Washington, DC

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

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Robert D. Hendler
Classification and Pay Claims
Program Manager
Agency Compliance and Evaluation
Merit System Accountability and Compliance


05/18/2016

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Date

As provided in section 511.612 of title 5, Code of Federal Regulations, this decision constitutes a certificate that is mandatory and binding on all administrative, certifying, payroll, disbursing, and accounting officials of the Government.  The agency is responsible for reviewing its classification decisions for identical, similar, or related positions to ensure consistency with this decision.  There is no right of further appeal.  This decision is subject to discretionary review only under conditions and time limits specified in the Introduction to the Position Classification Standards (Introduction), appendix 4, section G (address provided in appendix 4, section H).

Since this decision lowers the grade of the appealed position, it is to be effective no later than the beginning of the sixth pay period after the date of this decision, as permitted by 5 CFR 511.702.  The applicable provisions of parts 351, 432, 536, and 752 of title 5, Code of Federal Regulations, must be followed in implementing this decision.  If the appellant is entitled to grade retention, the two-year retention period begins on the date this decision is implemented.  The servicing human resources office must submit a compliance report containing the corrected position description 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 OPM office which accepted the appeal. 

Introduction

The U.S. Office of Personnel Management’s (OPM) Merit System Accountability and Compliance accepted this position classification appeal on September 17, 2014.  The appellant occupies the position of Grants Management Specialist, GS-1109-13, in the Headquarters Grants Administration Office (HGAO), Institutional Support Office, Management Operations Directorate, at Goddard Space Flight Center (GSFC) in Greenbelt, Maryland.  She requests reclassification of her position as GS-301-14.  We received the agency administrative report on November 12, 2014.   We accepted and decided this appeal under the provisions of section 5112 of title 5, United States Code.

Background

The HGAO was established and staffed in 1997.  The appellant’s position at that time was classified as Resource Analyst, GS-501-11, with full performance level GS-12, to which the appellant was promoted in August 2000.  In 2004, the appellant submitted a revised position description (PD) to her servicing human resources office and requested a desk audit and position review.  As a result, her position was reclassified as Grants Resources Specialist, GS-301-13.  The appellant submitted another revised PD in 2014 in connection with a requested upgrading of her position to GS-14.  The upgrade was denied and her position reclassified as Grants Management Specialist, GS-1109-13.  Throughout this sequence of events, the appellant reported and her supervisor confirmed that her duties had not changed, but that the electronic PD system had limited their ability to accurately represent the actual duties performed.

General issues

The appellant raises concerns about her agency’s classification review process.  By law, we must make our 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).  In adjudicating this appeal, our responsibility is to make our own independent decision on the proper classification of the position.  Because our decision sets aside all previous agency decisions, the agency’s classification review process is not germane to this decision.

The appellant reported she acts for her supervisor in that person's absence.  However, such "acting" duties do not normally affect the grade of a position.  First, "acting" in another employee's absence does not normally convey the full breadth of authority or range of responsibilities associated with the position and upon which its grade is based.  Second, only duties that occupy at least 25 percent of an employee's time can affect the grade of a position (Introduction, section III.J).  Occasional "acting" duties, such as when the supervisor is on leave or travel, do not meet this threshold.  Further, the previously cited section of the Introduction stipulates that “[w]ork which is temporary or short term, carried out only in the absence of another employee… cannot be considered paramount for grade level purposes.”

Position information

NASA headquarters awards two-year research and development grants for about 60 projects totaling approximately $600 million in appropriated funds and an additional $1.5 million in reimbursable funds from other Federal agencies, representing about 80 percent of all NASA grant awards.  The funds are awarded to universities and other qualifying scientific organizations throughout the United States via over 2,500 grant actions per year (i.e., new awards, multi-year funding continuations, augmentations, etc.).  The HGAO serves as an intermediary between the NASA headquarters science and engineering program offices which develop and submit grant actions (also called technical requirements proposal or TRP) and the NASA Shared Services Center (NSSC) which awards and administers the grants.    

