Washington DC
U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code
Director Mental Health
Naval Medical Center
Bureau of Medicine and Surgery
U.S. Department of the Navy
San Diego, California
GS-185-12
Damon B. Ford
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance
02/05/2019
Date
As provided in section 511.612 of title 5, Code of Federal Regulations (CFR), this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government. The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision. There is no right of further appeal. This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).
As discussed in this decision, our findings show the appellant’s official position description (PD) does not meet the standard of adequacy described in section III.E of the Introduction. Since PDs must meet the standard of adequacy, the agency must revise the appellant’s PD to reflect our findings. The servicing human resources office must submit a compliance report containing the corrected PD and Standard Form 50 showing the personnel action taken. The report must be submitted within 30 days from the effective date of the personnel action to the Office of Personnel Management (OPM), Agency Compliance and Evaluation, Washington, DC, office.
Introduction
The appellant’s position is currently classified as Social Worker, GS-185-12, but he believes it should be classified at the GS-13 grade level. The position is assigned to Substance Abuse, Director Mental Health, Naval Medical Center, Bureau of Medicine and Surgery (BUMED), U.S. Department of the Navy, in San Diego, California. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).
General issues
The appellant believes he performs work similar to nonsupervisory Psychologist, GS-180-13, positions assigned to his organization. By law, we must classify positions solely by comparing his current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112). Since comparison to PCSs is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions, which may or may not be classified correctly, as a basis for deciding his appeal.
Like OPM, the appellant’s agency must classify positions based on comparison to OPM standards and guidelines. However, the agency also has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions. If the appellant considers his position so similar to others that they all warrant the same classification, he may pursue the matter by writing to his agency’s human resources headquarters. In doing so, he should specify the precise organizational location, classification, duties, and responsibilities of the positions in question. If the positions are found to be basically the same as the appellant’s position, the agency must correct the classification of the positions to be consistent with the appeal decision. Otherwise, the agency should explain to the appellant the differences between his position and the others.
Position information
The appellant’s position is assigned to the Substance Abuse Residential Program (SARP), which provides drug and alcohol assessment, consultation, education, outpatient treatment, residential treatment, and continuing care services to active-duty service members from all branches of the U.S. military. One of five nationwide programs, the appellant’s SARP typically provides services to commands or mobile units geographically located west of the Mississippi River and across the Pacific Ocean. SARP provides various treatment levels, but the appellant’s position supports the 35 day, 24 hour, seven days a week residential treatment program designed to treat patients with substance abuse/dependence issues and co-occurring psychiatric disorders. Patients are required to reside in the assigned facilities to attend treatment including, but not limited to, individual and group counseling, life-skills workshops, groups for disorders (e.g., depression, anxiety, and post-traumatic stress disorder), recreational and fitness activities, medical and other assessments, and 12 step recovery programs and other support groups.
As a Licensed Independent Practitioner (LIP), the appellant leads one of the SARP’s seven treatment teams comprised of one GS-101-11 Senior Substance Abuse Counselor; one GS-101-9 Substance Abuse Counselor; and three military personnel performing GS-101-9 equivalent work. The team assesses and treats patients who are not coping well in life because of substance abuse and other co-occurring disorder issues. Along with team members, the appellant assesses the background of patients with alcohol dependence, substance abuse, and psychiatric disorder issues; manages cases; and conducts in-depth individual and group counseling and therapy. The team treats an average of eight to 12 patients every five weeks. The appellant is responsible for the overall treatment of patients, approving and, when necessary, modifying treatment plans for patients. As the LIP, he carries full professional responsibility for patients presenting a wide range of psychosocial problems. His position requires exercising mature and professional judgment to use a wide range of social work skills for serious and complicated cases. Furthermore, BUMED Instruction 6010.30 requires social workers serving as LIPs, like the appellant, to have obtained a master’s degree in social work (MSW) from a graduate school of social work accredited by the Council on Social Work Education, completed at least two years full-time postmaster’s degree of supervised clinical social work experience, and have the highest current State licensure as a clinical social worker to practice independently. The appellant is supervised by a psychologist serving as the Residential Division Officer (an O-5 Commander), who reports to the Deputy Department Head (a Supervisory Social Worker, GS-185-13, position).
