Washington, DC

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

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Carlos A. Torrico
Acting Classification Appeals and FLSA Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance

10/11/2017

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Date

Introduction

The appellant’s position is currently classified as Resource Manager, GS-501-14, but she believes it should be classified at the GS-15 grade level.  The position is assigned to the Resource Management Directorate (Directorate), Electronic Proving Ground (EPG), Army Test and Evaluation Command (Command), U.S. Department of the Army (DA), at Fort Huachuca, Arizona.  We have accepted and decided this appeal under section 5112 of title 5, United States Code (U.S.C.).

General issues

The appellant compares her position to other DA positions classified to the GS-15 grade level, as described by various PDs she submitted to OPM.  By law, we must classify positions solely by comparing their duties and responsibilities to OPM position classification standards (PCS) and guidelines (5 U.S.C. 5106, 5107, and 5112).  Since comparison to PCSs and guidelines is the exclusive method for classifying positions, we cannot compare the appellant’s current duties to other positions, which may or may not be classified properly, as the basis for deciding her appeal.

Implicit in the appellant’s rationale is a concern her position is classified inconsistently with other DA positions.  Like OPM, the agency must classify positions based on comparison to OPM PCSs and guidelines.  In accordance with 5 CFR 511.612, agencies are required to ensure consistency with OPM certificates.  Consequently, the appellant’s agency has primary responsibility for ensuring its positions are classified consistently with OPM appeal decisions.  If the appellant believes her position is classified inconsistently with another, then she may pursue this matter by writing to the human resources office at her agency’s headquarters.  She should specify the precise organizational location, series, title, grade, and responsibilities of the positions in question.  The agency should explain to her the differences between her position and the others, or classify those positions in accordance with this appeal decision.

The appellant asserts in her classification appeal request to OPM that “modest edits to the inaccurate current [PD]” would result in classifying her position to the GS-15 grade level.  A PD is the official record of the major duties and responsibilities assigned to a position by a responsible management official; i.e., a person with authority to assign work to a position.  A position is the duties and responsibilities that make up the work performed by an employee.  Classification appeal regulations permit OPM to investigate or audit a position and decide an appeal on the basis of the duties assigned by management and performed by the employee.  We classify a real operating position, and not simply the PD.

The appellant’s rationale for a higher grade is based, in part, on Contractor Officer Representative (COR) and Alternate COR duties she previously performed.  The record shows she served as COR from November 2015 to April 2016, when she was designated as Alternate COR.  On May 5, 2016, her Alternate COR duties were terminated.  Her comments to the agency administrative report state the removal of Alternate COR duties was an “attempt to diminish” her duties and responsibilities.  By law (5 U.S.C. 302 and 5102(a)(3)), agency management has the right to establish positions and determine the work assignable to each position.  Management actions concerning the assignment and removal of work are not reviewable under the classification appeals process.  Under 5 U.S.C. 5112, we can only consider current duties and responsibilities in classifying positions.  Our analysis will focus on the current work performed by the appellant based on the entire record, including information obtained from telephone interviews with the appellant and immediate supervisor.

Position information

The appellant’s official PD, number EJ431722, and other material of record furnish information about her duties and responsibilities and how they are performed.  Although the appellant asserts her PD “understates” her duties and responsibilities, the supervisor certified to the accuracy of the duties described in her official PD.  We find the PD is adequate for classification purposes, and we incorporate it by reference into this decision. To help decide this appeal, we conducted telephone audits with the appellant and a telephone interview with the immediate supervisor (i.e., the Technical Director, a GS-801-15 Supervisory General Engineer position).

The EPG is the DA’s Command, Control, Communications, Computers, and Intelligence Developmental Tester.  The appellant’s position serves as principal advisor to the EPG Commander, Technical Director, and other staff on resource management issues including budgeting, financial accounting, program review, management analysis, and manpower.  The appellant supervises the Directorate’s staff comprised of approximately 11 positions.  She oversees the financial systems supporting EPG’s fiscal operations including the Defense Travel System, General Fund Enterprise Business System, and Automated Time, Attendance, and Production System.

Series, title, and standards determination

The appellant’s position is properly assigned to the Financial Administration and Program Series, GS-501.  The position meets the requirements for coverage and evaluation by the General Schedule Supervisory Guide (GSSG).  Since there are no titles specified for the GS-501 series, the agency may construct a title, which must include a supervisory designation consistent with guidance in the Introduction.  Neither the appellant nor agency disagrees.  We evaluated the appellant’s supervisory work by application of the GSSG.

The appellant’s personally performed work is properly evaluated by application of the grading criteria in the Job Family Position Classification Standard (JFS) for Professional and Administrative Work in the Accounting and Budget Group, GS-500.  We applied the GS-500 JFS to the appellant’s personally performed work, and determined those duties and responsibilities are graded lower than her supervisory work.  Because her personally performed work is neither grade controlling nor does it serve as the basis of her classification appeal, we will only briefly discuss our evaluation of her personally performed work.

Grade determination

Evaluation using the GSSG

The GSSG employs a factor-point evaluation method that assesses six factors common to all supervisory positions.  Each factor is evaluated by comparing the position to the factor-level description for that factor and crediting the points designated for the highest factor level which is fully met, in accordance with the instructions specific to the factor being evaluated.  The total points assessed under all factors are then converted to a grade by using the grade conversion table in the GSSG.

The appellant only disagrees with the agency’s evaluation of Factors 1, 2, and 3.  We reviewed the agency’s determination for Factor 4, concur, and have credited the position accordingly.  Our evaluation will focus on the remaining factors.

