Washington, DC

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

---

Lakshmi Bouchard
Classification Appeals and FLSA Claims Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


10/09/2018

---

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 title 5, Code of Federal Regulations, sections 511.605, 511.613, and 511.614, as cited in the Introduction to the Position Classification Standards, 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 5 CFR parts 351, 432, 536, and 752 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 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 Support Services Specialist (Records Manager/Mail and Files Clerk), GS-0342-9, but she believes it should be classified in the Records and Information Management Series, GS-0308, and graded at the 11 level. The position is assigned to Information Technology and Telecommunications, National Capital Region (NCR), National Park Service (NPS), U.S. Department of the Interior, in Washington, DC. We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

Background and general issues

In response to the request for a desk audit of the appellant’s position, the NPS’s Human Resources Operation Center (HROC) conducted a review of her position. In its September 21, 2017, evaluation of the position, the HROC did not render a decision on the appropriate classification of the position but instead stated:

It is determined that the incumbent is performing duties outside of her current PD. It is recommended that a new [PD] is developed, that accurately describes her duties and responsibilities, and submitted to HROC Classification to be classified, which may be subject to competitive procedures.

However, an October 16, 2017, memorandum from the NCR’s Human Resources Officer states the HROC determined the appellant’s position was properly classified as Support Services Specialist, GS-0342-9. She was subsequently reassigned, effective October 29, 2017, from Acquisition, Financial Assistance, and Property Management to the Information Technology and Telecommunications. The appellant asserts that, although her immediate supervisor changed, there was no change to her major duties and responsibilities as a result of the reorganization.

In her appeal request to OPM, the appellant states she has “an approved Desk Audit that substantiates that [she is] working outside of [her] scope.” She makes other statements about her agency’s classification review process and evaluation of her position. In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of her position. By law, we must make that decision solely by comparing the appellant’s current duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112). Because our decision sets aside any previous agency decisions, the classification practices used by the appellant’s agency in classifying her position are not germane to the classification appeals process.

Position information

As the NCR’s Records Manager, the appellant provides records liaisons, management officials, and other employees in the region with advice regarding the preservation, identification, indexing, accessing, and disposing of records. Her oversight responsibilities include evaluating records management activities for compliance with Director’s Order 11D: Records and Electronic Information Management, NPS-wide Records Schedule (SRS), Records and Electronic Information Management (REIM) Guide, and other requirements. She coordinates and provides records training to NCR staff. Under the Regional Director’s leadership, the NCR is comprised of the regional office (RO) and approximately 12 parks, monuments, and offices (hereafter referred to as “parks”) in or near the Washington, DC area with an estimated 2,500 to 3,000 employees. The appellant’s position is supervised by the Regional Chief, Information Technology (a GS-2210-14 Supervisory Information Technology Specialist position).

The immediate supervisor certified to the accuracy of the appellant’s official PD, number 0000240. OPM considers a PD to be accurate for classification purposes when the major duties and responsibilities of the position are listed and proper classification can be made when the description is supplemented by otherwise accurate, available, and current information on the organization’s structure, mission, and procedures. Although her official PD allocates 30 percent of the time to mail and file work, the appellant states she spends 95 percent of her time on records management work and five percent on mail and file work to include providing oversight to the contractor operating the RO’s mailroom. The immediate supervisor was unable to confirm her percentages of time, but we find her estimates plausible given the limited mail and file duties described by her PD and the contractor’s presence in the mailroom performing such work. Only duties occupying at least 25 percent of an employee’s time can affect the classification of a position. Minor duties generally occupy a small portion of time, are not the primary purpose for which the position was established, and do not determine qualification requirements (see sections III.F and III.J of the Introduction). Because the mail and file work is considered a minor duty, the PD of record must be corrected to allow for the proper classification of her position which we will discuss further in the series determination section of our decision. We also note the PD incorrectly states her position is assigned to Acquisition, Financial Assistance, and Property Management and supervised by a GS-11 Fleet/Property Manager. The appellant’s PD does not meet the standard of adequacy addressed on pages 10-11 of the Introduction, and the agency must revise the PD to reflect our findings.