The appellant and first-level supervisor certified to the accuracy of the appellant’s official PD, number P500905. However, our review found his PD includes work not currently performed or inaccurately describes work performed. In contrast to the PD, he does not perform his duties in an outpatient clinic, but rather in an inpatient residential facility. He is not responsible for providing treatment to family members and retirees; marketing and promoting programs to patients, families, hospital staff, ancillary programs and services, and other military service providers; or participating in the Naval Medical Center’s social worker after-hours pager watch or consult watch. His PD incorrectly states his treatment team includes a family counselor, psychologist, and medical personnel. The PD also describes performing innovative program development and evaluation work. As discussed later in the decision, we disagree. Therefore, the appellant’s PD does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and the agency must revise the PD to reflect our findings.
In reaching our classification decision, we carefully considered all information provided by the appellant and his agency including his official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to gain more information about his work, we conducted a telephone audit with the appellant and telephone interviews with his first- and second-level supervisors.
Series, title, and standards determination
The agency assigned the appellant’s position to the GS-185 Social Work Series and titled it Social Worker. The appellant does not disagree and, after careful review of the record, we concur.
The appellant’s request to OPM includes an evaluation of his position based on application of the Primary Standard, which serves as the “standard-for-standards” for the Factor Evaluation System (FES). See Appendix 3 of the Introduction. The appellant seeks to credit his position at Levels 1-7, 2-5, 3-5, 4-6, 5-5, 6-3, 7-3, 8-1, and 9-1. However, the Primary Standard is not to be used in place of more appropriate grade-level criteria nor is it to be used alone to classify a position except when a factor level fails to meet the lowest, or exceeds the highest, level in the applicable FES standard. Therefore, our evaluation considered only the grade-level criteria directly applicable to the appellant’s position.
The Classifier’s Handbook provides the following guidance on the application of classification standards:
Standards do not describe all possible kinds or combinations of work in a particular occupation. This would be impossible because of the changes that occur so frequently in how some work is assigned and performed and in how some missions and organizations are structured. An attempt to completely describe how work is structured in all components of all agencies also would be an impossible task. In any case, the final evaluation decision is based on an evaluation of the whole position against appropriate grade level criteria following established classification policy and procedure.
Therefore, we evaluated the appellant’s position using two different standards. First, we applied the grading criteria in the GS-185 PCS, which is directly applicable to the classification of nonsupervisory social work positions in which primary emphasis is on direct professional service to individuals and families. Issued in June 1964, the GS-185 PCS has certain limitations in evaluating the appellant’s position as it was designed to measure the relative grade value of the kinds of social work positions prevalent in the Federal Government over fifty years ago. Although the GS-185 PCS identifies the action sequence of social workers as “study, diagnosis, and treatment” that appears to similarly describe the construct of the appellant’s position, the standard specifically describes the treatment sequence as providing indicated services, authorizing benefits, making referrals, and giving advice, guidance, and emotional support to individuals. Furthermore, social workers at the higher grade levels make independent professional decisions and recommendations for agency actions with serious impact on the persons served, e.g., separating members of families, approving adoptive parents, and placing delinquents in protective custody.
Today’s social workers, like the appellant, increasingly address the mental health needs of military service members returning from wars in Afghanistan and Iraq and other conflicts. Unlike the treatment description and decisions described by the GS-185 PCS, the appellant’s work and decision-making is focused principally on the treatment of an individual to modify attitudes, feelings, and behavior patterns. Our interviews and review of his PD and performance standards confirm his position requires the incumbent to be a licensed clinical social worker (LCSW), which entails a significant degree of training after graduating with a MSW degree and includes the mental health counseling branch of social work. The LCSW requires an understanding of the psychological, social, economic, and medical influences affecting an individual’s ability to live normally. Because the LCSW makes psychosocial diagnoses and employs a range of specialized treatment modalities appropriate to the treatment program, we conclude the GS-185 PCS is not adequately reflective of the knowledge and educational preparation required of the appellant’s position.