NSSC performs all pre-award and post-award actions for both competitive and noncompetitive grants; awards funding and administrative supplements; processes Principal Investigator (PI) transfers; processes cancellations; approves foreign travel, equipment purchases, and re-budgeting requests; and monitors zero costing and suspicious drawdowns.  The HGAO role is to review TRPs and other requested grant actions submitted by the Technical Officers (TOs) at NASA headquarters and requiring movement of funds (such as augmentations, de-obligations, or PI transfers) for completeness of documentation prior to their submission to NSSC in order that the actions may be processed without undue delays, and generating the associated procurement requests (PRs) which are the vehicles for requesting any grants action by NSSC.  The HGAO also provides continuous coordination of grant funding between NASA headquarters and GSFC by ensuring that any proposed funding has been transferred from the RAPTOR grant resource tracking system to the SAP core financial system by the TOs before grants action is taken, and provides continuous status information to the program offices on the expenditure and availability of grant funds.

The daily processing of grant transactions in the HGAO is carried out by four lower-graded employees who are responsible for reviewing the TRPs for their assigned grant projects to ensure that the grant documentation is sufficient and appropriate for the requested action and the existing grant status (e.g., multi-year funding, augmentation, etc.) and to ensure regulatory compliance with the NASA Grant and Cooperative Agreement Handbook, Federal Acquisition Regulations (FAR), and the NASA FAR Supplement; ensuring that budget elements are appropriate relative to "allowable costs"; flagging potential problem areas in the TRPs and obtaining missing or corrected information from NASA personnel and/or the grantee institutions; and preparing PRs in SAP to forward the TRPs to NSSC for action.  The purpose of these activities is to ensure that the TRPs are complete, contain accurate cost information, and meet regulatory requirements so that the subsequent procurement process carried out at NSSC flows smoothly and TRPs are not returned to the program offices by NSSC because of insufficient documentation or other problems.  These four employees also monitor the status of funds for their assigned blocks of grant projects through the use of RAPTOR, SAP, and other financial and business systems by reviewing financial reports and resolving discrepancies with NASA personnel; ensure that expenditures are consistent with funding information in RAPTOR; perform reconciliation of funding for their assigned grant projects at the task level; and conduct year-end closing activities. The purpose of these activities is to ensure that the program offices have access to accurate and up-to-date records on grant expenditures and available funds. 

Within this context, the appellant has two major areas of responsibility related to the work described above.  First, the appellant continually monitors and reviews the funding status of headquarters-issued grants at the project level to identify and reconcile variances between the funding allocations indicated in RAPTOR and the funding levels committed in SAP and to ensure that HGAO allocations are used on HGAO projects only, and resolves these discrepancies by, for example, working with the headquarters TOs or other staff to correct RAPTOR or with NSSC to de-commit funding that has not been obligated.  She coordinates the receipt of required documentation for the processing of requests for reimbursable funds from other Federal agencies by obtaining budget information from the participating agency, inputs required data into the SAAM (Space Act Agreement Maker) system, and submits the request for internal clearance and approval.  This includes calculating administrative fees, ensuring appropriate approval signatures, synopsizing the statement of work, and providing the WBS (work breakdown structure) element that will be used to fund the award.  The appellant also performs a variety of other related duties on an ad hoc basis as requested by NASA program staff such as identifying available funding in specific projects that can be reprogrammed for emergency use.  However, the appellant reported that the daily reconciliation work occupies the majority of her time.  

Secondarily, the appellant reviews and signs off on all TRPs for regulatory compliance, providing a second level of review prior to their forwarding to NSSC, and assists the lower-graded employees in resolving any issues identified relative to the grant actions requested.  The appellant provided the following work samples of the types of issues she resolves: there was no existing grant related to a proposed research project and the appellant advised that it be submitted as an unsolicited contract; a TRP was submitted to fund a scientific conference but the dates indicated the conference had already occurred; the PI identified in a TRP was a GSFC employee; the budget totals across the funding years exceeded 20 percent of the approved amounts, thus requiring submission of revised budgets; the proposed budget in a TRP included foreign travel estimates for a conference but no itinerary was provided; the proposed budget in a TRP included indirect cost rates but a current signed rate agreement was not attached; and a TRP included a cost reimbursement to a subcontract PI at a different university than the one to which the grant was to be awarded but the proposal page was missing and there were questions about the amount requested.