Factor 1, Program Scope and Effect

This factor assesses the general complexity, breadth, and impact of the program areas and work directed, including its organizational and geographic coverage (“scope”).  It also assesses the impact of the work both within and outside the immediate organization (“effect”).  These two elements are interrelated to some degree, but their distinction can be explained thus:  In addition to assessing complexity of the work supervised, “scope” measures the size or breadth of the organization directed in terms of either geographic coverage of line program operations (usually expressed in terms of the size of the population serviced and/or the area administered), or the organizational coverage of internal support activities (usually expressed in terms of organizational size or level).  “Effect” measures the degree to which the work supervised affects the organizations or populations supported.  In order for a particular factor level to be assigned under this factor, the criteria for both “scope” and “effect” must be fully met.  The agency assigned Level 1-2 under this factor.

            Scope

At Level 1-2, the program segment or work directed is administrative, technical, complex clerical, or comparable in nature.  The functions, activities, or services provided have limited geographic coverage and support most of the activities comprising a typical agency field office, an area office, a small to medium military installation, or comparable activities within agency program segments.

At Level 1-3, the position directs a program segment that performs technical, administrative, protective, investigative, or professional work.  The program segment and work directed typically have coverage which encompasses a major metropolitan area, a State, or a small region of several States; or, when most of an area’s taxpayers or businesses are covered, coverage comparable to a small city.  Providing complex administrative or technical or professional services directly affecting a large or complex multimission military installation also falls at this level.

The appellant’s position meets Level 1-2.  She directs a resource management program that performs administrative and technical work in support of EPG’s staff comprised of approximately 190 civilian employees, 300 full-time contractors, and 100 part-time contractors engaged in the performance of a variety of testing activities.  This is comparable to the geographic coverage of an agency field office or area office described at Level 1-2.  The appellant’s situation is comparable to the Level 1-2 illustration provided in the GSSG of a position directing budget, management, payroll, or similar services in support of a small Army, Navy, or Air Force base with no extensive research, development, testing, or comparable missions or a nondefense agency field office of moderate size and limited complexity.  Given the EPG’s testing mission, we recognize her position fully meets and somewhat exceeds the illustration at Level 1-2 of a position directing such services for an organization with no extensive testing missions.

The appellant seeks to credit her position at Level 1-4.  However, because each factor level is predicated on the preceding factor levels having been fully met, we must first compare her position to the description at Level 1-3 prior to considering Level 1-4 criteria.  The complexity of the work directed by the appellant is consistent with Level 1-3.  The types of work represented at Level 1-2 and 1-3 would appear to overlap in that both cover technical and administrative work.  Technical and administrative work extend across a range of grades, and the nature of such work described at Level 1-3 represents the higher end of the range.  The association of “administrative” work with professional and investigative work at Level 1-3 requires a corresponding grade association.  Since the GS-9 grade level is considered the first full performance level for two-grade interval professional and investigative work, then the administrative and technical work represented at Level 1-3 would be expected to be of the same level of complexity; i.e., two-grade interval work at the GS-9 or higher grade level.  The base grade level of work supervised by the appellant (as determined under Factor 5 of this decision) is GS-11, which is aligned with Level 1-3 complexity of work supervised.  However, although we conclude the complexity of work directed by her is consistent with Level 1-3, this level is not fully met as the population directly and significantly serviced by the program under her direction and control is not equivalent to a major metropolitan area, a State, or a small region of several States.  Also unlike Level 1-3, she does not provide complex administrative or technical or professional services directly affecting a large or complex multimission installation or the equivalent as defined by the GSSG (i.e., a total serviced employee-equivalent population exceeding 4,000 personnel engaged in a variety of serviced functions).  The illustration at Level 1-3 describes a position directing personnel, budget, or similar administrative services which support and directly affect the operations of a bureau or a major military command headquarters; a large or complex multimission military installation; an organization of similar magnitude, or a group of organizations which, as a whole, are comparable.  In contrast, the organizational coverage of her internally-oriented activities do not meet Level 1-3 as the population directly and significantly serviced by the appellant’s program includes the approximately 600 employees and contractors assigned to the EPG, i.e., a number significantly lower than that provided by the description and illustration at Level 1-3.

Since Level 1-3 criteria are not fully met, classification principles preclude consideration or the crediting of Level 1-4 as proposed by the appellant.  Scope is evaluated at Level 1-2.

            Effect

At Level 1-2, the services or products support and significantly affect installation level, area office level, or field office operations and objectives, or comparable program segments; or provide services to a moderate, local or limited population of clients or users comparable to a major portion of a small city or rural county.

At Level 1-3, activities, functions, or services accomplished directly and significantly impact a wide range of agency activities, the work of other agencies, or the operations of outside interests (e.g., a segment of a regulated industry), or the general public.  At the field activity level (involving large, complex, multimission organizations and/or very large serviced populations), the work directly involves or substantially impacts the provision of essential support operations to numerous, varied, and complex technical, professional, and administrative functions.

The appellant’s position meets Level 1-2.  As at this level, her work significantly affects resource management operations, functions, and activities at the EPG.  Her program provides services to a moderate, local, or limited population with the impact described at Level 1-2.

