Washington D.C.

U.S. Office of Personnel Management
Classification Appeal Decision
Under section 5112 of title 5, United States Code

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Damon B. Ford
Acting Classification Appeals and FLSA Claims Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


01/27/2021

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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).

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the fourth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of 5 CFR must be followed in implementing the decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources (HR) office must submit a compliance report containing the corrected position description (PD) and a 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 Program Support Assistant, GS-0303-05, but he believes it should be classified as Administrative Officer, GS-0341-09.  The position is assigned to Business Operations, Veterans Crisis Line (VCL), Office of Mental Health and Suicide Prevention, Veterans Health Administration (VHA), U.S. Department of Veterans Affairs, in Canandaigua, New York.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

The appellant’s position was previously classified as Secretary, GS-0318-05.  After he requested a desk audit of his position, the servicing HR office reviewed the classification of his position and determined it was instead appropriately classified to the Miscellaneous Clerk and Assistant Series, GS-0303.  Effective August 18, 2019, the appellant’s position was reclassified as Program Support Assistant, GS-0303-05, and assigned to official PD number 076140.

The appellant makes various statements about the classification review process conducted by his agency, and states his position was previously classified at the GS-06 grade level when encumbered by the prior incumbent.  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of his position.  By law, we must make that decision 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 standards is the exclusive method for classifying positions, we cannot compare the appellant’s position to the previous one he cites, which may or may not have been classified correctly, as a basis for deciding his appeal.  Because our decision sets aside any previous agency decisions, the classification practices used by the appellant’s agency in classifying his position are not germane to this decision.

Position information

The appellant and his first level supervisor certified to the accuracy of the duties described in his official PD number 076140.  The appellant’s position is assigned to the Business Operations group of the VCL, which is a 24-hour, 7-days a week service whose mission is to provide suicide prevention and crisis intervention to veterans, servicemembers, and their family members.  The Business Operations group is responsible for providing services related to staffing and recruitment, payroll, leave, travel, and HR liaison.  The appellant provides clerical and support services to staff assigned to the VCL’s three call centers (located in Canandaigua, New York; Atlanta, Georgia; and Topeka, Kansas), as well as other virtual locations.  According to the appellant’s supervisor, the VCL is comprised of approximately 800 to 900 employees.  The appellant is directly supervised by a Supervisory Management Analyst, GS-0343-12. 

The appellant’s official PD assigns the major duties of his position to the following areas:  administrative support, interview coordination and reporting, information and records management, key control and work orders, and purchase orders and supplies.  The appellant estimates spending approximately 50 percent of his time on interview coordination and reporting and information and records management work, 30 percent on purchase orders and supplies work, and the remaining time on other duties.  A summary of his duties follows.

The appellant’s interview coordination and reporting work entails setting up applicant interviews for the VCL’s recruitment efforts.  He estimates arranging over 2,000 applicant interviews in 2019.  He receives the list of referred applicants from the HR office (i.e., the Recruitment and Staffing Services of the VHA’s HR Operations Office).  In discussion with the Administrative Officer, a GS-0341-11, position assigned to Business Operations, the appellant identifies the timeframe for the conduct of interviews based on the training dates scheduled for new employees.  He typically makes initial contact with applicants either by phone or email, depending on the number of applicants on the certificate.  If no response to the initial contact is received, he makes a second contact attempt in three to five days.  The appellant is required to make at least three contact attempts to the applicant via email, phone, or mail.  He also requests missing information, e.g., phone number and mailing address, as well as additional information specifically requested by the selecting official, e.g., transcript or proof of licensure.  He or the Administrative Officer may contact employees to gain their participation on interview panels.  The appellant coordinates schedules and arranges interviews between panel members and applicants based on available dates and times.  Once scheduled, he sends out calendar invites.  The VCL hires for approximately 20 different occupations.  The appellant provides panel members with standard interview questions based on the occupation, location, or duties of the position being recruited.  If he identifies an applicant who previously interviewed with the VCL, he forwards a different set of interview questions to panel members.  He also maintains applicant and recruitment files.  For example, he updates records for the HR office in SharePoint including, but not limited to, interview notes, declinations, selection certificates, and communication with applicants.  He completes a spreadsheet indicating the highest and lowest scores, selections, veterans’ status, etc.  If an applicant fails to show up for an interview, the appellant requests a statement from a panel member to be included in his report of attempted contacts.