The appellant does not dispute the accuracy of her PD except to assert that the “language in the factors does not adequately capture the scope of the competencies that are required to perform the duties of [her] position,” and her supervisor certified its accuracy.  The appellant states the PD was developed “using the new system (ePDS),” which contains standardized language that can be modified to fit a particular position.  Although the PD appears to contain the basic elements of the position, these are subsumed within the extensive standardized verbiage that materially misrepresents both the nature of the work she performs and the level of authority she is delegated.  Further, the factor level descriptions consist of general language associated with the assigned factor levels, but do not have an identifiable relationship to the work she actually performs and appear to have been selected solely to support the desired factor level assignments.   

An employee's PD is expected to meet certain minimum standards of adequacy and accuracy in depicting the duties being performed in that it serves as the basis for determining the employee's pay and other associated benefits based on that pay.  The appellant’s PD does not meet these minimum standards of adequacy and accuracy and should be revised to describe the actual work she is performing, to more realistically depict the factor level characteristics associated with her work, and to provide an accurate documentation and clear understanding of the duties and responsibilities representing the approved classification.  Briefly, the following incongruities are noted between the appellant’s PD and the actual work performed:

• Factor 1 - The appellant’s position does not require the types of comprehensive grants management knowledges described because, as discussed later in this decision, the HGAO does not perform grants administration functions associated with such knowledge requirements, which reside at NSSC, but rather a grants support function.  The HGAO reviews the documentation being submitted to NSSC to initiate the award of a proposed grant or the modification of an existing grant, and only for the limited purposes of ensuring complete documentation and screening for any issues that may delay processing by NSSC.  Neither the HGAO nor the appellant are tasked with responsibility for evaluating NASA’s "grants program accomplishments" or translating "basic legislation into organizational program goals, actions, and services."  The appellant does not recommend "extensive changes to established grant procedures which may be in conflict with the desires of the overall grants program," nor does she serve as a "recognized agency expert" in grants management given the limited support nature of the HGAO.  There is virtually no element of this factor level in the appellant's PD that is representative of her actual duties. 
• Factor 2 - The appellant does not work under administrative direction with assignments in terms of “broad missions or functions,” nor is she responsible for independently planning, designing, and carrying out programs, projects, or studies.   She carries out well-defined and continuing assignments within an established program support function under normal technical supervision.  (Specifically, the appellant submitted work samples including copies of email exchanges clearly showing her supervisor’s involvement in technical matters encountered by the appellant, which is inconsistent with solely administrative supervision.) Further, her work is not considered technically authoritative within the context that term is used; i.e., in recommending new projects and alterations of objectives or in contributing to the advancement of technology.  We note that the language used under this factor is common to Level 2-5 across various occupational series and that this level is generally reserved for positions with significant program authority.  It would not be applicable to either the appellant’s position or to the type of support functions carried out by the HGAO. 
• Factor 3 - The appellant does not use NASA grants program guides that are “not specific and require interpretation”; rather, she applies recurring provisions and requirements of such guides, and situations that are unclear are referred to other offices, such as NASA legal counsel or the procurement office.  Further, she is not recognized as a technical authority in the development and interpretation of guidelines as neither the appellant nor the HGAO is responsible for developing grant guidelines. 
•  Factor 4 - The appellant’s work does not consist of “broad functions and processes of the grants management field” with the attendant complexity, as responsibility for carrying out “broad” grant management functions is vested at NSSC.  Her work  does not require "extensive research and analysis" of "largely undefined issues" or the establishment of "theories or programs."  Again, the HGAO is not responsible for these functions.
• Factor 5 - The appellant does not evaluate major administrative aspects of the NASA grants program, develop long-range program plans, evaluate the effectiveness of grants programs conducted throughout NASA,  develop administrative regulations or guidelines, or produce study reports of interest to senior NASA managers.  Further, the HGAO does not perform these functions.
• Factor 6 - Although the appellant has the types of external contacts described, they do not normally pose the types of problems depicted.
• Factor 7 - The appellant does not justify, defend, negotiate or settle complex or controversial issues regarding NASA grants management.  Again, the HGAO does not perform grants management, it performs a limited support function ensuring that the documentation to initiate the award or modification of grants is complete and that the financial records are accurate and current.  The work samples submitted by the appellant make clear that any complex or controversial issues encountered are settled by the program officials at NASA headquarters with ultimate responsibility for the individual grants. 