The appellant’s first- and second-level supervisors confirm that SARP’s LIP positions are filled by either a social worker or a Psychologist, GS-180. The LIPs are responsible for assessing and evaluating a patient’s mental health, making judgments on the best course of treatment based on the diagnosis, providing clinical training to counselors, etc. Patients are randomly assigned to one of seven treatment teams. The social workers and psychologists, as LIPs, thus employ functionally similar mental health diagnostic procedures and mental health therapies. In addition to similarities in the nature of their work, employees classified to the GS-180 and GS-185 series have comparable education requirements, e.g., while the social worker requires an MSW degree, counseling psychologists require satisfactory completion of two full academic years of related graduate study or a related master’s degree from an accredited educational institution, while clinical psychologists require satisfactory completion of a doctoral degree related to the field. Furthermore, to become a LCSW in the State of California, an applicant must possess a MSW degree; obtain at least 3,200 hours of supervised work experience (at least 2,000 of those hours must be in the areas of clinical psychological diagnosis, assessment, treatment, and counseling and at least 750 hours must be spent performing face-to-face individual or group psychotherapy); and complete additional required coursework in various areas including alcoholism and other chemical substance dependency. Therefore, to supplement the grading criteria provided in the GS-185 PCS, we consulted the PCS for the Psychology Series, GS-180, issued in June 1968, which describes positions involving professional work relating to the behavior, capacities, traits, interests and activities of human and animal organisms and involves applying knowledges of psychological principles, theories, methods, or knowledges of psychological principles, theories, methods, or data to practical situations and problems. We also found the GS-180 PCS addresses work at the GS-12 and GS-13 grade levels involving assessment and counseling assignments similarly performed by the appellant’s position. Between the GS-180 and GS-185 PCSs, applied separately and in full, a fair and accurate assessment of the appellant’s work is possible.
We also considered the appellant’s position against the General Schedule Leader Grade Evaluation Guide (GSLGEG). Part II of the GSLGEG is used to classify positions whose primary purpose is, as a regular and recurring part of their assignment and at least 25 percent of their duty time, to lead a team of other GS employees in accomplishing two-grade interval work that meets at least the minimum requirements of Part II. To be classified by application of Part II, positions must spend at least 25 percent of their time exercising the minimum authorities and responsibilities required for coverage (i.e., all of the first seven coaching, facilitating, and mentoring duties and a total of 14 of the 20 duties listed on pages 10-11 of the GSLGEG). The appellant leads a five-member counseling team including a GS-11, GS-9, and three military personnel performing work equivalent to the GS-9. Our review of the PD for the GS-101-11 Senior Substance Abuse Counselor shows the position also performs leader responsibilities including, but not limited to, coordinating and maintaining daily activities of the counselors, overseeing staff duties, and evaluating and monitoring staff. Given the level of independence inherent in the GS-11 senior counselor and because that position also performs leader-related responsibilities, we conclude the appellant is precluded from meeting the minimum 25 percent criterion. Furthermore, his first- and second-level supervisors estimate he spends less than 25 percent of his time on leader duties. Because the appellant does not spend at least 25 percent of his time on team leader duties, his position is therefore excluded from GSLGEG coverage.
Grade determination
Evaluation using the GS-185 PCS
The GS-185 PCS uses two basic elements to define assignment characteristics, assignment content and supervisory control. Two basic variables that affect the grade levels of positions are (1) the character of the caseload; and (2) the freedom of practice characteristic of performance. The first refers to the difficulty of problems present in the assignment and the degree of professional skill and judgment required by the social work decisions and the services they involve. The second reflects the recognition of the social worker’s competence through decreased supervisory control that allows independent performance of work. These variables are considered in concert when making grade level determinations.