The appellant’s position does not meet Level 1-3.  The impact of her resource management program is limited to EPG operations and thus does not significantly affect the wide range of agency activities, the work of other agencies, or the actual operations of outside interests such as segments of an entire industry described at Level 1-3.  The appellant supervises budget analyst and technician work, which supports the ability of the EPG to effectively spend, monitor, track, and report on funds of the testing and support programs.  She also supervises management analyst positions engaged in analyzing the resources required to perform EPG’s testing and evaluation mission, as well as maintaining and adjusting the tables of distribution and allowances and other manning documents annually or when required.  In directing and performing these and other resource management functions at the EPG, the appellant’s position does not involve the diversity and scale of functions expected at Level 1-3 where work significantly impacts operations carrying out “numerous, varied, and complex” technical, professional, and administrative activities equivalent to that carried out at a large military installation with large-scale and diverse technical functions.

Effect is evaluated at Level 1-2.

Since both Scope and Effect are credited at Level 1-2, 350 points are assigned.

Factor 2, Organizational Setting

This factor considers the organizational situation of the supervisory position in relation to higher levels of management.

At Level 2-2, the position is accountable to a position that is one reporting level below the first SES, flag or general officer, or equivalent or higher level position in the direct supervisory chain.

At Level 2-3, the position is accountable to a position that is SES level, flag or general officer military rank, or equivalent or higher level; or to a position which directs a substantial GS/GM-15 or equivalent level workload; or to a position which directs work through GS/GM-15 or equivalent level subordinate supervisors, officers, contractors, or others.

The agency credited the appellant’s position at Level 2-2, but we find her position meets Level 2-3 instead.  The appellant seeks to credit her position at Level 2-3, stating in her appeal request to OPM that she reports to the EPG Commander (a Colonel position) rather than the Technical Director.  According to the Technical Director, he approves her leave, serves as the rating official on her performance appraisals, and provides direction regarding her and the Directorate’s work.  We thus conclude the appellant is directly accountable to the Technical Director.  The GSSG instructs that if a position reports to two different positions, select the factor level associated with the position which has responsibility for performance appraisals.  Even if the appellant reported to both the EPG Commander and Technical Director under a shared reporting relationship, which she does not, the GSSG instructs selecting the level associated with the position having performance appraisal responsibilities (i.e., the Technical Director).

Regardless, EPG is divided into five directorates:  the Resource Management Directorate, Test Resources and Laboratories Directorate, Command Support Directorate, Mission Command and Network Test Directorate, and the Intelligence Electronic Warfare Test Directorate.  With the exception of the appellant’s Directorate, the other directorates are headed by GS-15 supervisory positions who all report to the Technical Director.  Similar to Level 2-3, the appellant’s position reports to the Technical Director, a position responsible for directing the work performed by the EPG through GS-15 level subordinate supervisors.

Level 2-3 is credited for 350 points.

Factor 3, Supervisory and Managerial Authority Exercised

This factor considers the delegated supervisory and managerial authorities exercised on a recurring basis.  To be credited with a level under this factor, a position must meet the authorities and responsibilities to the extent described for the specific level.

The agency credited the appellant’s position at Level 3-3b, but she seeks to credit her position at Level 3-4.  Because each factor level is predicated on the preceding factor levels having been fully met, we must first compare her position to the description at Level 3-2 prior to consideration of subsequent factor levels.

In order to meet Level 3-2, a position must meet any of the conditions described in paragraphs a, b, or c under this factor level.  Supervisors at this level must carry out at least three of the first four, and a total of six or more of the 10 responsibilities listed at that level in the GSSG.  Based on our review of the record, we found the position fully meets Level 3-2c; as this is contested by neither appellant nor agency, we will not address the responsibilities further but incorporate them by reference into this decision.

In order to fully meet Level 3-3, a position must meet the conditions described in paragraphs a or b under this factor level.  Level 3-3a describes managerial positions with authority to devise long-range staffing needs and which are closely involved with high-level program officials (or comparable agency-level staff personnel) in developing overall goals and objectives related to high levels of program management and development or formulation.  The appellant serves as a first-level supervisor for an organization without the subordinate organizational units or subordinate supervisors envisioned for an organizational setting at Level 3-3a and does not exercise the significant and extensive program authority defined at that level.

At Level 3-3b, a supervisor must exercise all or nearly all of the supervisory responsibilities and authorities described at Level 3-2c, plus at least 8 of the 15 responsibilities listed under Level 3-3b of the GSSG.  The appellant’s position exercises all 10 of the responsibilities described at Level 3-2c.  Of the 15 responsibilities listed under Level 3-3b, her duties and responsibilities are compared below.

Responsibilities 1, 3, 5, 6, and 8 refer to situations where work is accomplished through subordinate supervisors, team leaders, or other similar personnel.  Further, the supervisor’s organizational workload must be so large and work so complex that it requires using two or more subordinate supervisors, team leaders, or comparable personnel to direct the work.  The appellant is a first-level supervisor.  Given that the organizational workload of approximately 11.0 staff years is not so large and the work is not so complex as to require using subordinate supervisors, team leaders, or comparable personnel to direct the work, the appellant’s position is therefore not credited with responsibilities 1, 3, 5, 6, and 8.

Regarding the remaining authorities, responsibility 2 is credited because the appellant exercises significant responsibilities when dealing with the Commander, directors, division chiefs, and other staff from EPG’s program offices, advising management officials of higher rank as discussed in her PD of record.

Responsibility 4 is not credited because the appellant does not direct a program with multi-million dollar resources directly under her discretion and control.  In her September 1, 2017, email to OPM, the appellant asserts:

All funding has been managed in totality by the [Directorate] where I have ultimate accountability for the distribution and execution for all funding requirements (payroll, contracts, supplies, facilities, rents, training, travel, etc.), which equates to $140M annually.