In adjudicating a classification appeal, we determine the proper classification of the appellant’s position; i.e., the duties assigned by management and performed by the appellant, not the appellant’s PD.  Although it is expected that the duties assigned and performed will be accurately depicted in the appellant’s PD, we do not classify the position by relying on language in the PD which is not representative of the actual work performed.  To help decide this appeal, we conducted a telephone audit with the appellant on March 26, 2015, and April 14, 2015, and with her supervisor on June 17, 2015.  This decision is based on our assessment of the appellant’s duties and responsibilities as determined through our factfinding, including the telephone audit and interview with the supervisor, review of work samples furnished by the appellant, and other material received in the agency administrative report. 

Series determination

The current allocation of the appellant's position to the GS-1109 Grants Management Series is incorrect.  The GS-1109 series covers positions which manage, supervise, lead, or perform administrative, business, policy, and analytical work involving: (1) the management, award, and/or obligation of funds for grants, cooperative agreements, and other related instruments and services such as discretionary and mandatory grants, using financial, administrative, business, and negotiation procedures; (2) the competitive or non-competitive evaluation of grant proposals; and/or (3) the administration or termination, and/or closeout of grants and/or grants assistance and agreement awards.  To expand upon this series definition, the GS-1109 series flysheet provides a list of typical duties that include a range of functions related to awarding and administering grants.  Duties associated with awarding grants include such functions as announcing grant opportunities and soliciting applications or proposals; determining awardee eligibility; reviewing and evaluating grant applications, plans, and estimates; and negotiating terms and conditions of grant awards including costs, schedules, and oversight responsibilities.  Duties associated with administering grants include such functions as processing, issuing, and tracking grant awards; establishing performance measures; monitoring and assessing awardee performance and compliance with the terms and conditions of the award; conducting risk assessments and business reviews; serving as liaison between the Government and the awardee organizations; and performing final review of completed awards, making appropriate adjustments or disallowances, and processing close-outs.  Work in the GS-1109 series requires knowledge of:

• laws, regulations, rules, policies, procedures, and methods governing the administration of Federal grants, cooperative agreements, and awards;
• grants management processes and techniques consistent with sound business and industry practices; and
• financial methods, procedures, and practices to assess the financial stability of recipients of Federal grants.

Responsibility for the grants management functions described above resides at NSSC.  The appellant's role as it relates to the awarding of grants is limited to reviewing TRPs for completeness of documentation and resolution of identified problems prior to their submission to NSSC in order that the above actions may be taken without undue delays.  Her role as it relates to grant funding is limited to resolving discrepancies in financial records as opposed to awarding and obligating funds, as the HGAO does not have this authority.  The work requires primarily knowledge of the documentation needed for a complete grant package that can be processed by NSSC and some limited knowledge of regulatory requirements pertaining to the awarding of grants sufficient to flag potential problems.  However, these knowledge requirements do not approach those associated with the GS-1109 series.      

The appellant requests classification of her position to the GS-301 Miscellaneous Administration and Program Series.  This series includes positions the duties of which are to perform, supervise, or manage nonprofessional, two-grade interval work for which no other series is appropriate, and which requires analytical ability, judgment, discretion, and knowledge of a substantial body of administrative or program principles, concepts, policies, and objectives.  The GS-301 flysheet instructs that if the basic subject matter knowledges and skills for a position are covered by other specific series, then the position should be assigned to that series rather than the GS-301 series.  It also instructs that mixed positions; i.e., positions that involve work classifiable in more than one series, should be classified to the series that represents the paramount qualifications required.  In the appellant's case, her work is directly associated with two one-grade interval occupational series as discussed further below, and as such the GS-301 series is not appropriate.

