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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Kimberly A. Steide, DPA
Principal Deputy Associate Director
Agency Compliance and Evaluation
Merit System Accountability and Compliance

05/05/2025

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Date

Finality of Decision

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 changes the series and 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 536 and 752 of 5 CFR must be followed in implementing this decision. If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented. As discussed in this decision, our findings also 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 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), Merit System Accountability and Compliance, Agency Compliance and Evaluation, Washington, DC, office.

Introduction

The appellant’s position is currently classified as Administrative Specialist, GS-0301-13, but he believes the position should be classified at the GS-14 level.[1] He is currently assigned to the Office of the Assistant Director (AD), Freedom of Information Act (FOIA) Staff, Executive Office for United States Attorneys (EOUSA), U.S. Department of Justice (DOJ),Washington, DC. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant makes various statements concerning the agency’s evaluation of his position and compares it to other positions within the agency. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the appellant’s position. By law, we must make that decision solely by comparing the appellant’s current duties and responsibilities to OPM position classification standards (PCSs) 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 position to others that may or may not be properly classified, as a basis for deciding this appeal. Because our decision sets aside any previous agency decisions, the appellant’s concerns about the agency’s classification review process are not germane to the classification appeal process.

In his interview with OPM, the appellant cited his length of service with the agency and the high volume of computer system administration work performed by him as support for the requested grade increase. However, length of service and volume of work cannot be considered in determining the grade of a position (The Classifier’s Handbook (Handbook), Chapter 5).

The appellant emphasizes specific minor, non-grade-controlling duties and responsibilities he intermittently performs, which we did not evaluate. This is because the position classification process categorizes, measures, and assigns a grade only to the significant and substantive duties of a position. It is, therefore, generally necessary to describe only the major duties and other important aspects of the position that may affect the final classification determination. Generally, major duties are those that occupy a significant portion of the employee's time, and are those duties currently assigned, observable, identified with the position's purpose and organization, and expected to continue on a regular and recurring basis over a period of time, such as one year (Handbook).

Position information

The appellant and his supervisor initially certified to the accuracy of the appellant’s official position description (PD) number W99061. However, during interviews with OPM, both the appellant and the supervisor identified duties and responsibilities in the PD which are overstated or inaccurate. For example, the PD states the position “independently plans, manages, and defines a comprehensive administrative and support program that includes the spectrum of administrative support services (e.g., budget administration, personnel administration, space management, purchasing, information resource management, security, internal controls, mail, records, reproduction services, forms management, communication services, supplies, and so forth).” However, the appellant is not vested with the authority to independently plan, manage, and define a comprehensive administrative and support program. Instead, he coordinates with the AD to develop EOUSA’s administrative support program and associated guidelines and implements the mutually developed program within the parameters of established guidelines.

The PD states the position employs a wide variety of qualitative techniques in performing assignments, e.g., charting productivity and calculating means, modes, or similar statistical measures. However, the position does not require the appellant to calculate means, modes, or other similarly complex analytical calculations. Instead, the appellant performs basic analytical calculations, such as cost-benefit analysis, side-by-side comparison, and basic trend projections. In addition, under Factor 1, Knowledge Required by the Position, it states the position requires a “Mastery of advanced management and organizational principles and practices, guidelines and processes necessary to develop and interpret study procedures, apply new methodologies, conduct in-depth studies and probing analyses of business processes, and develop and implement plans to improve the effectiveness of organizational administrative programs, policies, and procedures; includes mastery of a wide range of quantitative and qualitative analytical methods and techniques…and knowledge of innovative management and organizational practices to conduct research, identify meaningful assessment criteria, conduct program reviews, and lead efforts to improve the effectiveness of change management and organizational transformation initiatives and activities designed to improve administrative operations and effectiveness and support significant EOUSA mission(s). However, we do not find that his position requires a “mastery” of any of the aforementioned principles, practices, guidelines, processes, or methods. Based on the preceding inaccuracies, we find his PD does not meet the standard of adequacy described on pages 11-12 of section III.E. of the Introduction and the agency must revise the appellant’s PD to reflect our findings.

The appellant provides administrative support to the AD and to subordinate employees within EOUSA. He uses his knowledge of EOUSA’s goals, mission, objectives, function, and priorities to help facilitate EOUSA’s operation, solve practical administrative problems within the organization and to obtain resources and services necessary to accomplish EOUSA’s daily business. He understands the lines and extent of authority within EOUSA and the DOJ and uses tact and diplomacy when dealing with higher-level agency personnel. He knows the impact of various work operations within EOUSA and how EOUSA’s work affects other organizations and groups both inside and outside EOUSA. He is responsible for planning and accomplishing the day-to-day administrative and support assignments required for staff operations and resolves most of the conflicts that arise. In that role, he oversees and provides administrative support services to the organization, including identifying processes and procedural issues affecting the administrative functions within EOUSA. As the administrative services manager, his duties include providing the full scope of administrative services to the staff including budget, personnel administration, various support services (e.g., purchasing, security, space and telecommunications management, supply, equipment, and property inventory management, website content, and technical assistance related to EOUSA Federal contracts). To illustrate, upon request from the AD or EOUSA staff he develops and submits applicable orders and requisitions for a variety of necessary equipment, supplies, and services, and monitors order status and keeps records of receipts and distributions. The appellant’s other areas of administrative support are discussed in greater detail below. He recommends solutions to problems involving these administrative areas and develops and distributes cyclical and non-cyclical reports.

