the 2015 negotiation session in order to further discuss this topic and search for solutions to NASCOE’s and management’s differences.

(NASCOE’s position paper submitted after the 2015 negotiation session is attached to these items)

Mining for New Leadership in FSA
(Concerning Negotiation item #9 “COT Hiring Process”, management expressed interest in NASCOE’s suggested changes to COT hiring and leadership development opportunities. This paper presents the NASCOE response.)

The recent 2014 Federal Employee Viewpoint Survey for FSA asked employees “how satisfied are you with opportunities to get a better job in your organization?” Results showed that less than a third of employees offered a positive response. County committees are hiring COT’s that stay in a county office for 2 years and move to another county office they find more attractive. Many of these county committees endure a revolving door of CED’s leading to low morale and lack of direction/continuity for the county office staff.

Management has stated that the COT program is working adequately to fill the need for CED’s and that PT’s can apply for this opportunity and compete. NASCOE sees county offices going too long without a CED and when a COT is hired, county offices must struggle to deliver programs until the COT slot is released to use somewhere else. In addition, many PT’s have expressed they would like to apply for a COT position however can’t because of current situations and the uncertainty of where they may be placed. The door for hiring CED’s-in-training for the county office where stationed has already been opened through Hard-to-Fill provisions in paragraph 458 of 27-PM. The following recommendations will address the intent of this option and make it even more successful for employees and county committees.

Recommendation #1
NASCOE proposes that the hiring system for COT’s be changed to be comparable to the FLM/FLOT system where COT’s will be hired in the county where they will be stationed with hopes that it will be a long term career decision. This would also provide an opportunity for PT’s to apply for a COT position with the insight of knowing where they will be stationed, avoiding the potential situation of having to uproot their family. This hiring process would benefit PT’s in the advertising county as well as those in surrounding counties. Recognizing that county committees might be more inclined to hire PT’s that they know rather than the most qualified candidates; certain safeguards would need to be put in place to assure the most qualified and suitable candidates are hired. 

NASCOE suggests the following steps:

  • Smith County advertises both within and outside of FSA for CED’s and COT’s that would ultimately be the CED in Smith County.
  • All applicants apply through USAJobs.
  • A panel, similar to the one that does COT interviews currently (AO, FLC, CED, DD, etc.), conducts interviews and submits qualified candidates to the STC.
  • The STC determines the top 3-5 candidates to submit to the COC for interview.
  • The COC, with the counsel of the DD, selects a COT that will begin training for the CED position in Smith County.
  • As training progresses the selected COT will increase the amount of time spent in Smith County as he/she takes the opportunity to put into practice skills that have been developed over the course of training. The COT would progress by conducting staff meetings and COC meetings while working under the direction of a mentor who would be the temporary shared management CED.

Recommendation #2
The second part of this equation concerns Program Technician leadership/management skills. NASCOE believes FSA is missing a huge opportunity to develop leadership/management skills in our Program Technician workforce. Why not create a program that identifies PT’s with management potential and provides a career ladder opportunity to feed the FLOT and COT program rather than waiting until a PT applies and “hope” management skills are present? 

NASCOE proposes a two-year Aspiring Leadership program be developed that PT’s could apply to participate in that would train and give opportunities to enhance management skills. Through an application process, selected PT’s would take part in speech classes and leadership development programs taught by FSA as well as other organizations. FSA would also have a mentoring element to this program that would assist in oversight of the training. Participants passing this two-year program would help identify a cadre of qualified PTs that have COT/FLOT potential. Many universities have similar programs that train potential leaders in agricultural practices through comparable methods and document great success.   

In Summary
Why is a policy of hiring FLOT’s to specific counties acceptable on the GS side and not acceptable for COT’s on the CO side? Why are some FLOT’s being hired with the expectation of being placed in a “region” of the state when COT’s do not receive this same opportunity? NASCOE sees Program Technicians leaving their position for FLOT positions when the same career ladder flexibility is not made available for COT position. NASCOE recommends that changes be made in COT hiring that reflects the same opportunities that are afforded in FLOT hiring

HRD Response: The decision on how to select and train COT’s and then ultimately place them is an agency choice. From an HR perspective, both the current process and the NASCOE proposal can be supported. Therefore, we defer to DAFO for any determination on what the needs of the agency are related to this issue of COT’s being hired for specific locations vs. at-large and placed/selected as needed. Both methods have been practiced throughout government for trainee positions. There is value in an at-large program as it provides the ability to hire and train COT’s before vacancies are known and therefore the vacant CED positions can be filled more rapidly than will occur if COT’s are hired for a specific location when it becomes vacant.

DAFO Response: Not all FLOT positions have a permanent duty location cited in the announcement. We understand the NASCOE position on this issue, but it is very difficult to determine which CED position would be available at the beginning of COT training, and, in fact, openings cannot be predicted with any certainty at all, as HRD notes. DAFO will continue to review NASCOE’s position NASCOE and HRD.

Agreement: NASCOE accepts the response.

ITEM 10: Update 25-AS
Issue: The filing system to be consistent in all county offices.