The level of discretion and control over the EPG’s overall annual budget, expected by responsibility 4, rests with the EPG Commander and Technical Director.  According to the Technical Director, the appellant manages but does not control the EPG’s overall annual budget.  The EPG Commander has delegated to her the discretion and control over her Directorate’s operating budget, projected for fiscal year 2018 at $14,910.  The Technical Director further states that salaries are considered a “must fund budget item” and thus not considered within her discretion and excluded from the Directorate’s operating budget.  Responsibility 4 does not consider Resource Manager responsibilities such as making budget, accounting, and planning-related recommendations concerning EPG’s annual budget of over $140 million.  Since the appellant lacks discretion and control over a multimillion dollar level of annual resources as confirmed by the Technical Director, responsibility 4 cannot be credited.

Responsibility 7 is credited because the appellant has authority to make or approve selections for subordinate nonsupervisory positions.

Responsibility 9 is not credited.  The appellant does not have authority to hear or resolve group grievances or serious employee complaints.  As stated by the appellant’s PD and confirmed by the Technical Director, she is to refer group grievances and serious employee complaints to the supervisor.  She can effect minor disciplinary measures (e.g., warnings, reprimands, or counseling letters which she recently issued to two subordinate employees involved in a workplace altercation).  However, such responsibility would not exceed that described by responsibility 7 of Level 3-2c, which is credited to supervisors who effect minor disciplinary measures such as warnings and reprimands, and recommend other action in more serious cases.

Responsibility 10 is not credited.  The appellant does not have authority to review and approve serious disciplinary actions (e.g., suspensions) involving nonsupervisory subordinates.  Such authority lies with the Commander or Technical Director.

Responsibility 11 is not credited.  The appellant does not have authority to make decisions on non-routine, costly, or controversial training needs and training requests.  Such decisions are made by the Commander or Technical Director.

Responsibility 12 is not credited because the appellant does not oversee the work of contractor personnel.  Since the work of the Directorate is performed by only civilian employees, she does not oversee the work of contractors in the manner intended for credit under this element.

Responsibility 13 is credited.  The appellant has authority to approve expenses comparable to within-grade increases, employee travel, and given an overtime budget, has the authority to approve extensive overtime.

The appellant recommends awards and bonuses for nonsupervisory personnel and changes in position classification, subject to approval by higher-level officials or others.  Directorate employees are not assigned to standardized PDs but rather to individual PDs classified by the local Civilian Personnel Advisory Center.  In addition to her PD describing responsibility for writing job descriptions, the appellant submitted emails to OPM showing she communicates with human resources staff to ensure duties assigned to subordinate staff are consistent with the classification of the position in addition to drafting and/or updating PDs associated with existing and new positions of the Directorate.  Given this environment, a recommendation by the appellant to change the classification of subordinate positions would have a reasonable chance of adoption.  Responsibility 14 is met.

Responsibility 15 is not credited.  It involves finding and implementing ways to eliminate or reduce significant bottlenecks and barriers to production, promote team building, or improve business practices; e.g., in a large production or processing unit.  This would apply to large organizations whose missions would be susceptible to the application of such methodological or structural improvements.  The work supervised by the appellant does not lend itself to those types of management applications.  The appellant’s authority in this area would not exceed that described by responsibility 9 of Level 3-2c, which is credited to supervisors who find ways to improve production or increase the quality of the work directed.

Our review of the appellant’s position against the criteria of either Level 3-4a or b is neither necessary nor appropriate.  Based on the information above, she performs only 4 of the 15 responsibilities listed under Level 3-3b.

Because the appellant’s position does not meet Level 3-3a, nor are 8 of the 15 responsibilities in Level 3-3b credited, Level 3-2c is credited for 450 points.

Factor 5, Difficulty of Typical Work Directed

This factor measures the difficulty and complexity of the basic work most typical of the organization directed, as well as other line, staff, or contracted work for which the supervisor has technical or oversight responsibility.

To evaluate first-level supervisors, the GSSG instructs determining the highest grade of basic (mission oriented) nonsupervisory work performed that constitutes 25 percent or more of the workload of the organization.  The following types of work are specifically excluded from the workload calculation:  work graded on the basis of supervisory or leader duties, work for which the supervisor does not have the minimum supervisory and managerial authorities defined under Factor 3, and lower-level support work primarily facilitating the basic work of the unit.

The agency credits the appellant’s position with Level 5-6, identifying GS-11 as the base level work of the organization.  Although the appellant does not disagree, we will nonetheless discuss this factor because the agency added and removed subordinate positions from the Directorate during our adjudication of the appeal (e.g., removed two positions with COR responsibilities and added a Financial Manager, GS-505-13, position).  We considered this impact, if any, on the base level supervised by the appellant’s position.  The following list shows the workload assigned to the Directorate and supervised by the appellant.

           GS-13

1         Financial Manager, GS-505[1]

           GS-12

1         Budget Analyst, GS-560

           GS-11

5         Budget Analyst, GS-560[2]

1         Management and Program Analyst, GS-343

1         Management Analyst, GS-343

           GS-9

1        Management Analyst, GS-343

          GS-7

1        Budget Technician, GS-561

Total nonsupervisory mission-oriented workload is 11.0 staff years.  The percentage of nonsupervisory mission-oriented workload at each grade level is as follows:

GS-13:             9.1%

GS-12:             9.1%

GS-11:             63.6%

GS-9:               9.1%

GS-7:               9.1%

At 9.1 percent each, the GS-13 and GS-12 grade level work constitute, separately and combined, less than 25 percent of the nonsupervisory workload.  We thus conclude the GS-11 work, at 63.6 percent, is fully representative of the highest level of nonsupervisory work performed by the organization.