Regarding personnel administration, the appellant coordinates with the AD to identify current and future personnel needs and works with the servicing HR office and the CO to develop vacancy announcements and Federal contracts to meet personnel needs. He coordinates with the AD and HR to identify and process various personnel actions, e.g., hiring, firing, promotions, and pay and award actions, and coordinates with EOUSA employees and contracted personnel to identify and obtain required training.

Concerning financial duties, the appellant performs a variety of accounting, budget, and finance-related tasks and uses a variety of analytical methods (e.g., side-by-side comparison, forecasting, cost/benefit analysis) to evaluate and predict financial and budgetary needs. He assists the AD, CO, and EOUSA program managers to develop funding proposals and requests and provides recommendations regarding the effective use of funds, contract personnel, computer programs, equipment, and supplies.

The appellant serves as a contracting officer’s technical representative (COTR) and performs the full range of COTR duties for administrative aspects of Federal contracts. As a COTR, the appellant coordinates with his supervisor and the Contracting Officer (CO) to identify issues and needs. He acts as a liaison between various Federal contractors and the CO and is responsible for ensuring satisfactory performance and timely delivery of services as set forth in assigned contracts. He performs contract pre-award tasks, such as preparation of work statements, and arranges for and coordinates the use of Government resources. He provides technical guidance concerning the performance requirements for EOUSA contract work, and receives, reviews, and submits a variety of contract-related data, documents, and reports (e.g., progress reports, selected invoices, and final reports) to the CO for consideration and action. He uses his administrative management experience and related technical judgment to help the CO monitor the effectiveness of contracted computer systems and services and the performance and progress of contracted work and makes recommendations to the AD and CO for changes to specific contracts. He coordinates with the AD and the CO to develop, monitor, and update contract-related budgets.

The appellant performs a variety of system administrator duties for EOUSA automated computer programs and databases. These include, but are not limited to, ensuring qualified access to secure systems; creating, monitoring, transferring, and deleting accounts; establishing and resetting passwords; monitoring the timeliness and accuracy of information entered into various EOUSA electronic databases and records keeping systems; coordinating with the Helpdesk to identify and remedy access and operational issues; recommending improvements to current data-gathering and storage systems and processes; researching new computer systems and assisting with updates to existing computer systems; and providing as-needed training to users. He monitors the functionality and operability of established computer programs, identifies and reports issues and deficiencies to his supervisor and the servicing information technology (IT) and cyber security offices, and coordinates with them to ensure the security of EOUSA computer programs. He processes and provides the appropriate access levels to new Federal and contract employees performing work within EOUSA and provides procedural and computer system administrative support to EOUSA employees and contractors.

Series, title, and standard determination

The series, title, and grade evaluating standard for a position are usually apparent from reviewing the regular and recurring duties and responsibilities assigned to and actually performed by the employee in the position. In most cases, the selected occupational series represents the primary work of the position, the highest level of work performed, and the paramount qualifications required (Handbook).
The agency classified the appellant’s position in the Miscellaneous Administration and Program Series, 0301, titling it Administrative Specialist. Although the appellant does not specifically disagree with the series and title assigned to his position, his appeal request includes comparisons of his position to the Information Technology Management series, 2210, and the Management and Program Analysis series, 0343. However, as discussed below, we find the duties and responsibilities assigned to and actually performed by the appellant do not meet the 2210, 0301, or the 0343 series. Instead, we find his actual work is properly classified to the Administrative Officer Series, 0341. Our discussion, analysis, and selection of the proper series covering those noted above follows.

The 2210 series covers two-grade interval administrative positions that manage, supervise, lead, administer, develop, deliver, and support information technology (IT) systems and services and for which the paramount requirement is knowledge of IT principles, concepts, and methods, e.g., data storage, software applications, networking. Unlike positions classified in the 2210 series, knowledge of IT principles, concepts, and methods is not the paramount knowledge to perform the primary duty of the appellant’s position. According to the appellant’s supervisor, the paramount knowledge to perform the primary duty of the appellant’s position is general administrative management and program support for EOUSA. Therefore, although the appellant’s position includes the performance of automated computer system administration, this duty is incidental to the primary duty and purpose of the position. Since the position’s paramount knowledge is not of IT principles, concepts, and methods, it does not meet the basic requirement for classification in the 2210 series.
The 0301 series includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no appropriate occupational series has been established. Positions in the 0301 series involve specialized work for which no appropriate occupational series has been established. Typically, positions in this series are too few of a kind to have been recognized as separate lines of work, involve new or emerging work or, more rarely, mixtures of work that cannot be identified with an established series. However, as discussed later in this section, we find the appellant’s primary duty involves work for which an appropriate subject-matter occupational series is established, i.e., Administrative Officer Series, 0341. Therefore, by definition, the position cannot be construed as meeting the basic requirement of the 0301 series and thus cannot be classified in that series.