Regarding his information and records management work, the appellant receives personnel notices which includes information such as employee name, date of birth, social security number, service computation date, and effective date of the hire, transfer, or departure from the organization.  He updates records in the Electronic Personnel Access System to create or delete agency Windows accounts and email addresses.  The appellant also assigns employees to appropriate email groups for the VCL based on occupation, supervisory status, work teams, duties, etc.

As a credit card holder, the appellant initiates purchase orders for supplies and services for VCL staff.  Purchasing responsibility is divided between him, the management assistant for Business Operations, and the supply technician assigned to the VCL’s Resource Management group.  With a credit card limit of $10,000 for purchases and $2,500 for services, the appellant creates and submits purchase requests for monthly orders of pens, paper, and other office supplies.  With approval from higher-level members of a resource board, he creates and submits purchase requests for other non-routine purchases such as training, chairs and other furniture, computers, reasonable accommodation needs, etc.  Purchase requests are subsequently forwarded to his supervisor, Assistant Deputy Director of Business Operations, or other official for approval.  Although the General Services Administration and the local medical facility fulfill most of their supply needs, the appellant conducts research on vendors, items, and costs when a supply need is identified by leadership or others.  He provides advice to the requestor on which items are available through preferred vendors.  The appellant initiates purchase orders through the Veterans Health Information Systems and Technology Architecture.  He tracks requests until the order is received by him or the requestor.

The appellant spends the remainder of his time on other duties.  For example, for Canandaigua-based staff, he tracks and manages office keys and key fobs issued to employees, receives and distributes mail from the mailroom, and requests work orders based on his personal inspection of the office space or at an employee’s request.

The appellant’s PD and other material of record furnish more information about his duties and responsibilities and how they are performed.  We find the major duties as described by his official PD are adequate for classification purposes, and we incorporate it by reference into this decision.  To help decide this appeal, we conducted telephone audits with the appellant and a telephone interview with his first-level supervisor.  In reaching our classification decision, we carefully considered all information gained from these interviews, as well as the written information furnished by the appellant and his agency.

Series, title, and standard determination

The appellant asserts his position should be classified in the Administrative Officer Series, GS-0341, which includes positions in which the employee is responsible for providing or obtaining a variety of management services essential to the direction and operation of an organization.  The paramount qualifications required by this series are extensive knowledge and understanding of management principles, practices, methods, and techniques, and skill in integrating management services with the general management of an organization.  The work covered by this series requires a high order of analytical ability in performing such typical duties as:  helping management to identify its financial, personnel, and material needs and problems; developing budget estimates and justifications and making sure that funds are used in accordance with the operating budget; counseling management in developing and maintaining sound organization structures, improving management methods and procedures, and seeing to the effective use of staff, money, and materials; collaborating with personnel specialists in finding solutions to management problems arising out of changes in work which have an impact on jobs and employees; and advising on and negotiating contracts, agreements, and cooperative agreements with other Government agencies, universities, or private organizations.  The GS-0341 series is a two-grade interval series, and the above duties are typical of work otherwise performed within the parameters of the corresponding two-grade interval occupation-specific series (e.g., the HR Management Series, GS-0201, Management and Program Analysis Series, GS-0343,  Budget Analysis Series, GS-0560, and the Contracting Series, GS-1102).  For his position to be classified to the GS-0341 series, the appellant must perform some combination of duties comparable to these or other two-grade interval series in the administrative occupations.  The issue therefore is whether his work is two-grade or one-grade interval in nature.