NASCOE Programs Chair Response: The agency does not have a lot of flexibility in their filing guidance, as USDA released a DM indicating how all agencies should set up their filing structure. However, this was released early last year and there has still been no FSA guidance. In fact, updating 25-AS was a topic of discussion last year during the negotiation meeting with management. In October 2015, Notice AS-2291 was released indicating that the rewrite combining 2-AS and 25-AS was in the works and would be released soon as 32-AS. This has still not occurred.

NASCOE Position: The county office shall enforce the use of the new filing procedures. NASCOE is requesting the new 32-AS be released as soon as possible to ensure the compliance of all filing nationwide in both the county and state offices as well as other related offices. NASCOE also acknowledges the receipt of the Maintenance and Disposition Manual in the interim.

DAM Response: The MSD team is currently finalizing the revision to 32-AS. It is anticipated this draft will be placed in clearance on or around April 29, 2016

Agreement: NASCOE accepts the response.

ITEM 11: CRP Forms
Issue: As of 2014, county offices were required to print an FSA-848A, FSA-848B and approval for each CP-12. We were to notify each producer of the requirement and that they would need to provide receipts for a practice that has zero cost share involved.

NASCOE Position: NASCOE would like to see the FSA-848 process alleviated because the producer is already certifying the practice on the FSA-578 each year that they have it and are maintaining it. NASCOE would also like to see the CP-12 be an approved cover. As an approved cover like a pond or lake, a producer would not have to sign an FSA-848.

DAFP Response: CP-12 is an approved cover of mostly commodity crops that is considered a zero dollar practice. CEPD has received some recommendations to NOT require certifications on the FSA 848B for CP-12 Food Plots since nothing is actually earned for the completion of this practice. After numerous discussions among National, State and County office staff, CEPD agrees that this is an unnecessary step, especially when the producer has already agreed to complete the practice when the CRP-1 was approved. CEPD will modify the policy and implement the change to NOT require certification of the 848B in the next handbook amendment.

Agreement: NASCOE accepts the response.

ITEM 12: FSA-13A forms
Issue: Currently 13-A’s are complicated to fill out and are being done repetitively.

NASCOE Position: NASCOE feels that there should be a more streamlined approach and that a standardized 13-A form should be generated, by Position Description, when an employee is hired. Further, NASCOE is aware that the New Employee Training Task force has worked on a list of all access required, based on Position Description, for employees in the County Offices and has briefly discussed this possibility with Access Management. NASCOE requests that management work with the Task Force and the Access Management Team to create an automated 13-A.

ITSD Response: ITSD is working with HRD and EPD to automate employee onboarding and off-boarding communications using the Web52 system. ITSD plans on using automated notifications from the Web52 system to alert personnel involved in access processing based on the SF-52. ITSD looks forward to (in the near future) not requiring a 13-A for the addition and removal of basic access (e.g., workstation, VPN, email) that can be derived from the SF-52. Using lessons learned from this Web52 automation pilot project, ITSD will work with State Office Security Liaison Representatives, HRD and program areas to identify access that can be further derived based on Position Description. The efficiency benefits of this improvement in derived access will take time to be realized by the agency. An alternative mechanism such as the 13-A may need to remain as a back-up process to any automated process that may be implemented and to handle exceptions to the standards.

Agreement: NASCOE accepts the response.

ITEM 13: Mailings
Issue: When the National Office is sending out mailings they are overriding the “no mail” flag. Ignoring the producer’s request and overriding the “no mail” flag generates phone calls to the county office from upset producers who have specifically requested not to receive the mail. This places unnecessary stress on the producer and additional demands on a reduced work force.

NASCOE Position: Do not override the producer’s request to not receive mail when mass mailings are generated by the National Office.

DAM Response: MSD does not have the ability to override the no-mail flag as the data comes from SCIMS. We are reaching out to the EDS system engineer to review the process and ensure this is not a technical glitch. MSD will also work with DAFP and CIO personnel to verify the no mail flag is active and working properly. MSD will provide a more detailed response after we have met with the system engineer and other agency officials.

Agreement: Management will provide an update within the next two weeks and then determine how often the updates would be sent out.

Follow up from DAM: FSA has approximately 11 million customers in the SCIMS database. Annually, FSA spends approximately $18 million on postage. FSA has approximately 1.1 million customers who currently have a “no mail flag” indicator. It is estimated that this solution will save approximately $400,000 annually in postage.

MSD is also working on initiatives to address undeliverable mails and correcting change of address issues. Fixing these challenges will result in additional postage savings.

ITEM 14: Temporary/Volunteer Computer Access
Issue: Temporary employees have been used extensively during the recent Farm Bill implementation. For some of these temporaries, their tour of duty has expired and more will likely end soon. Once the temporary tour of duty is completed, the computer permissions are revoked for the employee. If the employee is subsequently called back to work, computer permissions and the eAuth process must be completed from scratch delaying the date that employee can be fully productive.

In addition, various states have had past temporaries offer their services as volunteers to county offices. Currently volunteers have been unable to receive computer permissions which severely limits their ability to contribute significantly.