The 0343 series covers positions which primarily serve as analysts and advisors to management on the evaluation of the effectiveness of government programs and operations or the productivity and efficiency of the management of Federal agencies or both. The work of this occupation is typically performed in a staff capacity in that the results of the work support the accomplishment of the principal mission or line program(s) of the agency or organizational component in which the positions are located. Positions which require full competence in a particular specialized or subject-matter field for satisfactory performance of the work are excluded from this series. Unlike the 0343 series, the appellant’s position is not responsible for evaluating the effectiveness of government programs and operations or the productivity and efficiency of the management of the DOJ. Instead, the primary focus of his position is to provide the full range of administrative support services (e.g., computer data management, computer system administration, personnel actions, budget, space management, supplies, equipment, and COTR responsibilities associated with Federal contracts), perform analytical processes; and provide advice and recommendations to the AD and EOUSA personnel concerning administrative policy and processes directly affecting them. In doing so he applies extensive knowledge and understanding of the principles and practices of management and integrating support services with the general management of the EOUSA. Unlike the 0343 series, evaluations and analysis performed by the appellant focuses on EOUSA-related programs and issues, such as budgets and funding, FOIA and privacy act-related data, and the efficiency and effectiveness of EOUSA’s computer programs. Therefore, the appellant’s position does not meet the basic requirements for evaluation by application of the 0343 series.

The 0341 series includes positions in which employees are responsible for providing or obtaining a variety of management services essential to the direction and operation of an organization. The paramount qualifications required 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 and solving the practical problems of management. An administrative officer aids the operating manager and subordinate operating officials in getting things done through knowledge of and skill in dealing with organization, methods, funds people, equipment, and other tools or resources of management. Such positions are primarily concerned with providing, securing or negotiating for the resources or services needed to manage and run an organization. Ordinarily, an administrative officer has a responsible role in the management of both financial and human resources because of an immediate relationship to the operating manager. Although an administrative officer does key work in several other vital functions or services such as management analysis, procurement, contract administration, property and space management, security administration, reports management, data processing, etc., general management skills are the paramount requirement and no single functional, resource, or service area forms a basis for the paramount skills.

Administrative officer positions are mainly of two broad types. Type one is the chief of a central administrative unit which provides services to a number of operating divisions, field offices, or other units each headed by an operating manager. The central administrative unit includes specialist positions in various areas such as budget, data processing, etc. The administrative unit chief has considerable authority to complete personnel actions, obligate funds, make purchases, etc. Type two is the administrative officer position in an operating subdivision of an organization which receives services from central servicing offices such as personnel, procurement and administrative offices having substantial authority to complete action in some administrative matters. The type two administrative officer usually has few or no personnel specialists, management analysts, procurement agents, etc., and limited authority in personnel and procurement matters; however, the officer (like type one) may be engaged in any of the illustrative duties described above.\

The appellant’s work meets the 0341 series. Like the 0341 series, the appellant is responsible for providing and obtaining a variety of management services essential to the direction and operation of EOUSA, such as budget, personnel, building and space management, purchasing, information resource management, security, internal controls, mail, records, reproduction services, forms management, communication services, and supplies. Like the 0341 series, the paramount qualifications required of his position are an extensive knowledge and understanding of management principles, practices, methods and techniques, and skill in integrating the aforementioned services and solving administrative and program support problems associated with the general management of EOUSA. The appellant’s position meets the type two Administrative Officer within the context of the 0341 series. Like type two, the appellant provides direct operational administrative and program support services to EOUSA, which is a subdivision of the DOJ delegated substantial authority to review, adjudicate, and manage FOIA-related matters. Similar to type two, there are no personnel specialists, management analysts, procurement agents, or other administrative support personnel within the organizational structure of EOUSA. Like type two, the appellant exercises limited authority in matters such as budget, personnel, building and space management, purchasing, information resource management, security, internal controls, mail, records, reproduction services, forms management, communication services, and supplies.

Given that the appellant is not in a trainee or developmental job, the appropriate title of his position is Administrative Officer, and classified in the GS-0341 series.

Grade determination

There are no grading criteria for positions classified in the 0341 series. The GS-0341 Position Classification Flysheet (PCF) instructs that other individual standards (besides those that may be appropriate as listed in the PCF) for work related to the major duties or functions performed are to be used to evaluate positions in this series. OPM has evaluated the appellant’s position by application of the Administrative Analysis Grade Evaluation Guide (AAGEG), which grades nonsupervisory staff administrative analytical, planning, and evaluative work, at grade GS-09 and above that does not require specialized subject matter knowledge and skills. While such work does not require specialized educational preparation, it does include work requiring a high degree of qualitative and/or quantitative analytical skills, the ability to research problems and issues, written and oral communication skills, and the application of mature judgment in problem solving.

The AAGEG uses the Factor Evaluation System (FES), which employs nine factors. Under the FES, each factor level describes the minimum characteristics needed to receive credit for the described level. Therefore, if a position fails to meet the criteria in a factor-level description in any significant aspect, it must be credited at a lower level, unless an equally important aspect that meets a higher level balances the deficiency. Conversely, the position may exceed those criteria in some respects and still not be credited at a higher level. Each factor level has a corresponding point value. The total points assigned are converted to a grade by use of the grade conversion table in the Guide. Below is our evaluation with respect to the nine FES factors.

Factor 1, Knowledge required by the position

This factor covers the kind and nature of knowledge required, the skills needed, and how they are used in doing the work.