Guidance on distinguishing between one-grade interval support work and two-grade interval administrative work is provided in The Classifier’s Handbook.  In general, support work usually involves proficiency in one or more functional areas or in certain limited phases of a specific program.  Employees who perform support work follow established methods and procedures.  Support work can be performed based on a practical knowledge of the purpose, operation, procedures, techniques, and guidelines of the specific program area or functional assignment.  On the other hand, administrative work requires a high order of analytical ability combined with a comprehensive knowledge of the functions, processes, theories, and principles of management; the methods used to gather, analyze, and evaluate information; skill in applying problem solving techniques; and skill in communicating effectively both orally and in writing.  In other words, the primary skill requirements of administrative work are not the ability to carry out established processes and procedures, but rather to analyze a given issue or case assignment to ascertain the facts and determine the actions necessary; to conduct research, identify options, and determine regulatory requirements; and to prepare written products and explain or defend findings and conclusions.

Two-grade interval administrative work is always characterized by the conduct of some degree of analysis in reviewing documents or situations and then drawing conclusions or making recommendations based on the results of that analysis.  For classification purposes, “analysis” connotes studying the content of a document or the circumstances surrounding a proposal to define the issues involved, evaluate the merits of the information provided, and determine what actions should be taken in response.  The appellant’s duties do not involve subjecting any information received to any significant depth of analysis beyond requesting missing information.  The functions he performs, such as interview coordination, purchasing, and other work, are support activities and services constituting limited aspects of the broader administrative program with which they are associated.  His duties are transactional rather than analytical, i.e., they involve carrying out established processes and procedures based on practical knowledge of the requirements associated with the discrete functional assignments.  Furthermore, the process of “analysis” within the context of administrative work almost always requires the preparation of written work products expressing the analytical process in terms of findings and conclusions.  We found no evidence the appellant prepares work products demonstrating a significant degree of original written communication.  Instead, his written work products consist of emails, spreadsheets, work order requests, and brief memorandums of attempted contacts made with applicants.

The appellant’s work involves the application of a limited set of methods and procedures that do not significantly vary.  His work neither requires nor permits the exercise of a comprehensive knowledge of management principles and processes or skill in problem solving or written communication.  Instead, his work involves carrying out prescribed steps involved in such activities as interview coordination and purchasing.  Such duties can be learned on-the-job by following established processes and procedures without any deeper insight into the mission and programs of the agency or the broader program interrelationships associated with the work.  Given the characteristics described, we conclude the appellant’s position is properly classified to a one-grade interval series.

The appellant performs work divided among a variety of functions and activities including HR, purchasing, computer-related support, and office clerical work.  While such duties cover aspects of work typically performed by positions classified to specific established series, his position does not perform the full scope of such duties and thus is not properly placed in any of those series.  For example, although he performs limited support in the HR staffing area, his coordination of interviews does not require substantial knowledge of civilian HR terminology, requirements, procedures, operations, functions, and regulatory policy and procedural requirements applicable to HR transactions found in positions classified to the HR Assistance Series, GS-0203.  In addition, his purchasing duties do not require substantial knowledge of commercial supply sources and common business practices related to sales, prices, discounts, units of measurement, deliveries, stocks, and shipments found in positions classified to the Purchasing Series, GS-1105.  The agency assigned the appellant’s position to the Miscellaneous Clerk and Assistant Series, GS-0303, which includes positions the duties of which are to perform clerical, assistant, or technician work for which no other series is appropriate.  The work requires knowledge of the procedures and techniques involved in carrying out the work of an organization and involves application of procedures and practices within the framework of established guidelines.  Because the appellant’s position performs elements of work grouped under several series, we evaluated it in terms of the paramount knowledge required to do the work and the primary purpose for the position’s existence to determine its proper series placement.  The purpose of his position is principally to perform a variety of clerical work associated with the VCL’s Business Operations.  Such work requires knowledge of clerical and administrative support procedures, instructions, regulations, and directives as they relate to his organization.  We conclude the GS-0303 series best represents the primary purpose of the appellant’s position.