At the GS-11 level, social work assignments involve intensive social work services requiring the exercise of mature professional judgment and the flexible use of a wide range of social work skills. This level represents performance of services in serious and complicated cases with demonstrated effectiveness based on sufficient training and experience to require a minimum of supervisory control and guidance, and permit independent exercise of authoritative judgment. GS-11 social workers carry full professional responsibility for cases presenting a wide range of psycho-social and environmental problems with no limitations as to the difficulty of services that would be performed. At this level, social workers make independent professional decisions and recommendations for agency actions that can have serious impact on the life of the person served. At this level, techniques of service involved in the effectiveness of social work practice frequently demand highly developed professional skills, as, for example in motivating a psychiatric patient with a marginal adjustment toward resuming more effective control of his/her own life. At the GS-11 level, difficult professional services to clients with serious problems are not incidental but rather regularly performed on a continuing basis with infrequent recourse to supervisory guidance.
GS-11 social workers actively participate in program planning and in the development and maintenance of public understanding and sound working relationships with local agencies and community resources. At this level, social workers evaluate and advise medical staff of social factors relating to illness; have responsibility for social work aspects of integrated treatment programs; and furnish continuing social work services to patients and their families while they are learning to live with illness or disability of a family member. Also included at this level are assignments involving responsibility for providing continuing social work services at field locations without a supervisor available for consultation.
At the GS-11 level, social workers independently give interpretations of case histories to other professionals or persons involved in the case and make recommendations that can be relied on for soundness of judgment and maturity of insight on problem cases. The supervisor is kept informed of the progress of the work and is available for consultation on substantive problems. GS-11 social workers are accountable for identifying problems that should be brought to the attention of the supervisor, and for taking the initiative in determining when the supervisor should be consulted.
At the GS-12 level, the highest level described in the PCS, social worker positions are of two general types: (1) supervisory positions that include full technical and administrative responsibility for the accomplishment of the work of a unit of three or more subordinate professional workers when the base level of the unit fully meets the GS-11 level as defined in the GS-185 PCS; and (2) positions which are classified at this level in recognition of program responsibilities which are significant enough to justify grade GS-12 with or without the presence of professional subordinates.
Illustrative of positions of the second type are those of social workers in charge of the social work program at a separate installation or organizational component where they are responsible for development and maintenance of professional standards of service, initiating and effecting changes in methods that will promote efficient practice, and coordination of social work services with other programs of service to the same group of clients. They typically represent the social work program at conferences and in contacts with other agencies and the public. Work is subject to regulation and procedural direction from the program directors in the central office of the agency and to the local management control of the directors of the institution, such as a clinic or correctional institution. Another illustration of the second type describes social workers responsible for serving various beneficiary groups scattered over a large geographical area when assignments include direct social work practice in cases with complex problems, developing and coordinating procedures for the use of community services by related and satellite staffs, etc.
Basic responsibility for a program of social work services does not justify classification at the GS-12 level unless there is substantial accountability for program effectiveness, modification of service patterns, and promoting acceptance of the social work function. As distinguished from positions at the GS-11 level which are responsible for providing continuing social work services at a field location, positions classified at the GS-12 level on the basis of program responsibilities characteristically combine program development and evaluation with service functions.
The appellant’s position meets the GS-11 level. Similar to this level, his position operates with wide latitude and requires mastery of social work skills and independent professional judgment to provide social work services to patients with a wide range of psychosocial and environmental problems. The appellant manages all social work aspects involving the integrated treatment of patients with substance abuse/dependence issues resulting in emotional disorders. He conducts intake assessments; develops, modifies, and approves comprehensive treatment plans; provides individual and group counseling; and identifies and recommends further continuing care needs post-treatment. This is equivalent to the GS-11 level where intensive social work services require mature professional judgment to exercise use of a wide range of social work skills. As at the GS-11 level, the appellant seldom seeks guidance from his supervisors, and then only on substantive problems or decisions of an unprecedented nature (e.g., policy exceptions).