Level 5-6 is credited for 800 points.

Factor 6, Other Conditions

This factor measures the extent to which various conditions contribute to the difficulty and complexity of carrying out supervisory duties, authorities, and responsibilities.  If the level selected under this factor is 6-1, 6-2, or 6-3, and if three or more of the eight Special Situations described are met, the original level selected is increased by one level.  If the level selected is 6-4, 6-5, or 6-6, the Special Situations do not apply and the original level selected is credited.

The agency credited the appellant’s position at Level 6-6b, and she does not disagree.  However, the agency has taken the criteria for Level 6-6 out of context and appears not to have considered the inherent inter-factor relationship that clearly exists within the GSSG between Factors 5 (difficulty of typical work directed) and 6.  At Level 6-6b, the position manages through subordinate supervisors and/or contractors who each direct substantial workloads comparable to the GS-12 or higher level.  Since the appellant’s position is not responsible for supervising subordinate supervisors, Level 6-6b is not applicable.  The appellant’s position also does not meet Level 6-6a, where supervision and oversight requires exceptional coordination and integration of a number of very important and complex program segments or programs of professional, scientific, technical, managerial, or administrative work comparable in difficulty to the GS-13 or higher level.  As discussed under Factor 5, we find the base level of work for the appellant’s organization is GS-11, not the GS-13 level as expected at Level 6-6a.

Instead, we find the appellant’s position meets Level 6-4a, where supervision requires substantial coordination and integration of a number of major work assignments, projects, or program segments of professional, scientific, technical, or administrative work comparable in difficulty to the GS-11 level.  Similar to Level 6-4a, the appellant coordinates and integrates assignments of administrative work comparable to the GS-11 level.  This includes tasks such as integrating the work of the Directorate, ensuring comparability and consistency of policy interpretation and application, and providing leadership in evaluating and improving processes and procedures to monitor the effectiveness, efficiency, and productivity of the organization directed.

Level 6-4a is credited for 1,120 points.

Summary
Factors	Level	Points
1.  Program Scope and Effect	1-2	350
2.  Organizational Setting	2-3	350
3.  Supervisory & Managerial Authority Exercised	3-2c	450
4.  Personal Contacts
A.  Nature of Contacts	4A-3	75
B.  Purpose of Contacts	4B-3	100
5.  Difficulty of Typical Work Directed	5-6	800
6.  Other Conditions	6-4a	1120
Total		3245

This point total falls within the GS-13 range (3,155-3,600) on the grade conversion table provided in the GSSG.

Evaluation using the GS-500 JFS

The GS-500 JFS uses the Factor Evaluation System format, under which factor levels and accompanying point values are assigned for each of the nine factors.  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 to a lower level unless the deficiency is balanced by an equally important aspect that meets a higher level.  The total points assigned are converted to a grade level by use of a grade conversion table in the JFS.

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 1-7, positions require detailed, intensive knowledge of the policies, precedents, goals, objectives, regulations, and guidelines of a functional area such as financial oversight, budget formulation, and/or budget execution sufficient to analyze and evaluate continual changes in program plans and funding and their effect on financial and budget program milestones.  Positions at this level require such knowledge to analyze financial and budgetary relationships to develop recommendations for financial and/or budgetary actions under these types of conditions and time pressures:  uncertainty due to short and rapidly changing program and financial/budgetary deadlines and objectives; gaps and conflicts in program and financial/budgetary information; lack of predictive data; conflicting program and financial/budgetary objectives; and changing guidelines for the work.

At Level 1-8, positions require mastery of the concepts, principles, practices, laws, and regulations of budgeting and/or financing; and the financial and budgetary relationships between subordinate and most senior levels of financial management and budgeting within the employing entity and/or between the organization and programs of other Federal, State, and local governments, private industry, and large public organizations sufficient to:  analyze national level programs, exceptionally large and complex programs (e.g., multi-million dollar research grants, contracts, and/or cooperative acquisition agreements); develop, recommend, and implement budgetary and financial policies; interpret and assess the impact of new and revised Congressional legislation on the formulation and execution of budgets; project and analyze the potential effects of budgetary actions on program viability and attainment of program objectives; develop and render authoritative interpretations of executive orders, Office of Management and Budget guidelines and directives, and policies and precedents within and across agency lines; develop new methods and techniques of budgeting for the forecasting of long-range funding needs (e.g., 3 to 5 years or more into the future); and/or develop timetables for obtaining needed funding for new or modified substantive government programs.

The appellant’s position meets Level 1-7.  Her work includes performing EPG’s budget planning, execution, and reporting; management analysis; and manpower activities.  As at Level 1-7, her position requires detailed, intensive knowledge of policies, precedents, goals, objectives, regulations, and guidelines sufficient to analyze and evaluate continual changes in program plans and funding and their effect on financial and budget program milestones.  Similar to this level, she applies detailed, intensive knowledge to develop recommendations for financial and/or budgetary actions.  For example, when an inspection of the Directorate from Command headquarters revealed errors with travel-related vouchers and authorizations, the appellant was responsible for drafting and implementing the remediation plan establishing a quarterly preliminary audit to be performed by another directorate of the EPG.  Her position is responsible for developing EPG’s travel and other resource management policies, which are reviewed and approved by the EPG Commander and/or Technical Director prior to its distribution.  She also deals with changing program financial deadlines and objectives, lack of predictive data, and other conditions and time pressures described at Level 1-7.  When EPG requires repairing or acquiring equipment in the event an instrument breaks or newer technology is available, the appellant makes recommendations to obtain funding for unbudgeted requests.