No titles are specified for positions in the GS-0303 series.  The agency may construct a title in accordance with instructions in the Introduction.  The Position Classification Flysheet for the GS-0303 series does not contain grade-level criteria, but it instructs using the Grade Level Guide for Clerical and Assistance Work (Guide) when grading positions in that series.  Because none of the appellant’s duties constituting at least 25 percent of his worktime require a set of specific occupational knowledge and skills affecting the series and grade of his position, the Guide is appropriate to determine the overall grade level of his support work.

Grade determination

The Guide provides general criteria to use in determining the grade level of nonsupervisory clerical and assistance work being performed in offices, shops, laboratories, hospitals, and other settings in Federal agencies.  The Guide describes the general characteristics of each grade level from GS-01 through GS-07 using the two following factors for grading purposes:  Nature of Assignment (which includes knowledge required and complexity of work), and Level of Responsibility (which includes supervisory controls, guidelines, and contacts).

The Guide provides separate evaluation criteria for clerical and assistance work.  The term “clerical” is defined as performing work such as preparing, receiving, reviewing, and verifying documents; maintaining office records; locating and compiling data or information from files; compiling information for reports; keeping a calendar and informing others of deadlines and other important dates; and similar clerical support work within an organization.  This work requires knowledge of the clerical requirements and processes involved in maintaining the functional programs of the unit.  “Assistance” is defined as performing technical work to support the administration or operation of the programs of an organizational unit.  This work requires working knowledge of the work processes and procedures of an administrative field (e.g., office administration, communications, and security) and the missions and operational requirements of the unit.  For purposes of applying the Guide, the appellant’s work is clerical in nature involving duties such as keeping calendars, requesting missing information, maintaining records, and compiling data.  His work does not involve performing the technical work of an administrative field to support the programs of the organization.

Nature of Assignment

At the GS-04 level, work involves performing a full range of standard clerical assignments and resolving recurring problems.  The work consists of related steps, processes, or methods requiring the employee to identify and recognize differences among a variety of recurring situations.  Actions to be taken or responses to be made differ in nature and sequence because of differences in the particular characteristics of each case or transaction.  In addition to knowledge of how to carry out procedures, GS-04 work also requires some subject matter knowledge of an organization’s programs and operations; type of business practice such as maintaining inventory records and replenishing supplies; or of a body of standardized rules, processes, or operations.  The knowledge is needed to determine what is being done, why the action is being taken, and how it must be accomplished.

At the GS-05 level, work consists of performing a full range of standard and non-standard clerical assignments and resolving a variety of non-recurring problems.  Work includes a variety of assignments involving different and unrelated steps, processes, or methods.  The employee must identify and understand the issues involved in each assignment and determine what steps and procedures are necessary and the order of their performance.  Completion of each transaction typically involves selecting a course of action from a number of possibilities.  The work requires extensive knowledge of an organization’s rules, procedures, operations, or business practices to perform the more complex, interrelated, or one-of-a-kind clerical processing procedures.

The appellant’s position fully meets the GS-04 level.  Like this level, his work involves performing the full range of standard clerical assignments such as scheduling meetings, keeping calendars, entering data, updating spreadsheets, maintaining databases, filing and retaining records, identifying missing information, and purchasing office supplies, as well as resolving recurring problems relating to the day-to-day operations.  His duties are considered standard clerical assignments because such structured work is basically repetitive and involves carrying out the same predictable or prescribed steps without variation.  Although the work consists of related steps, processes, and methods, it requires him to identify and recognize differences among a variety of recurring situations.  For example, the appellant determines the steps to take in recurrent situations such as contacting applicants for missing information, coordinating interviews, rescheduling interviews in the event a panel member is unable to attend a scheduled interview, purchasing office and other supplies, etc.  Similar to the GS-04 level, his duties require subject matter knowledge of the VCL’s programs and operations as well as a set of standardized rules, processes, and operations.  This knowledge is required to determine what is to be done, why the action is being taken, and how it must be accomplished.