The appellant’s position does not meet the GS-12 level. His position does not perform either the supervisory or program responsibilities characteristic of the GS-12 level. He is not responsible for developing and maintaining professional standards of service at the SARP, initiating and effecting changes in methods to promote efficient practice, and coordinating social work services with other programs of service. In addition, he does not regularly represent SARP’s social work program at conferences and in contacts with other agencies and the public. He also does not serve various beneficiary groups scattered over a large geographic area. Unlike the GS-12 level, the appellant’s position is not assigned substantial accountability for program management or effectiveness. For example, he is not responsible for identifying and evaluating program deficiencies, developing action plans to correct identified problems, or implementing corrective actions to improve the program’s effectiveness, efficiency, and resulting patient care delivery. The appellant’s decision-making authorities and program responsibilities are limited to his assigned patients and do not extend outward to the overall residential treatment program. His first- and second-level supervisors are the decision-making authorities for such responsibilities.
Therefore, the aspects of the appellant’s work that are covered by application of the grading criteria in the GS-185 PCS are properly graded at the GS-11 level.
Evaluation using the GS-180 PCS
The GS-180 PCS uses two broad factors for making a grade level determination: Nature of assignment, which includes the knowledge required and complexity of the work, and Level of responsibility, which includes supervisory controls, guidelines, and contacts.
Nature of assignment
Psychologists at the GS-12 level carry out the full range of work in their specialized area and are professionally responsible for the soundness and validity of their recommendations, reports, and services. GS-12 psychologist positions differ from those of lower levels in that work assignments cover the range of problems in their specialized field, require the use of a broader range of techniques and methods, and are performed with less need for consultation with superiors.
At the GS-12 level, counseling psychologists provide psychological services to a broad range of clients presenting many combinations of vocational education, physical, and emotional disability problems. They are responsible for managing all but the most specialized of personality assessment or evaluation that is likely to arise in the counseling situation. They recognize the need for personal adjustment counseling and may provide such counseling over a period of time with professional responsibility. Counseling psychologists at the GS-12 level are responsible for clients requiring special rehabilitation techniques and resources such as (1) those with serious multiple disabilities, (2) those who are homebound because of their disabilities, (3) those who have seriously incapacitating reactions to their physical disabilities, and (4) those who have a long history of chronic mental disability and inability to adjust to social and occupational requirements. Many of these clients require skillful assistance through a variety of therapeutic counseling techniques. GS-12 counseling psychologists are responsible for making professionally sound recommendations on such critical matters as feasibility of education, training, and rehabilitation, desirability of hospitalization, or need of intensive psychotherapeutic intervention. At the GS-12 level, counseling psychologists carry out the full range of vocational, and education counseling services, practices, and techniques. Their assignments differ from those characteristic of GS-11 in terms of the broad range of clients with whom they deal. They typically provide extended personal adjustment counseling services for those clients requiring such counseling rather than referring them to others once the need has been recognized.
Psychologists at the GS-13 level are characteristically highly skilled in the delivery of professional services and serve as resource people to other psychologists, staff members, and operating officials. They work with full professional responsibility for their actions and advice. Positions at this level differ from GS-12 psychologist positions in the complexity of the cases assigned and in their being called upon to serve as advisers, consultants, and resource people to other persons concerned with patient treatment and care.
At the GS-13 level, counseling psychologists provide highly skilled counseling services to clients with difficult and complex problems of personal adjustment or vocational rehabilitation. They typically deal with such clients as: (1) multiple paraplegics or other homebound clients, who have severe emotional or family relations problems resulting from their disability, (2) chronic mentally disturbed patients or alcoholics, or (3) mentally disturbed or other clients with a long history of unsatisfactory vocational adjustments. Counseling psychologists see clients who are either initially assigned to them or who are referred to them by other staff psychologists who are not as experienced in counseling such difficult cases. GS-13 counseling psychologists also serve as advisers to other staff members who are working with clients having problems of the type described above. GS-13 counseling psychologists establish and maintain effective working relationships with other related professional services and activities of the organization. This includes establishing and maintaining effective liaison with Government and private agencies and potential employers to aid in vocational placement and rehabilitation of acutely or chronically disabled persons.