The appellant states her PD does not describe all the work she performs, identifying more than 25 duties she asserts are missing from the PD of record. Some listed duties were performed only once or occasionally (e.g., conducting market research and drafting statements of work), considered minor duties, and are therefore not required to be included in the PD. Other items on her list are considered knowledge, skills, or abilities required to perform the work (e.g., using technology to increase records management efficiencies, staying current on records management laws and regulations, and applying analytical and evaluative skills to records management issues) rather than actual duties required for PD inclusion.

We conclude other duties identified as missing by the appellant are specifically addressed by the PD in one of eight records management-related duties identified, the introduction, or the factor-level description. She suggests adding duties to the PD including providing guidance to records liaisons and custodians on recordkeeping obligations and information management lifecycle requirements, but the PD similarly describes the position as providing advice on safeguarding and preserving records and recommending records maintenance strategies. The appellant suggests the addition of a training-related duty, but we note the PD states she develops and provides training. She also suggests including a duty relating to the research, development, and implementation of records management procedures, but the PD similarly describes work related to developing, refining, and implementing records management policies and guidance. The appellant also identifies several specific tasks she performs (e.g., locating records, organizing case files and records, assisting in the transition of paper to electronic records, scheduling the physical transfer and retirement of records, and preparing inventories and plans for records disposition), which she asserts should be specifically included in her PD. Her PD was intended to highlight her role as advisor on records management issues rather than to describe the actual performance of such operational tasks, but we note the factor-level description section of the PD states she works with staff on establishing plans and assisting with records tasks. A PD does not have to be a comprehensive and detailed narrative of the characteristics and complexities of a position’s duties. A PD is accurate when the major duties and responsibilities of the position are listed. They should be only those duties currently assigned, observable, identified with the position’s purpose and organization, and expected to continue or recur on a regular basis over a period of time. Based on these criteria, we find the appellant’s PD fully describes her records management duties and responsibilities. This and other work will be further considered under the grade determination section of this decision.

Regardless, an OPM appeal decision classifies a real operating position and not simply the PD. Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the actual duties and responsibilities assigned by management and performed by the employee.

In reaching our classification decision, we carefully considered all information provided by the appellant and her agency including her official PD which, although not completely accurate, we have incorporated by reference into this decision. In addition, to gain more information about her work, we conducted a telephone audit with the appellant and telephone interviews with her immediate supervisor and the NPS’s Records Manager.

Series, title, and standard determination

The appellant believes her position warrants classification to the GS-0308 Records and Information Management Series, which covers two-grade interval positions that supervise, lead, or perform records information management work including planning, controlling, directing, organizing, training, promoting, and other activities involved with respect to records creation, records maintenance and use, and disposition in order to achieve adequate and proper documentation of the policies and transactions of the Federal Government and effective and economical management of agency operations. The work requires knowledge of records management laws, regulations, rules, policies, and procedures; the principles and concepts of information governance of various phases of records and information management; and the complete records process and content management framework that supports the entire life cycle of agency records.

The appellant’s position is currently classified to the GS-0342 Support Services Administration Series, which covers one-grade interval positions the primary duties of which involve supervising, directing, or planning and coordinating a variety of services functions that are principally work-supporting. Because her current position is classified to a one-grade interval series and she is requesting classification to a two-grade interval series, we must first determine whether the work she performs is covered by a one-grade interval support or two-grade interval administrative series. Since some tasks are common to both types of occupations, it is not always easy to distinguish between work classified in one-grade and two-grade interval occupations. Guidance on distinguishing the work is contained in the Introduction and The Classifier’s Handbook.

Support work usually involves proficiency in one or more functional areas or in certain limited phases of a specified program. Normally a support position can be identified with the mission of a particular organization or program. The work usually does not require knowledge of interrelationships among functional areas or organizations. Employees performing 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. Support personnel typically learn to do the work on the job through what may sometimes be many years of experience.