At Level 1-7, assignments require knowledge and skill in applying analytical and evaluative methods and techniques to issues or studies concerning the efficiency and effectiveness of program operations carried out by administrative or professional personnel, or substantive administrative support functions (i.e., internal activities or functions such as supply, budget, procurement, or personnel which serve to facilitate line or program operations). This level includes knowledge of pertinent laws, regulations, policies, and precedents which affect the use of program and related support resources (people, money, or equipment) in the area studied. Projects and studies typically require knowledge of the major issues, program goals and objectives, work processes, and administrative operations of the organization.

Knowledge at Level 1-7 is used to plan, schedule, and conduct projects and studies to evaluate and recommend ways to improve the effectiveness and efficiency of work operations in a program or support setting. The assignments require knowledge and skill in adapting analytical techniques and evaluation criteria to the measurement and improvement of program effectiveness and/or organizational productivity. Knowledge is applied in developing new or modified work methods, organizational structures, records and files, management processes, staffing patterns, procedures for administering program services, guidelines and procedures, and automating work processes for the conduct of administrative support functions or program operations. Knowledge may also be applied in analyzing and making recommendations concerning the centralization or decentralization of operations.

Level 1-8 describes the expert analyst who has mastered the application of a wide range of qualitative and/or quantitative methods for the assessment and improvement of program effectiveness or the improvement of complex management processes and systems. In addition to knowledge of the next lower level, this level requires comprehensive knowledge of the range of administrative laws, policies, regulations, and precedents applicable to the administration of one or more important public programs. Typically, this includes knowledge of agency program goals and objectives, the sequence and timing of key program events and milestones, and methods of evaluating the worth of program accomplishments. Work requires knowledge of relationships with other programs and key administrative support functions within the employing agency or in other agencies. Knowledge characteristic of this level is applied to a variety of ways. For example, knowledge is applied to the design and conduct of comprehensive management studies where the boundaries of the studies are extremely broad and difficult to determine in advance; i.e., the actual limits of the project are developed as the study proceeds.

Study objectives are to identify and propose solutions to management problems which are characterized by their breadth, importance, and severity, and for which previous studies and established management techniques are frequently inadequate. For other assignments, knowledge may be applied in preparing recommendations for legislation to change the way programs are carried out; in evaluating the content of new or modified legislation for projected impact upon agency programs and resources; and/or in translating basic legislation into program goals, actions, and services. Also included at this level is skill to plan, organize, and direct team study work and to negotiate effectively with management to accept and implement recommendations, where the proposals involve substantial agency resources, require extensive changes in established procedures, or may be in conflict with the desires of the activity studied.

Level 1-7 is met. Like this level, the appellant’s position requires knowledge and skill in applying analytical and evaluative methods and techniques to issues associated with substantive EOUSA administrative support functions, such as budget administration, personnel, space management, purchasing, computer system administration, security, mail, records, reproduction services, forms management, communication services, and supplies. Similar to this level, the position requires knowledge of administrative laws, policies, regulations, and precedents applicable to the administration of EOUSA’s FOIA and privacy act programs, including knowledge of EOUSA program goals and objectives, the sequence and timing of key program and organization-related events and milestones. Like this level, the appellant uses his knowledge of EOUSA’s mission, goals, and processes to help the AD and program/project managers plan, schedule, and conduct projects and studies to evaluate and recommend ways to improve EOUSA’s effectiveness and efficiency. He develops new or modified work methods, records, and files, staffing patterns, guidelines, and procedures, and coordinates with the servicing IT and cyber security departments to develop procedures for administering automated computer systems needed to conduct administrative support functions and program operations within EOUSA.

Level 1-8 is not met. Unlike this level, while the appellant is considered the most knowledgeable employee in EOUSA in independently managing the administrative support functions of the organization, his work does not require that he function as an expert analyst who has mastered the application of a wide range of qualitative and/or quantitative methods for the assessment and improvement of the overall organization’s effectiveness or improvement of complex management processes and systems. Such responsibilities are typically found at higher agency levels where program evaluation and assessment require comprehensive knowledge of the range of administrative laws policies and regulations applicable to an agency’s administration of one or more of its important public programs.

Within this context, the appellant’s assignments are much narrower from a programmatic standpoint and the functions he performs are less demanding than those described as typical of Level 1-8. His work does not require knowledge of relationships with other programs and key administrative support functions within the employing agency or in other agencies, such as designing and conducting comprehensive management studies whose boundaries are extremely broad and difficult to determine in advance because they are developed as the study proceeds. Instead, his duties are limited to applying knowledge of the relationship of EOUSA administrative programs and processes to facilitate and provide a variety of administrative support services to enhance the effectiveness and achievement of the organization’s program goals and objectives. Observations and analysis performed by the appellant are specific to EOUSA issues, processes, and products and do not involve identifying and proposing solutions to broad, important, or severe management problems for which previous studies and established management techniques have proven inadequate.
Unlike Level 1-8, the appellant is not assigned the authority or responsibility for preparing recommendations for legislation to change the way DOJ programs are carried out; evaluate the content of new or modified legislation for projected impact upon DOJ programs and resources; or to translate basic legislation into program goals, actions, and services. Instead, responsibility for proposing, interpreting, and projecting the impact of legislation on the DOJ rests with higher-level managers within the agency. In contrast to this level, the appellant is not responsible for planning, organizing, or directing controversial, possibly adversarial, team studies or negotiating with management to accept and implement recommendations involving substantial DOJ resources and/or extensive changes in established procedures for DOJ or EOUSA. In short, the nature of the appellant’s work demands neither the scope of knowledge nor range of skills expected at Level 1-8.