The appellant’s position does not meet the GS-05 level.  His work does not involve performing the full range of standard and non-standard clerical assignments nor does it involve resolving the variety of non-recurring problems described at the GS-05 level.  Instead, his work requires performing the same unvarying standard clerical tasks to resolve recurring problems.  Because his interview coordination, purchasing, database management, and other well-established duties do not afford him the latitude to decide which steps, processes, or courses of action need to be taken since they are basically prescribed, the appellant’s work does not involve the complex or one-of-a-kind clerical processing demands expected at the GS-05 level.  What and how tasks are to be completed are driven by past precedents, standard operating procedures, and other established guidelines.  His interview coordination duties require reviewing documents and identifying when, for example, missing information requires requesting it from the applicant; or an applicant is a former employee who should not be contacted for an interview; or identifying a repeat applicant which requires providing the interview panel with a different set of interview questions.  Unlike the GS-05 level, the nature of his work does not reflect the need to identify and understand the issues involved in each assignment and determine what steps and procedures are necessary and the order of their performance.  Furthermore, because his assignments do not involve complex, interrelated, or unique clerical processing procedures, the appellant’s work does not require applying an extensive knowledge of the organization’s rules, procedures, operations, or business practices characteristic of the GS-05 level.

In contrast to the GS-05 level, the appellant’s work does not involve dealing with a variety of assignments each of which involves different and unrelated steps, processes, or methods.  The Guide provides an illustration at the GS-05 level of an Inspectional Aid, who provides specialized clerical assistance to Customs Inspectors by controlling in-bound manifests for air and sea cargo, and inbound storage.  In addition, the aid controls manifested cargo by posting a variety of entry permits and other clearance documents against corresponding bills of lading; examines documents for completeness, discrepancies, sampling requirements, prohibited cargo, and other special requirements and identifies entries that may involve fraud, smuggling, etc., based on available intelligence data; authorizes lay order extensions, obtains general order control numbers, resolves manifest and entry discrepancies, and prepares official and office workload reports for the inspection facility; and maintains office files, inventories nonexpendable equipment, prepares supply requisitions, accepts cash, and prepares daily cash transmittals.  In contrast, because the appellant’s position is repetitive in that it involves carrying out the same essential steps and procedures, he is not required to make the sort of judgmental decisions reflected in the GS-05 illustration.  His duties require making more limited judgments, e.g., identifying missing information, applying standardized processes and procedures for his interview coordination duties which are essentially the same each time, subject to a limited number of easily recognizable circumstances.  Therefore, completion of each transaction typically does not require him to select a course of action from a number of possibilities as expected at the GS-05 level.

This factor is evaluated at the GS-04 level.

Level of Responsibility

At the GS-04 level, the supervisor provides little assistance with recurring assignments.  The employee uses initiative in completing work according to accepted practices, but unusual situations may require assistance from the supervisor or a higher-level employee with completed work reviewed more closely.  At this level, work procedures are established and specific guidelines available.  The number and similarity of guidelines and work situations require employees to use judgment in locating and selecting the most appropriate guidelines, references, and procedures.  The employee makes minor deviations in adapting guidelines to specific cases.  Contacts are with coworkers and individuals outside the organization to exchange information and, in some cases, resolve problems related to the immediate assignment.

