BY WAY OF defending his record of concern for women, President Reagan Monday again asserted that he has substantially outpaced his immediate predecessor in appointing women to top executive positions. Not so, the National Women's Political Caucus once more replied, citing data compiled by the U.S. Commission on Civil Rights and its own independent counts showing the proportion of Reagan appointments going to women to be well below the Carter rate. Which numbers are right?

Part of the discrepancy can be accounted for by differences in what is being counted. The White House, for example, claims that 94 women received presidential appointments to full-time jobs during the first two Reagan years. Some of these, however, were merely appointments to staff positions not requiring Senate confirmation. The number also includes women who have already come and gone. Anne Gorsuch Burford and Rita Lavelle are two examples that leap to mind. On the other hand, the White House excludes judicial appointments, a category in which, with the notable exception of Justice Sandra Day O'Connor, the Reagan administration has not done very well by women.

If you take account of the acceleration of female appointments during the first part of 1983 and remove from the Reagan claim the staff aides who don't belong in the comparison in the first place, you will come up with a number close to the Civil Rights Commission's estimate, which is also based on White House data. The commission recently reported that President Reagan had appointed 68 women to nonjudicial top-level positions during his first 27 months in office, including those who have already left, dual appointments and appointments still pending. The Caucus credits him with 78 such appointments to positions requiring Senate confirmation by June 1983, and inspection of the Caucus list shows the omission of two others. That--if you can stand any more--is not far from the White House's latest claim of 83 appointments to such positions up through July 11 of this year. So we are agreeing on 80 or so for the Reagan figure.

But how well did Jimmy Carter do? Here (no surprise) the claims also diverge. The Caucus says Mr. Carter appointed 97 women to positions requiring Senate confirmation, and provides a list; aside from two women who seem to have been counted twice for the same position, it holds up under inspection. But the Reagan White House says that Mr. Carter chose only 76 female presidential appointees during his first two years in office, declining to provide a list because of a "major malfunction by the computer." For its part, the Civil Rights Commission has no two-year Carter numbers. Its records--compiled in 1980 from White House data--show that as of October 1980 the Carter administration had 98 women in top-level positions, not including 45 judgeships. This gives President Carter, near the end of his term, an 11 percent nonjudicial appointment rate compared with an 8 percent rate for President Reagan so far.

The commission number, however, does not include women who had already left the Carter administration or switched jobs, so that a running total of appointments would have been still higher. On the other hand, it represents the net result of almost four years in office, and it is possible that the Carter administration, like the Reagan administration, speeded up its female appointments in later years.

So far, it appears, President Reagan has appointed fewer women to positions requiring Senate confirmation than President Carter did. The difference is not huge, and it's not fair to accuse Mr. Reagan of tokenism; his administration includes some women of genuine stature. But the numbers don't back up Mr. Reagan's assertion that he's appointed more women to top executive jobs than his predecessor did.