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03/14/2011
MEMORANDUM FOR HUMAN RESOURCES DIRECTORS
From:

ANGELA BAILEY
DEPUTY ASSOCIATE DIRECTOR RECRUITMENT AND DIVERSITY

Subject:
Classification of Freedom of Information Act Positions

In support of the President’s commitment to transparency in the Federal Government and to the improved administration of the Freedom of Information Act (FOIA), the U.S. Office of Personnel Management (OPM) is providing clarifying guidance on the classification of positions responsible for administering FOIA.  This clarification facilitates Governmentwide workforce planning and management, while emphasizing the significance of the Federal Government’s responsibility for administering the FOIA. 

The primary FOIA position is one for which the principal requirements are subject matter knowledge of the FOIA itself, including its principles, concepts, policies, and objectives, as well as analytical ability, judgment, and discretion.  This position may be most appropriately classified to the 0301, Miscellaneous Administration and Program Series.  Agencies may utilize other personnel to support or advise the primary FOIA position.  For example, positions involving such activities as receipt, control, and tracking of FOIA requests constitute administrative aspects of the function for which the 0341, Administrative Officer Series, is generally appropriate.  Finally, some agencies utilize program experts to review and analyze the sensitivity of requested information for the purpose of advising the person holding the primary FOIA position.  Those officials’ positions are classified based on programmatic responsibilities and requirements.  

For those FOIA positions classified to the 0301 occupational series, agencies should assign the official title of “Freedom of Information Act Officer” or “Freedom of Information Act Specialist.”  Application of this titling guidance will ensure Governmentwide consistency and assist agencies in distinguishing these positions.  FOIA positions in other occupational series, including 0341, should be titled according to the applicable classification standards and guidance.

If you have questions or would like additional information, please contact your agency’s assigned OPM Human Capital Officer.

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