At the GS-05 level, the supervisor assigns work by defining objectives, priorities, and deadlines and provides guidance on assignments which do not have clear precedents.  The employee works in accordance with accepted practices and completed work is evaluated for technical soundness, appropriateness, and effectiveness in meeting goals.  Extensive guides in the form of instructions, manuals, regulations, and precedents apply to the work.  The number and similarity of guidelines and work situations require the employee to use judgment in locating and selecting the most appropriate guidelines for application and adapting them according to circumstances of the specific case or transaction.  A number of procedural problems may arise which also require interpretation and adaptation of established guides.  Often, the employee must determine which of several alternative guidelines to use.  Contacts are with a variety of persons within and outside the agency for the purpose of receiving or providing information relating to the work or resolving operating problems in connection with recurring responsibilities.

The appellant’s position fully meets the GS-04 level.  Like this level, his work is recurring and is covered by extensive guidelines in the form of oral instructions, agency administrative procedures, office and organizational instructions, etc., which are readily available and cover most aspects of his work.  He memorizes most guidelines, but he works independently when necessary to select appropriate guidelines to fit a particular situation and exercises judgment in determining when deviations are appropriate or when situations are not covered directly by guidelines or instructions and should be referred to the Administrative Officer, his supervisor, or others (e.g., technical difficulties with computer systems or software).  Like the GS-04 level, he regularly applies well-established guidelines to accomplish continuing work assignments.  Comparable to the GS-04 level, he makes minor deviations in adapting guidelines to specific cases.  For example, he provides panel members with a list of established interview questions based on a position’s responsibilities.  If he identifies an applicant who previously interviewed with the VCL, the appellant forwards a different set of established interview questions to panel members.  Similar to the GS-04 level, his regular contacts are with coworkers, applicants, resource personnel, and people outside the organization to exchange information, obtain or provide necessary information, coordinate work order requests, make purchases, and resolve problems related to immediate assignments.

The appellant’s position does not meet the GS-05 level.  The record shows no evidence that he regularly receives assignments requiring the kind of direction and review typical at the GS-05 level.  Although the appellant and supervisor agree he performs his assigned work independently with minimal supervision, the degree of supervisory control at the GS-05 level is based on performance of the correspondingly more difficult assignments described at this level.  In order to meet the GS-05 level, the employee would have to be performing work that is relatively complicated enough to require the supervisor to define objectives and priorities and to review it for technical soundness.  Because the appellant’s work is recurring (e.g., scheduling meetings, keeping calendars, entering data, updating spreadsheets, maintaining databases, filing and retaining records, identifying missing information, and purchasing office supplies) and involves a confined set of responsibilities with clear precedents, that degree of supervisory guidance and review is not required.

The illustration in the Guide at the GS-05 level describes an Inspectional Aid who is assigned work in terms of objectives, priorities, and deadlines.  The aid independently plans and carries out successive steps according to the specific requirements of each case.  Customs Inspectors are informed of unusual situations and help with unusual problems.  Completed work is evaluated for appropriateness and effectiveness.  The aid uses judgment in discovering problems for referral to the Customs Inspectors, in authorizing lay order extensions and in answering substantive questions from importers.  Contacts with coworkers and the importing public are to exchange information and resolve problems in meeting the importing requirements of the Tariff Act.  In contrast to the GS-05 level criteria and illustration, the appellant’s work does not regularly require or permit interpreting and adapting guidelines to make them fit particular work situations.  According to the appellant, he refers to the Federal Acquisition Regulation or the Government Accountability Office’s Red Book when dealing with unusual purchases (e.g., facial tissues) or situations.  Nonetheless, unlike the GS-05 level his work does not often require determining which of several alternative guidelines to use.  Instead of referring to extensive guidelines to decide what action to take in a particular situation, most of the appellant’s work can be carried out in accordance with past precedents and standard operating procedures without reference to guidelines.  In addition, the purpose of his work contacts involves sharing information, not resolving operating problems to the extent described at the GS-05 level.

This factor is evaluated at the GS-04 level.

Summary

In summary, both Nature of Assignment and Level of Responsibility are evaluated at the GS-04 level.  Therefore, the appellant’s position is graded at the GS-04 level.

Decision

The appellant’s position is properly classified as GS-0303-04, with the title at agency discretion.

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