Guidance on determining whether work is one- or two-grade interval in nature is contained in The Classifier’s Handbook.  Support work 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.  Employees who perform support work follow established methods and procedures.  They may occasionally develop work plans or recommend new procedures, but these typically are related to the employee’s individual assignment or immediate work unit.  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 be many years of experience.  Administrative work, on the other hand, requires primarily 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 orally and in writing.  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.

Within this context, the appellant’s duties represent one-grade interval support work rather than two-grade interval administrative work.  Her work requires proficiency in and is specifically identified with certain limited phases of the NASA grants administration function and is transactional in nature; i.e., it is not based on a body of broad functional knowledge associated with an administrative field, such as the grants management functions covered by the GS-1109 series, but rather focuses on the review and processing of documents so that the substantive functions associated with the awarding and administration of grants can be carried out by others.  Although the appellant may provide input to procedural changes in the NASA Grant Handbook and NRA Proposers Guidebook as these specifically relate to the work of the HGAO, she otherwise follows established methods and procedures; i.e., her work is clearly defined in terms of the processes to be carried out.  She performs her work based on a practical knowledge of NASA grant documentation requirements and readily identifiable disallowed conditions as acquired through extensive on-the-job exposure.  She does not, however, perform work requiring a high order of analytical ability and a comprehensive knowledge of management processes and functions.  For example, the appellant provides information requested by program officials relative to the status and funding of specific grants by researching the grant history in various electronic financial and business systems or by drawing on her own recollection of actions that transpired.  However, obtaining information by pulling data or reports from an automated system does not involve the exercise of a "high order of analytical ability," and reporting a sequence of events does not require "comprehensive knowledge of management processes."  As another example, the appellant identifies issues in TRPs that are potentially disallowable.  However, the work samples submitted show that any problems extending beyond missing documentation, conflicting information, or recurring issues and which would potentially require a “high order of analytical ability” are handled by the TOs, NASA legal counsel, or the procurement office.   

The appellant describes her work involving the review of TRPs prior to their submission to NSSC as "procurement" duties.  However, this is an inaccurate characterization.  The appellant does not carry out the "procurement" process as it relates to the solicitation and awarding of grants, which work is carried out at NSSC.  Rather, her work supports the grant management functions carried out at NSSC by ensuring the submission of complete and supportable documentation for processing; i.e., she prepares and/or reviews procurement requests for the actual procurement to be carried out by others.  As such, her work is most closely associated with the GS-1106 Procurement Clerical and Assistance Series, which includes positions that involve performing or supervising clerical or technical work that supports the procurement of supplies, services, and/or construction and includes such work as preparing, controlling, and reviewing procurement documents such as purchase requests, amendments, waivers, and other preaward documents, and researching errors or conflicting information in procurement documentation.  This accurately depicts the appellant’s position in that she reviews “procurement documents” (i.e., TRPs, analogous to purchase requests, amendments, and other “preaward documents”) to identify “errors or conflicting information in procurement documentation.”

The appellant's work involving the reconciliation of  funding discrepancies is likewise one-grade interval in nature and is most closely associated with the GS-503 Financial Clerical and Technician Series, which includes positions that involve performing or supervising clerical or technical work in support of financial management functions and specifically covers work involved in reconciling accounts. 

There is no basis for classifying the position to one of the two-grade interval series in the GS-500 Accounting and Budget Occupational Group, such as the GS-501 Financial Administration and Program Series.  Positions in this series perform work of a fiscal, financial management, accounting, or budgetary nature that is not classifiable to another more specific professional or administrative series in the GS-500 group (such as GS-510 Accounting, GS-511 Auditing, or GS-560 Budget Analysis).  Examples of GS-501 positions provided in the corresponding Job Family Standard (JFS) include such work as developing new or revised automated financial management systems, or conducting financial oversight by monitoring financial transactions to ensure the cost effective use of funds (e.g., by identifying potential reimbursable costs or early payment discounts).   By contrast, the appellant's reconciliation work does not involve two-grade interval financial oversight in the sense of, for example, identifying ways that cost savings could be achieved, but rather the more mechanical function of searching through financial records to identify unobligated funds or the source of funding discrepancies, which work is directly described within the context of the GS-503 series.