The appellant’s position does not meet Level 1-8.  The EPG’s annual budget includes reimbursable funds and direct Department of Defense (Defense) funding sources from Research, Development, Test and Evaluation institutional funding; Operation and Maintenance; and Other Procurement Army Budget.  The Directorate is managed and operated locally, and the appellant carries out operational responsibilities such as consolidating budgetary submissions, providing oversight and advisory services to management, and recommending budgetary and financial management changes for the EPG.  Her work does not require mastery of financial concepts, principles, practices, laws, and regulations to analyze the national level programs or exceptionally large and complex programs described at Level 1-8.  Also unlike this level, the development and promulgation of agency policy is neither within the realm of the appellant’s authority nor is it within the scope of EPG’s mission.  Annually, the EPG develops the Program Objective Memorandum (POM), which identifies programmed needs for five years based on current and future projects.  EPG’s directors and management officials provide information required for POM submissions by considering current and projected mission workload, manpower requirements, and funding levels.  In addition to consolidating budget submissions, the appellant’s work includes providing oversight and advisory functions for the EPG’s POM work to ensure adherence to budget criteria, policy, and reporting requirements.  She responds to technical questions regarding EPG’s POM submissions from resource staff at Command headquarters.  Unlike Level 1-8, this and other work do not require developing new methods and techniques for the forecasting of long-range funding needs.

The JFS provides an illustration at Level 1-8 of GS-501 work requiring mastery of the concepts, principles, laws, and regulations of budgeting and/or financing sufficient to manage or analyze national-level mission-related programs and perform such duties (or the equivalent) as providing staff direction and guidance in designing and implementing the agency’s business and financial management information systems.  The systems involve multiple facilities and services, and include the finance, accounting, budget, cost analysis, and management functions.  The illustrated position also provides authoritative policy interpretations on functional systems design issues; identifies operating policies and procedures to be developed or revised; and advises senior agency executives on the direction and allocation of resources for operation and administration of the agency business/resource management systems.  The appellant is an operating-level resource manager and does not serve as an agency-level technical authority required to develop justification for agency financial policy or provide senior-level agency coordination of financial issues as described by the Level 1-8 illustration.

Level 1-7 is credited for 1,250 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.

The appellant’s position meets Level 2-4, where the supervisor outlines overall objectives and available resources.  She is experienced at applying concepts and methodologies and is knowledgeable in functional program characteristics and requirements to develop and maintain EPG’s financial management processes and procedures.  Similar to Level 2-4, the appellant is a technical authority responsible for actions such as planning and carrying out the assignment, directing functional specialists, resolving most conflicts that arise, coordinating the work with others as necessary, interpreting policy and regulatory requirements, and providing recommendations for improvements in order to meet program objectives.  She keeps the supervisor informed of progress and of potentially controversial matters that may adversely impact EPG programs from a financial standpoint.  Also like Level 2-4, her supervisor reviews completed work (e.g., status updates, budget reports, and manpower documents) for soundness of overall approach, effectiveness in meeting requirements of expected results, the feasibility of recommendations, and adherence to requirements.

The appellant’s position does not meet Level 2-5, where the supervisor provides administrative and policy direction in terms of broadly defined missions or functions of the organization.  At this level, the employee is responsible for a significant program or function.  The employee defines objectives, interprets policy promulgated by authorities senior to the immediate supervisor, and determines their effect on program needs.  At Level 2-5, the supervisor’s review of the work covers such matters as fulfillment of finance or budget program objectives and the effect of advice, influence, or decisions on the overall program.  The supervisor usually evaluates the employee’s recommendations for new systems, methods, projects, or program emphasis in light of the availability of funds, personnel, equipment capabilities, priorities, and available resources.  Implicit in Level 2-5 is a degree of program management authority not delegated to the appellant’s position.  For example, she does not operate within the parameters of broadly defined missions to independently plan, design, and carry out major program activities.  The appellant serves as the EPG’s technical advisor on resource management-related issues.  Her position does not involve such work as recommending new systems or program emphasis that would lend itself to the administrative direction described at Level 2-5.  In short, Level 2-5 does not merely represent a high degree of technical independence but also a corresponding management role, beyond the authority vested in the appellant’s position, to define the basic content and operation of the program beyond the technical aspects of discrete assignments or groups of assignments.

Level 2-4 is credited for 450 points.

Factor 3, Guidelines

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

The appellant’s position meets Level 3-4, where guidelines and policies are scarce, very general in nature, pertain to routine issues and matters, and are stated in terms of goals rather than approach.  Employees at this level devise new methods and techniques for acquiring information and analyzing data or modifying systems to accept new kinds of data.  Also included at this level is the interpretation and application of voluminous and ambiguous or conflicting guidelines of more than one Federal agency or department which apply to the budgets of assigned programs and organizations, e.g., executing the budget of an organization which provides reimbursable services on a nationwide basis to components and personnel of other agencies.  The appellant’s guidelines consist of broad fiscal guidance such as that provided by DA and Defense Financial Management Regulations, Federal Acquisition Regulation, Generally Accepted Accounting Principles, Generally Accepted Government Auditing Standards, and instructions on the Defense Automated Time, Attendance, and Production System.  Her guidelines are varied and provide an outline of the concepts, methods, and financial goals to be followed but are also characterized as being of limited use and requiring her to develop methods when performing day-to-day work involving, e.g., establishing criteria for reprogramming funds and ensuring compliance with budget criteria, policy, and reporting requirements.  Characteristic of Level 3-4, she interprets and applies voluminous, ambiguous, or conflicting guidelines applying to the budget of EPG which provides reimbursable services involving constantly changing and unpredictable funding streams.

