Faction Abilities and Concentration Checks

I was writing a story where a Guvner is grappled and attempts to use the faction feat Evaluating The Outcome to bend probability and improve her chance of breaking free. Then, I realized that she shouldn't be able to attempt this without making a Concentration check. After all, it takes quite a bit of intellectual effort to bend the laws of probability. 3.5 uses a DC of 20 + spell level for casting spells while grappled; Pathfinder uses 20 + grappler's CMB + spell level. Either way, what level of spell would this — or other — faction abilities be rated as?