Factor 1 is evaluated at Level 1-7 and 1250 points are assigned.

Factor 2, Supervisory controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee's responsibility for carrying out assignments, and how completed work is reviewed.
At Level 2-4, within a framework of priorities, funding, and overall project objectives (e.g., cost reduction, improved effectiveness and efficiency, better workload distribution, or implementation of new work methods), the employee and supervisor develop a mutually acceptable project plan which typically includes identification of the work to be done, the scope of the project, and deadlines for its completion. Within the parameters of the approved project plan, the employee is responsible for planning and organizing the study, estimating costs, coordinating with staff and line management personnel, and conducting all phases of the project. This frequently involves the definitive interpretation of regulations and study procedures, and the initial application of new methods. The employee informs the supervisor of potentially controversial findings, issues, or problems with widespread impact. Completed projects, evaluations, reports, or recommendations are reviewed by the supervisor for compatibility with organizational goals, guidelines, and effectiveness in achieving intended objectives. Completed work is also reviewed critically outside the employee's immediate office by staff and line management officials whose programs and employees would be affected by implementation of the recommendations.

At Level 2-5, the employee is a recognized authority in the analysis and evaluation of programs and issues and is subject only to administrative and policy direction concerning overall project priorities and objectives. At this level, the employee is typically delegated complete responsibility and authority to plan, schedule, and carry out major projects concerned with the analysis and evaluation of programs or organizational effectiveness. The employee typically exercises discretion and judgment in determining whether to broaden or narrow the scope of projects or studies. Analyses, evaluations, and recommendations developed by the employee are normally reviewed by management officials only for potential influence on broad agency policy objectives and program goals. Findings and recommendations are normally accepted without significant change.

Level 2-4 is met. Like this level, the appellant and the AD identify projects and studies and develop mutually acceptable plans, which include potential issues and problems, overall objectives, resources, milestones, reporting dates and mechanisms, and deadlines for completion. Similar to this level, the appellant independently plans, organizes, and conducts all phases of assigned work, such as interpreting and applying existing guidelines, performing analysis, developing, and updating budgets, reviewing, and recommending new products, services, and methods, coordinating with the servicing HR office to identify and address typical personnel actions, and performing the full range of COTR and computer system administrator duties. Comparable to this level, completed work, reports, and recommendations produced by the appellant are reviewed by the AD for compatibility with applicable guidelines and program goals and objectives.

Level 2-5 is not met. Unlike this level, the appellant is not recognized as an authority in the analysis and evaluation of programs and issues concerning broad administrative management support functions. While his supervisor recognizes him as the person most knowledgeable of administrative support activities within the organization, his work is limited to program analysis and evaluation directly related to the provision of day-to-day support services to the EOUSA’s programs and processes. Unlike this level, the appellant is not subject only to administrative and policy direction concerning overall project priorities and objectives. Instead, projects, studies, and non-routine program-related analytical processes, particularly those addressing broad DOJ policy objectives and overall agency program goals, are regularly discussed with and approved by the AD during scheduled and non-scheduled meetings, phone calls, and e-mails prior to initiation. Unlike this level, the appellant must consult the AD prior to broadening or narrowing the scope of projects or studies. Given these limitations, the degree of the appellant’s supervisory review, discretion, and independent decision-making authority does not meet Level 2-5.

Factor 2 is evaluated at Level 2-4 and 450 points are assigned.

Factor 3, Guidelines

This factor covers the nature and extent of guidelines for performing the work and the judgment needed to apply them.

At Level 3-4, guidelines consist of general administrative policies and management and organizational theories which require considerable adaptation and/or interpretation for application to issues and problems studied. At this level, administrative policies and precedent studies provide a basic outline of the results desired, but do not go into detail as to the methods used to accomplish the project. Administrative guidelines usually cover program goals and objectives of the employing organization, such as agency controls on size of work force, productivity targets, and similar objectives. Within the context of broad regulatory guidelines, the employee may refine or develop more specific guidelines such as implementing regulations or methods for the measurement and improvement of effectiveness and productivity in the administration of operating programs.

At Level 3-5, guidelines consist of basic administrative policy statements concerning the issue or problem being studied, and may include reference to pertinent legislative history, related court decisions, state and local laws, or policy initiatives of agency management. The employee uses judgment and discretion in determining intent, and in interpreting and revising existing policy and regulatory guidance for use by others within or outside the employing organization (e.g., other analysts, line managers, or contractors). Some employees review proposed legislation or regulations which would significantly change the basic character of agency programs, the way the agency conducts its business with the public or with private industry, or which modify important inter-agency relationships. Other employees develop study formats for use by others on a project team or at subordinate echelons in the organization. At this level, the employees are recognized as experts in the development and/or interpretation of guidance on program planning and evaluation in their area of specialization (e.g., work force management, contingency/emergency planning, position management, work measurement, or productivity improvement).