The appellant’s position does not meet Level 3-5, where guidelines consist of broad policy statements, basic legislation, laws, regulations, and agency goals.  Often the guidelines originate from more than one Federal department or agency.  They may require extensive interpretation to effect agency-specific policy statements, regulations, and instructions.  The employee exercises broad latitude to interpret the intent of applicable guides.  Often the employee has peer recognition as a technical authority with responsibility for developing policy, standards, and guidelines for use by others within agencies or within functional areas that cross agency lines.  Unlike the appellant’s position, Level 3-5 describes assignments where the employee is responsible for developing agency-level policies, regulations, and guidelines.

Level 3-4 is credited for 450 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 4-4, work consists of performing a variety of analytical, technical, and administrative work for substantive programs and support activities.  These programs and activities are funded through a number of sources such as appropriations, allotments, reimbursable accounts, and transfers of funds between organizations.  Programs and funding are unstable and subject to change throughout the fiscal year.  The employee identifies and analyzes changes in budgetary and/or financial policies, regulations, constraints, objectives, and available funds that affect the accomplishment of program objectives.  The employee conducts research, identifies, and analyzes trends in the use of funds, and recommends adjustments in program spending that require the rescheduling of program workloads.  At Level 4-4, the employee must choose the analytical technique appropriate for the task.  Unpredictable short-term deadlines that vary according to financial/budgetary objectives, available funding, program goals, and workload make it difficult for the employee to, e.g., recommend program spending adjustments that require rescheduling of program workloads.

At Level 4-5, work consists of selecting and using many different and unrelated analytical techniques and methods relative to substantive agency programs with widely varying needs, goals, objectives, work processes, and timetables.  Employees at this level recommend changes in funding and budget plans that if accepted may require management to revise substantive programs; develop proposals concerning alternative methods, sources, and timing of financing for substantive programs; and evaluate the mutual effects and interrelationships between program goals and accomplishments and budgetary resources and policies.  At Level 4-5, the employee encounters difficulty in formulating, presenting, and/or defending budget requests.  The employee must devise and apply innovative criteria to evaluate the progress and cost effectiveness of program plans, goals, and objectives.  The employee encounters and resolves issues in work environments characterized by conditions such as continually changing program objectives, plans, and funding requirements resulting from new legislation, revised policies, and shifting demand for goods and services.

The appellant’s position meets Level 4-4.  As at this level, she performs a variety of analytical, technical, and administrative work for the substantive programs and support activities of the EPG.  Her work includes evaluating the status of program budgets; monitoring financial policies and practices; recommending the distribution and reprogramming of financial resources as necessary; identifying trends, accomplishments, deficiencies, and imbalances with the programs; and resolving force structure, resource utilization, waste and fraud prevention, cost reporting, and other resource management issues.  Her work, critical to ensuring EPG’s financial management processes and procedures conform to applicable laws and regulations, involves identifying and analyzing changes to financial policies, regulations, constraints, objectives, and available funds affecting the accomplishment of program objectives as expected at Level 4-4.  The appellant evaluates resource needs requiring continual adjustments as a result of new test missions acquired, high technology cost growth, development of new testing hardware, and other unforeseen circumstances.  As at Level 4-4, this dynamic program environment makes it difficult for the appellant to recommend program spending adjustments, identify trends in the use of funds, and assist management in interpreting the impact of, and planning for, multi-year financial/budgetary and program changes.

The appellant’s position does not meet Level 4-5.  Unlike this level, her position does not require devising and applying innovative criteria to evaluate the progress and cost effectiveness of program plans, goals, and objectives.  She also does not encounter and resolve issues in work environments characterized by continually changing program objectives, plans, and funding requirements from new legislation or other conditions described at this level.  An illustration at Level 4-5 of a GS-501 position describes work interpreting laws and regulations pertaining to the expenditures of Social Security Trust funds.  Work involves preparing agency-wide policies and procedures on administrative payments and collections, certifying officers, cashiers, and designated agents; commenting on Government Accountability Office, Office of Management and Budget, and Department of the Treasury proposals; conducting research on new methods and techniques; and preparing findings and interpretations in lay terms for personnel at all levels of management and in technical terms for personnel in operating units.  The specific budget, manpower, and other resource-related issues the appellant encounters in the operating environment of the EPG are not so broad as to require devising and applying innovative criteria as expected at Level 4-5.

Level 4-4 is credited for 225 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.

The appellant’s position meets Level 5-4, where work involves executing modifications to systems, programs, and/or operations, and/or establishes criteria and other means to assess, investigate, or analyze a variety of unusual problems and conditions.  Similar to Level 5-4, the appellant’s work involves developing and maintaining EPG’s financial management processes and procedures, advising managers on operations impacting financial conditions, and coordinating the resolution of problems and conditions from the conventional to the unusual.  Her work involves activities of private sector entities with which the EPG provides test services, and affects the reliability and timeliness of financial data, efficient use of funds, and ultimately the availability of funds for EPG programs and services.  Her position is comparable to the illustration at Level 5-4 of a GS-501 position monitoring appropriated and non-appropriated fund resources and activities at the installation level, and managing the financial management information system that supports accounting, budgeting, procurement, disbursing, and statistical reporting.  Like the illustration at Level 5-4, the appellant’s position affects the financial success and viability of installation-level programs.

