The underlying duties and organization must support the claim. A percentage does not transform routine operational work into qualifying management.
Explain what the time is actually spent doing
Use a reasonable account of recurring activities and authority. Avoid double counting and explain variation rather than presenting invented precision as evidence of managerial capacity.
Identify what the applicant manages and how others perform underlying work. Identify how often that discretion is exercised, who prepares the underlying analysis, whether subordinates or professionals carry out the routine work, and what headquarters can still reverse. Cross-check any stated share of time against a representative week of calendar entries, signed approvals and messages directing subordinates, since a round figure carries less weight than specific evidence of what actually filled that time. Compare a slower period against a busier one rather than relying on a single sample week, because a percentage drawn from only the busiest stretch can overstate how consistently the applicant's time is actually spent managing rather than performing tasks personally. Where a tool, template or automated process now produces work a person once did by hand, explain how that shift changed what the applicant personally contributes to the underlying decision, so the stated percentage reflects the role as it currently operates rather than an earlier description that no longer matches daily practice. Ask whether the same percentage was reported for every prior filing or was recalculated for this one, because a figure that never changes despite genuine shifts in staffing or workload reads as a repeated estimate rather than a fresh accounting of the current role.