Level 3-4 is met. Like this level, the appellant interprets and adapts general Federal law and FOIA and DOJ guidelines and policies (e.g., DOJ FOIA Regulations, U.S. Attorneys’ Policy and Procedures, U.S. Attorneys’ Manual, Justice Manual, title 3 EOUSA, FOIA Xpress user manual, and FOIA Xpress Administrator Manual). Due to the general nature of administrative policies, regulations, and laws, the appellant develops local supplemental guidelines to advise the AD and other EOUSA personnel concerning administrative actions and processes and to make recommendations associated with a variety of new and current computer data management, security, and system administration issues. Like this level, there are some instances where available guidelines lack sufficient detail or specificity regarding the issue or situation facing the appellant. In these instances, the appellant may be required to adapt available guidelines in order to apply them to specific processes, issues, and conditions experienced in his work. Comparable to this level, the appellant’s actions are governed by established DOJ and EOUSA goals and objectives and the appellant cannot change the overall intent or broaden the parameters of guidelines he adapts.

Level 3-5 is not met. Unlike this level, the appellant’s guidelines are generally more applicable than simply basic agency administrative policy statements regarding administrative matters, which may include reference to legislative history, related court decisions, or policy initiatives of the agency’s management. Although the appellant may interpret and modify current guidelines to apply to specific processes, issues, and conditions, application of his guidelines do not require the significant degree of judgement and discretion characteristic of Level 3-5. While he may supplement current guidelines for local use, he does not interpret and revise existing agency policy and regulatory guidance for use by others within or outside his organization. Contrary to this level, the appellant does not review proposed legislation or regulations which would significantly change the basic character of EOUSA programs, or the way DOJ conducts business, nor is he responsible for developing study formats for use by employees on a project team or at other subordinate echelons within DOJ. Finally, the appellant is not a recognized expert in the development and/or interpretation of program guidance on program planning and evaluation in his area of specialization, i.e., administrative support functions.
Factor 3 is evaluated at Level 3-4 and 450 points are assigned.

Factor 4, Complexity

This factor covers the nature, number, variety, and intricacy of tasks, steps, processes, or methods in the work performed, the difficulty in identifying what needs to be done; and the difficulty and originality involved in performing the work.

At Level 4-4, the work involves gathering information, identifying, and analyzing issues, and developing recommendations to resolve substantive problems of effectiveness and efficiency of work operations in a program or program support setting. This is in addition to improving conditions of a procedural nature which relate to the efficiency of organizations and workers described at the lower level. Work at this level requires the application of qualitative and quantitative analytical techniques that frequently require modification to fit a wider range of variables. Subjects and projects assigned at this level usually consist of issues, problems, or concepts that are not always susceptible to direct observation and analysis (e.g., projected missions and functions). Difficulty is encountered in measuring effectiveness and productivity due to variations in the nature of administrative processes studied (e.g., those associated with processing information, reorganizing to meet changes in mission, or providing support services). Information about the subject is often conflicting or incomplete, cannot readily be obtained by direct means, or is otherwise difficult to document. For example, assignments may involve compiling, reconciling, and correlating voluminous workload data from a variety of sources with different reporting requirements and formats, or the data must be carefully cross-checked, analyzed, and interpreted to obtain accurate and relevant information. Characteristic of this level is originality in refining existing work methods and techniques for application to the analysis of specific issues or resolution of problems. For example, the employee may revise methods for collecting data on workload, adopt new measures of productivity, or develop new approaches to relate productivity measurements to a performance appraisal system.

At Level 4-5, work consists of projects and studies which require analysis of interrelated issues of effectiveness, efficiency, and productivity of substantive mission-oriented programs. Typical assignments require developing detailed plans, goals, and objectives for the long-range implementation and administration of the program, and/or developing criteria for evaluating the effectiveness of the program. Decisions about how to proceed in planning, organizing, and conducting studies are complicated by conflicting program goals and objectives which may derive from changes in legislative or regulatory guidelines, productivity, and/or variations in the demand for program services. Assignments are further complicated by the need to deal with subjective concepts such as value judgments; the quality and quantity of actions are measurable primarily in predictive terms; and findings and conclusions are highly subjective and not readily susceptible to verification through replication of study methods or reevaluation of results.

At Level 4-5, options, recommendations, and conclusions developed by the employee take into account and give appropriate weight to uncertainties about the data and other variables which affect long-range program performance. For example, the employee may need to consider and assess the relative advantages and disadvantages of centralizing or decentralizing work operations in organizations with several echelons of geographically separated components. In some instances, work is complicated by the need to develop data about workload and program accomplishments which is currently unavailable. Current measurements of program effectiveness may be ambiguous and susceptible to widely varying interpretations. Under these circumstances the employee develops new information about the subject studied and establishes criteria to identify and measure program accomplishments, develops methods to improve the effectiveness with which programs are administered, or develops new approaches to program evaluation which serve as precedents for others.

Level 4-4 is met. Like this level, the appellant’s work involves gathering information and identifying and analyzing and/or evaluating issues associated with a variety of analytical services and administrative support functions he provides to facilitate accomplishment of EOUSA-related programs and projects. Similar to this level, he reviews data and information and develops recommendations to resolve problems involving EOUSA’s effectiveness and efficiency of EOUSA programs and administrative management processes. Comparable to this level, the appellant’s work requires the application of qualitative and quantitative analytical techniques (e.g., interviews, data mining, cost/benefit analysis, and trend projections) which he modifies to cover variables, such as staffing levels, workload, funding and budget projections. Like this level, the subject of projects and studies supported by the appellant often consist of issues, problems, or concepts that are not always susceptible to direct observation and analysis, such as projected budgets and estimated operational functions of key programs managed by EOUSA. Similar to this level, intermittent changes in EOUSA processes make it difficult to measure the efficiency and effectiveness of administrative support services, because data concerning the impact of FOIA and the privacy act on Federal employees and agencies is often difficult to obtain and document. Comparable to this level, the appellant uses originality to adjust existing methods and techniques used to gather, document, analyze, and report program-related issues and information and to develop and recommend resolutions to identified issues.

