The following is an attempt to present my thoughts and experiences with dealing with the structure of a unit. Specifically, it highlights how rating regulations restrict how you can structure your unit.

Up front, you’re probably thing “Dude, just go download the MTOE or TDA from FMSweb.” FMSweb does provide an outstanding starting point. However, it is very easy to misinterpret these authorization documents. Also, these documents only give a best guess at what your unit will “have”, whether it’s equipment or personnel or both.

The point of this discussion is not to talk overlong about the MTOE or TDA, but to look at the gaps in what’s provided and how you determine how to organize, mostly administratively.

As an AIT commander, my unit was governed by a TDA. Our TDA was a subsection of the larger Engineer School TDA. I was given command over four separate UICs (3 permanent party and one trainee UIC). One of my permanent party UICs contained the expected company cadre (CDR, 1sG, XO, AIT PSGs, etc.). The second UIC was a equipment support section. The third was a UIC that contained ~60 military instructors as well as the authorization for civilian instructors.

What makes this worth a discussion is that third UIC, the instructor section. As we all probably know, each UIC lists all the required and authorized personnel. Now, one thing I learned is that the one in charge of whatever paragraph we’re talking about in the TDA is listed first. So for any company MTOE, you will always see the CDR listed first. This probably seems self-evident and unimportant. I promise we’re going to get somewhere with all this.

The first person listed on the instructor subparagraph was the Chief (a GS12 Civilian). So this chief should be in charge of everyone listed under that TDA portion, correct? I would say yes. However, my Leadership had concerns about the impacts on the military instructors (specifically the SFCs). In their eyes, a SFC without at least a CPT as the senior rater would make them non-competitive for the board.

The result of this decision led to a rating scheme that caused a lack of unity of command. The SFCs were rated by a GS09 civilian (whom I was not in the rating chain for) and senior rated by me (the company commander). The issue here is that it is not in accordance with AR 623-3 (the one that governs NCOERs and OERs). The regulation states that the rater must be the individual who directly oversees the rated Soldier, and the senior rater must be the rater of the rater. However, this issue would be very hard for HRC to figure out, so your NCOERs still go through (that does not make it right though).

After many hours of research and work and many briefs, I was able to get my leadership to understand that the rating scheme was not IAW regulation. This meant we needed to change the rating scheme and portions of the unit structure.

During my analysis of the problem, there was another factor that further restricted the possible structure of the unit. AR 623-3 sets a rank requirement for the senior rater. This is generally a non-issue for most units. For a SFC, the senior rater must be at least a SGM (E9) or a GS09, MSG(P) does not meet the requirement. It is open for discussion whether the regulation requires the rank to be held currently by the NCO, or if them being assigned to a higher rank position allows them to senior rate at that grade. My interpretation is they must hold that rank. Unlike the rater/senior rater relationship as mentioned above, HRC could potentially kick back NCOERs that don’t meet the rank requirements. This happened occasionally.

Essentially, all things considered, there were two options that I pitched which would have satisfied the regulation (if we were ideally staffed).

-Option 1: Place all military instructors on the rating scheme under the company commander. The senior instructor (E8) would rate E7 instructors and senior rate E6s. Issues: The senior instructor position had been historically filled by an E7. SFCs cannot senior rate SSGs. Also, the civilian instructors at each area are “in charge” of the area, so you run in to the issue of the NCO being able to say “I don’t work for you”. Essentially, this option would take the unity of command issue and push it a few levels down.

-Option 2: Remove the commander from the senior rating position. E7 instructors would be senior rated by a GS11. Issues: This removes the ability of the commander to influence evaluations. The only tool to enforce compliance would be threat of UCMJ/administrative action.

In the end, my Leadership did something different. They elected to have the section’s SGM position (held by a MSG(P), reference the above discussion on rank requirements). They pitched having the Chief (and all of his subordinates) placed under my supervision, but our higher HQs denied that due to another Army Regulation that sets recommended rank equivalents for civilians.

So, in the end, does your unit have organization issues? Hopefully not, and hopefully they are not as complicated as mine was!