The appellant’s position fully meets the GS-12 level. As at this level, he carries out the full range of work in the specialized area and is professionally responsible for the soundness and validity of recommendations, reports, and services provided by his team. His work requires a comprehensive theoretical knowledge base of his specialized area of mental health. The population served, generally characterized as young active duty patients with significant emotional disabilities and risk factors (e.g., impulsive behaviors destructive to themselves or others, lack of support systems, and poor coping skills), are dealing with substance abuse issues and mood, anxiety, thought, and other co-occurring disorders and problems. The appellant and his team conduct a comprehensive specialized psychosocial assessment of patients referred to the residential program. During the initial screening, which follows the American Society of Addiction Medicine criteria, the team gathers information on biopsychosocial elements including, but not limited to, family history, developmental history, addictive history (alcohol, tobacco, and other drug use), personal history, legal history, psychiatric history, medical history, spiritual history, and administers a mental status examination. The appellant identifies the most suitable level of care based on a determination of the severity of the patient’s disorder, as well as any co-occurring disorders arising within the context of the screening. If he identifies an imminent risk to self (the patient) or others, he will arrange to have the patient transported to the hospital immediately. By reference to the Diagnostic and Statistical Manual of Mental Disorders, which is the standard text on the symptoms and diagnostic features of addictions and other recognized mental illnesses, the appellant classifies the severity of the disorder based on the number of criteria met (e.g., inability to stop using the substance, cravings and urges to use the substance, and continued use of the substance despite it causing relationship problems). The clinical and historical information gathered by the appellant and his team are then incorporated into an integrative summary report which they use as a guide in the treatment of the patient.
Similar to the GS-12 level, the appellant is responsible for patients requiring special techniques and resources such as those with a long history of chronic mental disability and inability to adjust to social and occupational requirements. Because he provides counseling services to a broad range of patients exhibiting many combinations of emotional and physical problems, his position requires professional knowledge in a wide variety of mental health theories applicable to individual and group modalities. The SARP has adopted various evidence-based interventions shown to be effective with their population such as motivational interviewing, cognitive behavioral therapy, exposure therapy, eye movement desensitization and reprocessing therapy, reality therapy, interpersonal therapy, and psychopharmacology. As LIP, the appellant approves treatment plans outlining the goals and strategies for overcoming the mental health issues specific to the patient. His patients require individual skilled assistance to navigate through the variety of therapeutic counseling and treatment techniques as expected at the GS-12 level. The appellant applies cognitive processing therapy and other treatment practices when providing individual counseling to patients with posttraumatic stress, borderline personality disorder traits, depression, anxiety, and other disorders. In addition, he is responsible for the dialectical behavior therapy group designed to guide patients by replacing harmful behaviors with life-enhancing ones. Based on the individual treatment plan, the patient may also participate in specialty groups to address depression, anxiety, hygiene, and other issues; small and large group counseling; workshops; recreational activities; and/or 12 step recovery programs and other support groups. The appellant regularly meets with his team members to discuss any unaddressed patient issues (e.g., discovered trauma symptoms) that require modification of treatment plan objectives.
The appellant’s position does not meet the GS-13 level. While he treats high risk and severe (e.g., suicidal) chronic mentally and emotionally disturbed patients or alcoholics, unlike the GS-13 level he is not regularly called upon to serve as an adviser, consultant, or resource person to other staff members concerned with the treatment and care of patients having problems of the type described above. Also in contrast to this level, the appellant is not responsible for establishing and maintaining effective working relationships with other related professional services and activities of the organization, including establishing and maintaining effective liaison with Government and private agencies to aid in vocational placement and rehabilitation of acutely or chronically disabled persons.
This factor is credited at the GS-12 level.