Level 4-5 is not met. Unlike this level, the appellant’s work does not consist of projects and studies which require analysis of interrelated issues of effectiveness, efficiency, and productivity of the agency’s (i.e., DOJ) substantive mission-oriented programs. In addition, he is not involved in developing detailed plans, goals, and objectives for long-range implementation and administration of the agency’s programs (including overall program administration) and/or in developing criteria for evaluating program effectiveness. Instead, his work focuses primarily on short-term technical and administrative management issues and EOUSA projects, programs, and processes. Furthermore, the appellant does not perform work analogous to the broad program-oriented activities described at this level (e.g., work related to the operation of broad DOJ programs). Instead, the administrative program management and project and program support duties performed by the appellant are primarily focused on improving the effectiveness and efficiency of specific EOUSA administrative programs and activities and providing specific technical support to the AD and EOUSA’s staff.

Factor 4 is evaluated at Level 4-4, and 225 points are assigned.

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work, i.e., the purpose, breadth, and depth of the assignment, and the effect of work products or services both within and outside the organization.

At Level 5-4, the purpose of the work is to assess the productivity, effectiveness, and efficiency of program operations or to analyze and resolve problems in the staffing, effectiveness and efficiency of administrative support and staff activities. Work involves establishing criteria to measure and/or predict the attainment of program or organizational goals and objectives. Work at this level may also include developing related administrative regulations, such as those governing the allocation and distribution of personnel, supplies, equipment, and other resources, or promulgating program guidance for application across organizational lines or in varied geographic locations. Work that involves the evaluation of program effectiveness usually focuses on the delivery of program benefits or services at the operating level. Work contributes to the improvement of productivity, effectiveness, and efficiency in program operations and/or administrative support activities at different echelons and/or geographical locations within the organization. Work affects the plans, goals, and effectiveness of missions and programs at these various echelons or locations. Work may affect the nature of administrative work done in components of other agencies (e.g., in preparation and submission of reports, in gathering and evaluating workload statistics, or in routing and storing official correspondence or files).

At Level 5-5, the purpose of the work is to analyze and evaluate major administrative aspects of substantive, mission-oriented programs. This may involve, for example, the development of long-range program plans, goals, objectives, and milestones, or to evaluating the effectiveness of programs conducted throughout a bureau or service of an independent agency, a regional structure of equivalent scope, or a large complex multi-mission field activity. The work involves identifying and developing ways to resolve problems or cope with issues which directly affect the accomplishment of principal program goals and objectives (e.g., the delivery of program benefits or services). Some employees develop new ways to resolve major administrative problems or plan the most significant administrative management aspects of professional or scientific programs, while some employees at this level develop administrative regulations or guidelines for the conduct of program operations, while others develop new criteria for measuring program accomplishments (e.g., the level, costs, or intrinsic value of benefits and services provided) and the extent to which program goals and objectives are attained.

At Level 5-5, study reports typically contain findings and recommendations of major significance to top management of the agency, and often serve as the basis for new administrative systems, legislation, regulations, or programs. Typical of work products prepared by employees at this level are complete decision packages, staff studies, and recommendations which upon implementation would significantly change major administrative aspects of missions and programs, or substantially affect the quality and quantity of benefits and services provided to the agency's clients.
Level 5-4 is met. Like this level, the purpose of the appellant’s work is to analyze and resolve problems associated with the effectiveness and efficiency of operational-level administrative support and staff activities within EOUSA and to measure and predict the success of EOUSA program, goals, and objectives. Similar to this level, the appellant coordinates with the AD to develop guidelines for administrative programs and processes (e.g., personnel, budget, procurements, space management, Federal contracts, data management, and computer system administration) and communicates DOJ related guidelines to all EOUSA staff. Like this level, the appellant’s work improves the efficiency and effectiveness of administrative and program activities for EOUSA headquarters and field staff throughout the U.S.

Level 5-5 is not met. Unlike this level, the purpose of the appellant’s work is not to analyze and evaluate major administrative aspects of substantive agency mission-oriented programs. His work does not include the development of long-range agency or EOUSA program plans, goals, objectives, and milestones, or evaluating the effectiveness of programs conducted throughout the types of organizations described under Level 5-5. In addition, his work does not involve identifying and developing ways to resolve agency problems or cope with issues directly affecting the accomplishment of principal DOJ program goals and objectives, such as the delivery of an agency’s program benefits or services. Also, the appellant’s duties do not directly affect the design, structure, and administration of DOJ programs or address broad DOJ programs, policies issues, and concerns, nor does it encompass the scope of activities and work products addressed in the three situations described under Level 5-5. Instead, the appellant’s work is limited to providing administrative management technical support for EOUSA programs and related processes and procedures.
Unlike Level 5-5, the appellant’s position is not responsible for developing study reports typically containing findings and recommendations of major significance to top DOJ management officials, which often serve as the basis for new administrative systems, legislation, regulations, or programs. Instead, he typically works within the parameters of EOUSA programs (e.g., FOIA, Privacy Act, and related computer system administration) and makes recommendations and suggestions related to issues and concerns directly associated with processes and procedures affecting the aforementioned programs. Responsibility for decisions and recommendations which may significantly impact major aspects of legislation and regulations and/or DOJ administrative systems and programs rest with higher-level officials within the agency.