On the other hand, administrative work primarily requires a high order of analytical ability combined with a comprehensive knowledge of (1) the functions, processes, theories, and principles of management, and (2) the methods used to gather, analyze, and evaluate information. Administrative work also requires skill in applying problem-solving techniques and skill in communicating effectively both orally and in writing. Administrative positions do not require specialized education, but they do involve the type of skills (analysis, research, writing, judgment) typically gained through college-level education or through progressively responsible experience. Administrative work often involves planning for and developing systems, functions, and services; formulating, developing, recommending, and establishing policies, operating methods, or procedures; and adapting established policy to the unique requirements of a particular program.

Because the appellant asserts her position is classifiable to the GS-0308 series, we first considered whether her work is one-grade interval support or two-grade interval administrative in nature. The primary purpose of her position is to serve as NCR’s Records Manager, advising staff on records management issues; managing temporary and permanent records (paper, electronic, video, audio, and photographs) including its creation, dissemination, storage, disposition, and retention; recommending strategies for preserving records in active use; and disposing of records either by transfer to records center or destruction. The appellant regularly resolves problems or issues relating to records identification, categorization, handling, and disposition. Her work requires applying relevant laws and regulations, as well as agency-specific policy documents, handbooks, guidelines, and accepted practices and procedures to advise NCR employees. In contrast to administrative positions, her work is based on knowledge of the organization’s mission, goals, and functions in combination with an extensive but practical knowledge of records management gained through many years of experience.

The appellant forwarded various work samples to OPM including site inspection and assessment forms, corrective action plans, and other memorandums drafted as a result of the onsite assessments she conducts to ensure an office’s compliance with records management requirements. She prepares for assessments at the RO and NCR parks by mailing notification letters to the administrative officer or records liaison 30 days prior to the visit, reviewing findings from previous assessments, and preparing checklists and questionnaires to be completed onsite. During the visit, she interviews the records liaison to ascertain the extent of records management knowledge and the office’s current practices, as well as reviews records to ensure they are maintained properly and consistently with existing electronic and paper file plans (i.e., detailed lists of the files contained in drawers and cabinets, identifying the category, subcategory, retention authority and requirement, and the managing project or program). She briefs records liaisons on her assessment findings. The appellant drafts a corrective action plan or other memorandum explaining deficiencies (e.g., failure to provide or implement file plans) in accordance with the Director’s Order 11D, SRS, REIM Guide, and other guidelines. In general, the appellant’s work samples show she provides a summary of information regarding the problems identified and recommendations to correct deficiencies from her onsite assessments. Because she provides interpretations to and recommendations consistent with Director’s Order 11D, SRS, REIM Guide, and other readily applicable records management guidelines established by NPS’s Records Manager and other higher agency-level officials, her onsite assessment and other work represents support for the park’s decision-making regarding records management rather than actual decisions made by the appellant. Also unlike administrative work, her position does not require application of a high level of analysis or judgment to make the information available or gathered fit a particular situation covered by relevant laws, regulations, or other guidelines.

Some aspects of the appellant’s work are similar to duties illustrated in the GS-0308 position classification flysheet (e.g., provide advice and guidance to records liaisons, coordinate the proper disposition of records, conduct training, and conduct compliance audits), but her position does not meet the nature of work and level of knowledge required for assignment to the two-grade interval administrative series. The GS-0308 series does not cover positions with limited responsibilities for performing records and information management work. It is intended to cover positions primarily responsible for the overall management of the records and information management program; therefore, it assumes authority has been delegated to manage the program from formulating policy to ensuring sound information governance and accountability measures are in place. In contrast, the appellant’s position does not require broad or in-depth knowledge and application of records management principles and concepts or the analytical and evaluative methods required for program management work characteristic of the GS-0308 series. The narrow scope of her decision-making responsibilities and the extensive guidelines applicable to her work preclude her position from assignment to the GS-0308 series. Instead, the appellant’s work is considered one-grade interval support in nature.