Level of responsibility
At the GS-12 level, psychologists operate as mature professionals in their particular areas of assignment. The nature of their responsibility is similar to that described at the preceding level (e.g., psychologists are responsible for carrying out their professional duties in accordance with generally accepted psychological theories, methods, techniques, and practices). The responsibility of the psychologist is enhanced, however, by the seriousness of the problems they are called upon to solve at the GS-12 grade level, the diversity and complexity of the methods and techniques employed, and the breadth and depth of knowledge which they must employ in resolving the problems posed by their assignments. Typically, the course of action decided upon by the GS-12 psychologist is accepted as being professionally sound in light of current scientific information. Working relationships with their superiors are largely consultative. They keep their superiors informed of the status and progress of individual cases and projects. They may seek advice from senior specialists on unusual or uniquely complex client responses, and similar matters, or on matters of agency policy, practice, and requirements. Personal work contacts are similar to those at GS-11. They are enhanced in importance by the greater complexity of the subject matter dealt with, and the added weight which is given to the observations of psychologists occupying positions at this level.
At the GS-13 level, psychologists exercise full professional responsibility for their findings, interpretations, decisions, recommendations and reports. They keep abreast of new concepts and techniques in their specialty areas and apply them as appropriate in direct services work. They must be thoroughly familiar with all aspects of their employing agencies’ policies, program objectives, and established practices as these affect the psychology program. They act with full professional authority within those policies, precedents, etc. They are responsible for recognizing the need for further development or modification of accepted policies and procedures, for recognizing the professional and administrative implications involved in such changes, and for making proposals and recommendations. GS-13 counseling psychologists are specialists in dealing with clients who have complex vocational rehabilitation or personal adjustment problems. Their advice and counsel is sought and their opinion given weight by their peers both within and outside their employing agency. They frequently work in collaboration with their counterparts in State, city, or private organizations in seeking solutions to particularly complex vocational rehabilitation or adjustment cases or problems.
The appellant’s position fully meets the GS-12 level. He provides integrated treatment and mental health services to residential patients with substance abuse/dependence issues and co-occurring psychiatric disorders in accordance with generally accepted clinical theories, methods, techniques, and practices. As the LIP for his treatment team, he operates as a mature professional in his particular area of assignment as expected at the GS-12 level. His responsibility is enhanced by the seriousness of the problems he deals with and the breadth and depth of knowledge employed in resolving problems. He makes difficult decisions for high risk and other patients in determining their care and treatment, whether they are a risk to themselves or others, post-treatment continuing care options, etc. Similar to the GS-12 level, the courses of action he decides upon are generally accepted as being professionally sound. His supervisory relationships are largely consultative, keeping the first- and second-level supervisors informed of significant events in the progress of cases (e.g., when he contacts security or the hospital in the event a patient is determined to be a danger to self or others). He also notifies his supervisors if patients are to be discharged prior to completing the residential program. The only technical review of the appellant’s work is through the monthly peer review, which involves another social worker reviewing his patient records to ensure assessment and other documents are complete, recommendations and diagnoses are compatible with clinical notes, and treatment meets standards of care. As at the GS-12 level, his work contacts are with his peers and a variety of medical specialists including psychologists, psychiatrists, and hospital staff for patient consultations.
The appellant’s position does not meet the GS-13 level. In contrast to this level, his position is not responsible for recognizing the need for further development or modification of accepted policies and procedures, for recognizing the professional and administrative implications involved in such changes, and for making proposals and recommendations. His peers occasionally seek him out for his knowledge of cognitive processing therapy and other areas; however, there is no evidence his advice and counsel is sought and his opinion given weight by peers both within and outside SARP as expected at the GS-13 level. Also unlike the GS-13 level, he does not frequently work in collaboration with his counterparts in State, city, or private organizations in seeking solutions to particularly complex vocational rehabilitation or adjustment cases or problems as expected at the GS-13 level.
This factor is credited at the GS-12 level.
Both Nature of assignment and Level of responsibility are evaluated at the GS-12 level. Therefore, the aspects of the appellant’s work that are covered by application of the grading criteria in the GS-180 PCS are properly graded at the GS-12 level.
Summary
Based on our application of the grading criteria in the GS-180 and GS-185 classification standards, the GS-12 level represents the highest grade-level work performed and is therefore the appropriate grade of the appellant’s position.
Decision
The appellant’s position is properly classified as Social Worker, GS-185-12.