NASCOE Position: For temporaries that may be called back periodically, could their computer permissions be suspended and the county office retain custody of the LincPass card? This would alleviate having to completely start over when the employee is called back to work. For volunteers, develop a method where they could have sufficient computer permissions to significantly contribute to completing the workload of the county office where they are volunteering.

EPD Response: For temporary employees, these individuals would have been issued an AltLinc versus a LincPass card. The AltLinc expires one year after the date of printing/issuance. “Suspending” an AltLinc card is likely not applicable, since the person will need to be re-enrolled for a new card if past the one-year mark.

If we were to issue a LincPass, the certificates are valid for three years and the card for five years, and we (STO HRD) may be able to suspend logical access through EmpowHR. The CED may secure the LincPass until the temporary employee reports back for work, and the STO can then “unsuspend” the card. Need some help from HRD to answer whether or not this assumption is accurate.

We—HRD and EPD—will need to keep watch of the administrative logical access suspension to ensure an employee is not in a non-active status greater than 730 days. At that point, the background investigation process will have to be reinitiated.

Volunteers are a separate issue. If we wish to provide logical access, then we process with a NACI and onboard as with any other employee.

ITSD Response: ITSD understands that quick reactivation of suspended accounts helps employees and contractors deliver FSA’s mission. Federal regulations require that systems access be limited, disabled/suspended, or removed when no longer needed. eAuth account activation is systematically controlled by actions taken by HRD or the COR in EmpowHR. eAuth has been automated by the Department to disable accounts under certain active employment conditions in EmpowHR. However, other accounts (workstation, network, VPN) can be controlled by ITSD. In order to balance security and business, accounts can be disabled/suspended which reduces the reactivation time to approximately 1 business day. Managers and CORs should contact their State Office Security Liaison Representative or the ITSD Information Security Office for assistance.

Agreement: NASCOE accepts the response.

ITEM 15: Compliance Issues
Issue: In the past, compliance was a very large part of what we did. Producers knew that we did compliance checks and we did a lot of them. Integrity for our programs has always been an important part of what we do. Over the years we have gotten further and further away from compliance, partly due to staffing, however, it is really starting to show. We are seeing more and more violations than ever before, and part of it is because producers know we are not coming out. Regardless of our heavy workload and reduced staff, compliance needs to become a priority again. GIS is a great tool and can be used for a lot of things, but there are some things that we cannot use it for.

NASCOE Position: Make sufficient resources available and give county offices the ability to be in the field more. An increased physical presence in the field will increase program integrity and discourage future compliance issues.

DAFP Response: As indicated, budget restraints have been prohibitive of completing a large number of compliance checks; therefore, it is recommended communicating the need with DAFO to see if additional funds can be made available for compliance activities. Until such time as additional funds are available, offices should take advantage of any opportunity when required to have a physical presence in the field and add compliance activities, which would have limited cost.

Agreement: NASCOE accepts the response.

ITEM 16: Opportunity to Apply for Positions
Issue: Some states are telling grade 7 Program Technicians they are not eligible to apply for grade 9 FLOT positions. There are situations where grade 7 PT’s are permitted to apply for FLOT positions in various states. NASCOE understands that management is interested in upward mobility opportunities for program technicians based on USDA-FSA’s strategic goals and making sure all grade 7 PT’s understand their opportunity to apply for grade 9 FLOT positions would seem to meet those goals.

NASCOE Position: NASCOE requests that management clarify the opportunities for grade 7 PT’s to be eligible for grade 9 positions such at FLOT. Further, please make sure states are educating grade 7 PT’s on opportunities to apply for positions above grade 7.

HRD Response: Employees should never be left with the impression they are prohibited from applying for a vacancy announcement as long as they are within the area of consideration. However, it is a common practice for HR and administrative staff to explain eligibility and qualification requirements for FSA positions to help the applicants understand what those are. HRD will communicate to the States the need to continue to inform and educate any potential applicant on the various eligibility and qualification requirements but to do so in a manner that does not leave them with the impression they are prohibited from applying.

It is also important to note that not all grade 7 PTs will be qualified for FLOT positions as the 9 level. It depends on the experience and or education each PT has. If qualifying based on their experience as a grade 7 PT, then that experience (at that grade level) must be directly related to the FLOT duties. Not all PT’s are performing duties that are directly related to the FLOT duties.

FYI – This would include experience that demonstrates basic knowledge of loan examining and/or servicing principles, procedures and techniques as they apply to investigation, analysis, and evaluation of financial factors and credit risks in relation to granting and servicing of agricultural loans. Experience may have been gained in such work as assisting in reviewing and passing upon applications for agricultural loans; servicing an agricultural loan portfolio of a bank or other loan association; or similar work. In addition, this experience must demonstrate basic knowledge of farm operations, land use and value, production of various crops and livestock, and prices and markets in the farming area where loans are made and serviced. The agency must use this experience requirement as it is part of the government-wide qualification standards administered by the Office of Personnel Management.

DAFO Response: DAFO agrees with the HRD position.

Agreement: NASCOE accepts the response.