Department of Veterans Affairs v. Federal Labor Relations Authority

Opinion for the court filed by Circuit Judge BUCKLEY.

BUCKLEY, Circuit Judge:

The Portland, Oregon office of the Veterans Administration implemented new performance standards that it proposed to enforce by sampling a portion of its employees’ work product. In response, Local 1974 of the National Federation of Federal Employees submitted two bargaining proposals that contemplated the use of a particular statistical methodology to ensure the accuracy of the sampling process. We agree with the Federal Labor Relations Authority that these proposals were procedural in nature and hence negotiable…