The agency classified the appellant’s position to the GS-0342 series, which covers one-grade interval positions that involve supervising, directing, or planning and coordinating a variety of services functions that are principally work-supporting, i.e., those functions without which the operations of an organization or services to the public would be impaired, curtailed, or stopped. Such service functions include, but are not limited to, communications, procurement of administrative supplies and equipment, printing, reproduction, property management, space management, records management, mail service, facilities and equipment maintenance, and transportation. Clearly, GS-0342 positions perform more than one service function. Because her mail and file work is considered a minor duty and does not influence the overall classification, the appellant’s position with responsibility for providing records management services would not meet the variety element required by the GS-0342 series. We further note the GS-0342 PCS specifically excludes positions, like the appellant’s, concerned with the performance of substantive work properly classified in an established series.

After careful consideration, we find the appellant’s position is properly classified to the GS-0344 Management and Program Clerical and Assistance Series. This series includes positions involved in supervising or performing clerical and technical work in support of management analysis and program analysis, the purposes of which are to evaluate and improve the efficiency, effectiveness, and productivity of organizations and programs. The work requires a practical knowledge of the purposes, methods, and techniques of management and/or program analysis and the structures, functions, processes, objectives, products, services, resource requirements, and similar features of Government programs and organizations.

GS-0344 employees apply clerical and technical procedures, methods, and techniques to support management analysis functions and processes. Management analysis involves analyzing, evaluating, and improving the efficiency of internal administrative processes, organizations, or management. It also involves developing, evaluating, and advising on the methods and policies for providing administrative or information management systems to agencies such as records, directives, mail, or forms management systems. Some GS-344 employees work independently to control and maintain installed administrative or information management systems such as forms, records, mail, directives, or publications management systems. GS-344 employees apply policies and procedures to assist operating personnel in understanding and using the systems; identify problems or deviations in system use; apply or adapt established guidelines to correct problems; make operational changes or improvements within the policy or structural limitations of the systems; and identify and refer serious problems or questions, requiring detailed analysis or extensive system modification (i.e., beyond the limits of established policies), to the responsible management analyst or higher-level employee. We find the appellant’s work is descriptive of the GS-344 series as her work supports the evaluation and improvement of the efficiency and effectiveness of the records management system in place at the RO and NCR parks.

Management Assistant is the appropriate title for positions at the GS-5 and above that primarily involve performing work, like the appellant’s, in support of management analysis functions and processes. We applied the grading criteria in the GS-0344 PCS to determine the grade of her position.

Grade determination

The GS-0344 PCS uses the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are assigned for each of the nine factors. The total points assigned are converted to a grade level by use of a grade conversion table provided in the PCS. Under the FES, each factor-level description demonstrates the minimum characteristics needed to receive credit for the described level. 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 the deficiency is balanced by an equally important aspect that meets a higher level. Conversely, if a factor is evaluated above the highest factor level published in the PCS, the factor is evaluated by reference to the Primary Standard (PS), the FES’s “standard-for-standards” in Appendix 3 of the Introduction, and other related FES standards.

Factor 1, Knowledge Required by the Position

This factor covers the nature and extent of information or facts the employee must understand to do acceptable work (e.g., steps, procedures, practices, rules, policies, regulations, and principles) and the nature and extent of the skills needed to apply the knowledge.

At Level 1-4, the highest level described in the PCS, the work requires knowledge of an extensive body of management analysis technical rules, guidelines, regulations, and precedents. It also requires knowledge of basic objectives and policies governing various management or program operations. Some work requires skill in applying basic data gathering methods, such as standard interviewing or surveying techniques, to collect various types of factual information. Some also apply knowledge of standardized processes for evaluating management operations to perform duties such as planning the steps to take to complete assignments, identifying problems from collected data, and selecting solutions from alternatives in guidelines and precedent cases. Some employees also use writing skills to prepare reports. Employees apply this knowledge to individual, nonstandard technical assignments. Assignments may involve limited aspects of higher level work.