The appellant’s position does not meet Level 5-5, where work involves isolating and defining unknown conditions, resolving critical problems, and developing new theories.  Examples of the scope of financial administration and program work at Level 5-5 include coordinating information outputs from financial management systems that support management of programs funded by a number of appropriations, and assessing the impact of proposed systems features on major systems development or modification efforts.  Unlike the appellant’s position, the effect of work at Level 5-5 may impact areas such as major aspects of programs or missions; the well-being of substantial numbers of people; the comprehensive application of accounting principles, concepts, and techniques to developing or managing complex accounting systems; and the establishment of a definitive framework for applying audit theories, concepts, and techniques.  The JFS provides an illustration of GS-501 work at Level 5-5 providing technical expertise to management on budgeting and cost estimating in conjunction with a large multi-year, multi-billion dollar acquisition program, and reviewing and advising on financial management issues that are characterized by diverse and innovative approaches and coordinated and uncoordinated efforts by numerous subordinate organizations.  The Level 5-5 illustration also describes the advice of the position affecting the agency’s ability to obtain project funding, and the availability of this funding affecting the agency’s capability to carry out programs of national significance.  In contrast to the Level 5-5 illustration, the appellant is the resource manager within the operating environment of the EPG and, as such, her position neither requires her to perform work involving coordination with numerous subordinate organizations nor affects the agency’s ability to carry out programs of national significance.

Level 5-4 is credited for 225 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

The appellant’s contacts meet Level 3.  Contacts at this level are with executives, officials, managers, and/or professionals including corporation officials, and employees of other agencies and outside organizations and businesses.  Contacts are not routine or recurring and require recognizing or learning the role and authority of each party during the course of the contact.  Similar to examples provided in the JFS at Level 3, the appellant’s contacts are with representatives of contractors, other Federal agencies, and higher levels of agency management.  Specifically, her personal contacts are with directors, division chiefs, project managers, and other high-level officials at EPG; test customers of the EPG (Defense and non- Defense); counterparts at the Command’s other test centers; resource management officials at Command headquarters, DA, Defense Finance and Accounting Service, and other Defense organizations; and private industry officials.

Unlike Level 4, the appellant does not have recurring face-to-face, telephone, or email contact with high-ranking officials from outside the employing department or agency at national or international levels in highly unstructured settings.  In contrast to examples at Level 4, she does not have recurring contact with Congressional appropriations committee members; Presidential advisors and cabinet level appointees of major departments and agencies; State governors, mayors of large cities, presidents of large national or international firms; presidents of national unions; and/or occasional contact with nationally recognized representatives of the news media on financial matters of national significance.

            Purpose of Contacts

At Level c, the purpose of contacts is to influence, motivate, interrogate, or control persons or groups where there is wide disagreement on the merits of a proposed action, or when persons contacted are fearful or uncooperative.  Examples provided in the JFS at Level c include  persuading program managers and other officials in positions of decision-making authority with widely differing goals and interests to follow a recommended course of action consistent with established budget/financial management policies, objectives, or regulations.  Another example includes influencing or persuading others to the employee’s point of view regarding the merits of a technical budget/resource management method, concept, or procedure when others hold strongly opposed points of view.  Similarly, the purpose of the appellant’s contacts is to influence, persuade, and control persons where opposing opinions on a proposed action exist, e.g., when dealing with higher-level managers and others to resolve disagreements related to funding availability.  Her contacts involve identifying financial management issues requiring adjustment and/or correction to ensure orderly and timely budget execution, briefing higher-level managers on analyses of findings, and persuading them to follow recommended or corrective courses of action.  The purpose of the appellant’s contacts meets Level c.

Unlike Level d, the purpose of the appellant’s contacts does not require presenting, justifying, defending, negotiating, or settling matters involving significant or controversial issues nor does it generally involve topics of long-range issues or problems.  Also in contrast to this level, the situations do not require she work with the contacts to achieve a common understanding of the problem.  The purpose of the appellant’s contacts do not involve defending alternative methods of financing substantive program operations or the redistribution of appropriated funds and programs among components immediately below agency or equivalent level; negotiating and resolving controversial financial and program issues of considerable significance that are not susceptible to resolution at lower echelons in Government; justifying proposed changes to achieve major economies; or other situations equivalent to the examples provided by the JFS at Level d.

Level 3c is credited for 180 points.

Factor 8, Physical Demands

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

Similar to Level 8-1, the appellant’s work is primarily sedentary and does not involve any special physical effort.  Some work may require periods of walking, bending, or carrying of light items.

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.

Similar to Level 9-1, the appellant’s work environment consists of an adequately lighted, heated, and ventilated area.  Her work involves the everyday risks or discomforts of an office or automobile setting and requires normal safety precautions.

Level 9-1 is credited for 5 points.

Summary
Factors	Level	Points
1. Knowledge Required by thePposition	1-7	1250
2. Supervisory Controls	2-4	450
3. Guidelines	3-4	450
4. Complexity	4-4	225
5. Scope and Effect	5-4	225
6. & 7. Personal contacts and Purpose of contacts	3c	180
8. Physical Demands	8-1	5
9. Work Environment	9-1	5
Total		2790

 

The total of 2,790 points falls within the GS-12 range (2,755 to 3,150) on the grade conversion table provided in the JFS.

Summary

The appellant’s supervisory work is evaluated at the GS-13 level while her personally performed work is evaluated at the GS-12 level.  The final grade of her position is GS-13, based on application of the mixed grade position criteria stated in established OPM guidance for classifying positions, e.g., chapter 5 of The Classifier’s Handbook.

Decision

The appellant’s position is properly classified as GS-501-13.  The title is to be determined by the agency with a “Supervisory” prefix.

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