Factor 5 is evaluated at Level 5-4 and 225 points are assigned.

Factor 6, Personal contacts / Factor 7, Purpose of contacts

These two factors are interdependent. The relationship between factors 6 and 7 presumes the same contacts will be evaluated under both factors. These factors cover the type and level of contacts made in carrying out the work and the reasons for those contacts. Under the AAGEG, these factors are evaluated separately, but a combined point credit is established by determining where the respective levels intersect in the table in the AAGEG.

Persons Contacted

At Level 6-3, contacts include persons outside the agency which may include consultants, contractors, or business executives in a moderately unstructured setting. This level may also include contacts with the head of the employing agency or program officials several managerial levels removed from the employee when such contacts occur on an ad-hoc basis.

At Level 6-4, contacts include high-ranking officials such as other agency heads, top congressional staff officials, state executive or legislative leaders, mayors of major cities, or executives of comparable private sector organizations.

Level 6-3 is met. Like this level, the appellant’s contacts include administrative personnel within EOUSA, DOJ, and Federal contractors in moderately unstructured settings, such as telephone and email communications. Like this level, the appellant has contact on an ad-hoc basis with persons several managerial levels removed from his position.

Level 6-4 is not met. Unlike this level, the appellant does not have contact with high-ranking officials and/or heads of other agencies, congressional staff officials, mayors of major cities, or executives of comparable private sector organizations.

Factor 6 is evaluated at Level 6-3.

Purpose of Contacts

At Level 7-c, the purpose of contacts is to influence managers or other officials to accept and implement findings and recommendations on organizational improvement or program effectiveness. May encounter resistance due to such issues as organizational conflict, competing objectives, or resource problems.

At Level 7-d, the purpose of contacts is to justify or settle matters involving significant or controversial issues; e.g., recommendations affecting major programs, dealing with substantial expenditures, or significantly changing the nature and scope of organizations.

Level 7-c is met. Like this level, the appellant uses data and information concerning administrative operations and the results of evaluations and studies to inform and persuade the AD, CO, and subordinate EOUSA staff to accept and implement his findings and recommendations to improve the efficiency and/or effectiveness of various EOUSA administrative programs. Similar to this level, the appellant may encounter resistance from project leaders and staff due to competing objectives and limited funding. In these circumstances, the appellant shares data and makes compelling recommendations.

Level 7-d is not met. Unlike this level, the purpose of the appellant’s contacts is not to justify or settle matters involving significant or controversial issues like those described at this level. His recommendations do not affect the substance or course of major DOJ or EOUSA programs, propose substantial expenditures, or involve significantly changing the nature and scope of EOUSA, DOJ, or organizations.

Factor 7 is evaluated at Level 7-c.

Factors 6 and 7 are evaluated at Levels 6-3, 7-c, respectively, and 180 points are credited.

Factor 8, Physical demands

This factor covers the requirements and physical demands placed on the employee by the work assignment.

At Level 8-1, the work is primarily sedentary, although some slight physical effort may be required.

At Level 8-2, assignments regularly involve long periods of standing, bending, and stooping to observe and study work operations in an industrial, storage, or comparable work area.

Level 8-1 is met in that the appellant’s work is primarily sedentary with minimal to no physical efforts required.

Level 8-2 is not met. Unlike this level, the appellant’s assignments do not regularly involve long periods of standing, bending, and stooping to observe and study work operations in an industrial, storage, or comparable work area.

Factor 8 is evaluated at Level 8-1, and 5 points are assigned.

Factor 9, Work environment

This factor considers the discomfort and risk of danger in the employee’s physical surroundings and the safety precautions require.

At Level 9-1, work is typically performed in an adequately lighted and climate-controlled office and may require occasional travel.

At Level 9-2, assignments regularly require visits to manufacturing, storage, or other industrial areas, and involve moderate risks or discomforts. Protective clothing and gear and observance of safety precautions are required.

Level 9-1 is met. Like this level, the appellant’s work is performed in a well-lit and climate-controlled office setting with little to no travel required.

Level 9-2 is not met. Unlike this level, the appellant’s assignments do not regularly require visits to manufacturing, storage, or other industrial areas, involving moderate risks or discomforts. His work does not require the use of protective clothing and gear and observance of safety precautions.
Factor 9 is evaluated at Level 9-1, and 5 points are assigned.

Summary

A total of 2790 points falls within the GS-12 grade level point range of 2755-3150 points on the Grade Conversion Table in the AAGEG.

Factor	Level	Points
Knowledge required by the position	1-7	1250
Supervisory Controls	2-4	450
Guidelines	3-4	450
Complexity	4-4	225
Scope and Effect	5-4	225
Personal Contacts	6-3	----
Purpose of Contacts	7-c	180
Physical Demands	8-1	5
Work Environment	9-1	5
Total Points		2790

Decision

The appellant’s position is properly classified as an Administrative Officer, GS-0341-12.

1. An undated classification evaluation statement in the case file shows that agency human resources staff reviewed the position’s classification and recommended it be classified as Management and Program Analyst, GS-0343-13. However, the agency did not implement the findings.

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