The appellant’s position fully meets Level 1-4. Her work requires knowledge of the objectives and policies governing records management. As at this level, she applies extensive knowledge of records management rules, guidelines, regulations, and precedents provided by the NPS, Department, and National Archives and Records Administration (NARA) to evaluate compliance of the RO and NCR parks with requirements. Her work is comparable to an illustration in the PCS at Level 1-4:

Employees monitor the management of records in an organization by distributing questionnaires to offices asking them for lists of file numbers and corresponding subject content and, using knowledge of agency records management regulations, reviewing the completed questionnaires to ensure material is filed under proper record numbers. Periodically, employees inspect the files of these offices to ensure all records are stored and labeled correctly, contain current material, and are not duplicated. If problems exist, they explain procedures to the office’s records coordinator including how to number and store paper, electronic, and other types of records; when to dispose of or transfer records to central holding areas; and how and where to store or destroy classified records.

Similar to the description and illustration at Level 1-4, the appellant performs individual, nonstandard technical assignments such as onsite assessments, which require application of interviewing techniques and other basic data gathering methods to collect factual information and writing skills to prepare narrative reports of her findings. She reviews data and makes observations while onsite to determine whether records activities and functions meet requirements, assisting the office when necessary in adopting recommendations to correct deficiencies.

We found the knowledge required by the appellant’s position exceeds Level 1-4 and instead meets Level 1-5 as described by the PS. The PS describes Level 1-5 as practical knowledge of technical methods to perform assignments such as carrying out limited projects involving the use of specialized complicated techniques. Because Director’s Order 11D mandates all of NPS to stop creating paper records by managing records in electronic records management systems, the appellant is tasked with projects involving an office’s migration to an electronic records system. For example, when the RO moved into temporary office space, she was responsible for developing strategies and an action plan to process and digitize 400 cubic feet of paper records for storage at the records center. Such work requires classifying records by identifying the appropriate category of each record, e.g., records regarding resource management and lands to category 1, protection and safety to 2, fire management to 3, park facilities and maintenance to 4, commercial visitor services to 5, interpretation and education to 6, partnerships to 7, national assistance program to 8, information and public information management to 9, and management and accountability to 10. She prepares inventory lists and organizes records in chronological and alphabetical order. She completes the Standard Form 135, Records Transmittal and Receipt, for approval to transfer paper records to the Government-approved records center for storage. In addition to requiring thorough and detailed knowledge of, and skill in applying, records management rules, procedures, and operations, her work requires knowledge of the mission, activities, and operations to classify and organize the extremely varied records of program offices within the NCR. Consistent with Level 1-5, she applies knowledge of, and skill in applying, practical knowledge of the specialized records management regulations, techniques, principles, and concepts to records modernization projects complicated by, e.g., the NPS designating approximately 85 percent of their records as permanent and records classifiable to diverse categories, as well as the need to devise strategies and action plans to accomplish work within the specified timeframe, monitor work progress of employees assigned to assist with project execution, and resolve technical problems encountered (e.g., undated records).

We confirmed the factor level we assigned to the appellant’s position by reference to an analogous FES standard, i.e., the Job Family Standard (JFS) for Assistance and Technical Work in the Medical, Hospital, Dental, and Public Health Group, GS-0600, which covers positions classified to the GS-0675 Medical Records Technician Series. This series describes one-grade interval technical support positions performing support work in connection with processing and maintaining medical records for compliance with regulatory requirements. The GS-0600 JFS describes Level 1-5 as positions having, in part, a thorough and detailed knowledge of, and skill in applying, a comprehensive body of rules, procedures, and operations such as medical records activities, operations, and regulations; medical record classification systems coding techniques; and computerized data entry and retrieval systems. This knowledge is sufficient to assist in a wide range of quality assurance studies; make recommendations to improve procedures for compiling and retrieving medical records information; identify specific clinical findings, support existing diagnoses, or substantiate listing additional diagnoses in the medical record; code complicated medical records that are difficult to classify; plan, organize, and maintain special registries; gather and represent data graphically; make a variety of basic statistical computations; identify possible trends and patterns for preparing reports; and manage medical records.

The appellant’s position requires broad knowledge of records management laws, regulations, policies, and practices to perform work characteristic of the Level 1-5 description in the GS-0600 JFS, including assisting in quality assurance studies, making recommendations to improve procedures, and managing NCR’s records. We recognize the appellant’s position does not require the knowledge of medical-related records and functions, terminology, and classification systems noted by the GS-600 JFS at Level 1-5; this deficiency, however, is balanced by her role as Records Manager for the NCR which extends beyond the management of an individual record type or office but instead encompasses the wide variety of record types generated by all program offices at the RO and NCR parks with its estimated 2,500 to 3,000 employees. As NCR’s Records Manager, she identifies the need for refining, developing, and implementing regional-level guidance (e.g., protocol for managing emails). She provides NPS’s Records Manager with input regarding regional-level impact resulting from agency initiatives and new or revised laws and regulations. The appellant provides annual three-hour training covering topics including, but not limited to, program history; roles and responsibilities; record types, maintenance, schedules, and categories; and other areas she determines based on consideration of staff needs. We conclude her responsibility for the regional-level records management functions and activities require a more thorough and detailed knowledge of the comprehensive body of records management rules, procedures, and operations to perform specialized, complicated assignments consistent with the Level 1-5 description in the PS and GS-0600 JFS. The appellant’s position fully meets but does not exceed Level 1-5.

Level 1-5 is credited for 750 points.

Factor 2, Supervisory Controls

This factor covers the nature and extent of direct or indirect controls exercised by the supervisor, the employee’s level of independence and personal responsibility, and how the work is reviewed or controlled.

At Level 2-3, the highest level described in the PCS, the supervisor or higher-level employee defines the objectives, priorities, and deadlines for projects or assignments and assists the employee with unusual situations, problems, or studies that do not have clear precedents. The employee plans and carries out the successive steps of management analysis technical projects and assignments and handles problems and deviations in accordance with instructions, policies, previous training, or accepted practices. The supervisor or higher-level employee evaluates reports and other completed work for technical soundness, appropriateness of conclusions or recommendations, consistency, relevance of support material, and compliance with policies and requirements. The methods used in arriving at the end results are not reviewed in detail.

The appellant’s position fully meets but does not exceed Level 2-3. The immediate supervisor does not provide input on objectives, priorities, and deadlines due to the generally recurring nature of most of her tasks. She has discretion to plan, schedule, and complete her onsite assessment and training work. However, when she assists an office with records modernization and other projects, the administrative officer or other records liaison generally provides her with the project objectives and deadlines characteristic of Level 2-3. She plans, coordinates, and carries out specific steps when necessary to complete NCR’s records management activities and functions. Problems and deviations are handled in accordance with accepted practices, previous training, and program instructions and policies as described at Level 2-3. The appellant contacts the NPS’s Records Manager when problems arise for which guidance conflicts or requires policy interpretations, e.g., developments related to litigation holds on records. Also at Level 2-3, her work is reviewed in terms of results achieved, consistency and compliance with policy, appropriateness of recommendations, timeliness, and customer service.

Level 2-3 is credited for 275 points.

Factor 3, Guidelines

This factor considers the nature of guidelines and the judgment needed to apply them.

At Level 3-3, guidelines lack specificity or are not completely applicable to the work requirements, circumstances, or problems because of the unique or complicating characteristics of the assignments. For example, standard procedures for tracking program or project status require frequent modifications due to fluctuations in budgets, production goals, or workload and established records or forms management practices require adaptation for consistent use by organizations with different functions and administrative needs. The employee uses judgment in interpreting and adapting guidelines to apply to specific situations such as evaluating the appropriateness of justifications for changes in clerical staffing levels; determining the cause or extent of deviations from established production rates or resource use; or determining whether an organization’s proposed directives, publications, or functional statements are within the scope of their established delegated authority or assigned function. The employee analyzes the results of applying guidelines and recommends changes to them.

The appellant’s guidelines fully meet but do not exceed Level 3-3. Her guidelines include Director’s Order 11D, the SRS, and the REIM Guide. The guidelines, which are to be applied in conjunction with each other, describe NPS activities and standards for maintaining and providing access to paper and electronic records. Other guidelines include oral instructions, standard practices and procedures, and other legal, regulatory, or policy requirements issued by NPS, Department, or NARA. Although guidelines are available, the appellant encounters unique or complicating circumstances as a result of the diverse record types and the varying records management practices adopted by the RO and NCR parks. Her position requires using judgment to apply guidelines to the specifics involved in each office to identify relevancy to the situation. Consistent with Level 3-3, the appellant analyzes the results of applying guidelines and develops standard operating practices and procedures (e.g., records management close out procedures for departing employees) when necessary for NCR-wide implementation.

Level 3-3 is credited for 275 points.

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 4-3, the highest level described in the PCS, work consists of various duties, projects, or assignments involving different and unrelated management analysis technical processes and procedures. Assignments or projects involve various actions or steps that are not completely standardized or prescribed in instructions, guidelines, or precedent cases; adaptation or modification of established procedures and methods; various types and sources of information; nonrecurring problems, trends, or issues; management operations with varying or changing conditions (e.g., work units or program areas with different functions or requirements or with period changes in workloads, budgets, staff levels, work processes, or program objectives); or similar features. The employee decides what needs to be done by considering the characteristics, practices, objectives, and interrelationships of various work units, program areas, and/or management or program operations. The employee studies and analyzes issues such as the nature of the assignments; the various sources of information; the nature and requirements of the work units, program areas, or operations; the objectives of management analysis processes and techniques; and the applicability of precedent cases, rules, and regulations. The employee selects, adapts, and applies the most suitable practices, procedures, methods and precedents to collect and analyze various types of information, formulate conclusions, define needs, and/or make recommendations for resolving problems to higher level employees.

The complexity of the appellant’s position fully meets but does not exceed Level 4-3. As at this level, her work consists of various duties, projects, and assignments involving different, unrelated technical processes and procedures relating to the management, retention, disposal, and protection of records. Work steps require application of established procedures and methods to resolve the wide variety of records management issues expected at Level 4-3. An example provided by the PCS at Level 4-3 includes studying work processes of clerical work units with different functions and objectives and identifying areas requiring improvements. Similarly, the appellant conducts an all-day assessment at the RO and NCR parks, which involves interviewing the records liaison to explain the purpose of the visit and ascertain the employee’s knowledge regarding records creation, maintenance and use, and disposition. She walks around office spaces to make observations relating to, e.g., the condition of the building where records are stored, volume of paper records stored, and appropriate maintenance of records containing personally identifiable information. She takes photographs to support observations. She also reviews the paper and electronic file plans to determine if plans are being followed. Consistent with Level 4-3, the appellant considers extensive amounts of data from her interviews, observations, review of local plans and procedures, and other sources of information to identify issues, determine if sufficient information has been gathered to substantiate findings, and propose recommendations enabling park officials to make records management-related decisions.

Level 4-3 is credited for 150 points.

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 assignments, and the effect of work products or services both within and outside the organization.

At Level 5-3, the highest level described in the PCS, the purpose of the work is to plan and carry out assignments or projects which improve the efficiency and productivity of organizations or program operations. Employees use established methods and criteria to identify, study, and recommend solutions for resolving conventional problems or questions. The work affects the design of organizational structures and workflow; the evaluation and improvement of operating program efficiency and effectiveness; the use and management of staff, funding, equipment, and other resources; and the design or use of similar management or program operations. Some of the work also affects the management of administrative or information systems throughout a wide range of offices or organizations with different administrative or information management needs.

The appellant’s position fully meets but does not exceed Level 5-3. As at this level, she carries out records management functions and activities for the region, delivering annual classroom training, conducting assessments, and providing advice and recommendations on records management issues and problems. This work is accomplished by application of established procedures, processes, and guidelines to resolve conventional problems or questions as expected at Level 5-3. She advises records liaisons and other staff on preservation, maintenance, and disposition of records, which ultimately affect public access to information. Her work affects the records management systems and practices adopted by the RO and NCR parks. Similar to Level 5-3, the appellant’s position affects the management of administrative or information systems throughout a wide range of offices with different needs, as well as the efficiency and productivity of the organizations by ensuring consistent and appropriate control and handling of records.

Level 5-3 is credited for 150 points.

Factors 6 and 7, Personal Contacts and Purpose of Contacts

Personal contacts include face-to-face and telephone contacts with persons not in the supervisory chain. Levels described under this factor are based on what is required to make the initial contact, the difficulty of communicating with those contacted, and the setting in which the contact takes place. These factors are interdependent. The same contacts selected for crediting Factor 6 must be used to evaluate Factor 7. The appropriate level for personal contacts and the corresponding level for purpose of contacts are determined by applying the point assignment chart for Factors 6 and 7.

Personal Contacts

At Level 2, which is the highest level described in the PCS, contacts are with employees in the same agency but outside the immediate organization. Persons contacted are with managers, employees, and other representatives of the programs involved or organizations served. Contacts may also be with members of the general public, as individuals or groups, in moderately structured settings at Level 2. For example, the employee may contact contractors to obtain justifications for project delays.

At Level 3, as described in the PS, contacts are with individuals or groups from outside the employing agency in a moderately unstructured setting. For example, the contacts are not established on a routine basis; the purpose and extent of each contact is different; and the role and authority of each party is identified and developed during the course of the contact. Typical contacts at this level are those with people in their capacities as attorneys, contractors, or representatives of professional organizations, the news media, or public action groups.

Similar to Level 2, the appellant’s recurring contacts are with employees at all levels of the RO and NCR parks, as well as with NPS’s Records Manager. Although she has contact with NARA officials, Level 3 is not met since her personal contacts outside her agency are established on a regular basis, and the role and authority of the persons contacted are known to her in advance of the contact or established early in the contact. Her personal contacts meet Level 2.

Purpose of Contacts

At Level b, which is the highest level described in the PCS, the purpose of the contacts is to plan, coordinate, or advise on work efforts; discuss significant findings; or resolve operating problems by influencing or motivating individuals or groups who are working toward mutual goals.

Similar to Level b, the appellant plans, coordinates, and advises on records management-related work efforts with RO and NCR park staff. She discusses assessment findings with records liaisons to resolve problems, implement efficiencies, and ensure compliance with requirements. The appellant’s position meets but does not exceed Level b.

Level 2b is credited for 75 points.

Factor 8, Physical Demands

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

At Level 8-1, which is the only level identified in the PCS, the work requires no special physical demands. It may involve some walking, standing, bending, or carrying of light items.

At Level 8-2, as described in the PS, the work requires some physical exertion such as long periods of standing; walking over rough, uneven, or rocky surfaces; recurring bending, crouching, stooping, stretching, reaching, or similar activities; or recurring lifting of moderately heavy items, such as typewriters and record boxes. The work may require specific, but common, physical characteristics and abilities, such as above average agility and dexterity.

Similar to Level 8-1, the appellant’s work involves some walking, standing, bending, or carrying of light items. While carrying out records modernization projects and other work, she lifts boxes of records, which she estimates at 30 to 40 pounds, to be placed on a box-moving handcart. Unlike Level 8-2, her work does not require recurring lifting of moderately heavy items (under 50 pounds). Her work involves the occasional and brief lifting of boxes onto the handcart rather than the recurring (i.e., the repetitive or continuous) lifting of moderately heavy items expected at Level 8-2.

Level 8-1 is credited for 5 points.

Factor 9, Work Environment

This factor considers the risks and discomforts in the employee’s physical surroundings or the nature of the work assigned and the safety regulations required.

As at Level 9-1, which is the only level identified in the PCS, the appellant’s work is performed in an office or similar setting requiring normal safety precautions against everyday risks or discomforts.

Level 9-1 is credited for 5 points.

Summary

Factor	Level	Points
1.  Knowledge Required by the Position	1-5	750
2.  Supervisory Controls	2-3	275
3.  Guidelines	3-3	275
4.  Complexity	4-3	150
5.  Scope and Effect	5-3	150
6. & 7.  Personal Contacts and Purpose of Contacts	2-b	75
8.  Physical Demands	8-1	5
9.  Work Environment	9-1	5
Total		1,685

This point total falls within the GS-8 range (1,605-1,850) on the grade conversion table provided in the Introduction.

Decision

The appellant’s position is properly classified as Management Assistant, GS-0344-8.

Back to Top