The appellant reported that the above-described reconciliation and related duties occupy the majority of her time and therefore, her position is properly classified to the GS-503 series.

Title determination

Titles are not specified for positions classified to the GS-503 series.  Therefore, the agency may construct a title for the appellant's position following guidance provided in the Introduction.

Grade determination

Evaluation using the GS-500 Job Family Standard (JFS) for Clerical and Technical Accounting and Budget Work

The appellant’s work involving the reconciliation of funding discrepancies and other related work is evaluated using the GS-500 JFS for Clerical and Technical Accounting and Budget Work.  The GS-500 JFS is written in the Factor Evaluation System (FES) format, under which factor levels and accompanying point values are to be assigned for each of the following nine factors, with the total then being converted to a grade level by use of the grade conversion table provided in the JFS.  The factor point values mark the lower end of the ranges for the indicated factor levels.  For a position to warrant a given point value, it must be fully equivalent to the overall intent of the selected factor level description.  If the position fails in any significant aspect to meet a particular factor level description, the point value for the next lower factor level must be assigned, unless the deficiency is balanced by an equally important aspect that meets a higher level.

When an individual FES factor falls either below the lowest or above the highest factor level described in the applicable FES standard, the Primary Standard may be referenced to evaluate that factor.  The Primary Standard serves as the basis for all occupational FES standards and is used to maintain alignment across occupations.

Factor 1, Knowledge required by the position

This factor measures the nature and extent of information an employee must understand in order to do the work, and the skills needed to apply that knowledge.

The knowledge required by the appellant’s position matches Level 1-5 (the highest level described under this factor).  At this level, the work requires a broad, in-depth practical knowledge of accounting or other financial management technical methods, techniques, precedent cases, and procedures to resolve especially difficult or sensitive problems.  At this level, employees typically use:

Knowledge of the accounting methods, procedures, and techniques to conduct difficult and responsible analysis and determinations within a complete accounting system to validate transactions and to perform research to resolve inconsistencies;

Knowledge of the interrelationships of various accounting system applications and computer file systems and content to resolve problems of processed transactions.  These modifications relate to obligations, collections, disbursements, and interfund transactions or other actions involving complicated adjustments such as carry back and carry forward and restricted interest cases; and/or

Knowledge of related financial regulations and rulings covering diverse types of transactions to typically function as a technical authority for the resolution of an extensive range of issues or problems.

The appellant's position fully meets but does not exceed this level in that her work requires broad knowledge of the agency’s various financial systems to research variances in grant funding at the project level and resolve problems of processed transactions (e.g., funding was erroneously applied to a contract rather than the intended grant).  As at this level, the appellant functions as a technical authority for the resolution of transactional funding discrepancies associated with the grant projects. 

Level 1-5 is credited (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 responsibility, and the review of completed work.

The supervision under which the appellant operates is consistent with Level 2-3 (the highest level described under this factor).  At this level, the supervisor assigns work with standing instructions on objectives, priorities, and deadlines and provides guidance for unusually involved situations.  The employee independently processes the most difficult procedural and technical tasks or actions and handles problems and deviations in accordance with instructions, policies, previous training, or accepted practices.  The supervisor evaluates completed work for overall technical soundness and conformance to agency policies, legal, or system requirements.  Completed work is reviewed by sampling in a quality review system and/or spot checked for results and conformity to established requirements and deadlines.  The methods used to complete the assignment are seldom reviewed in detail.

The appellant's position fully meets this level in terms of the extent of controls exercised by the supervisor and the employee's responsibility, in that the appellant works within the parameters of established procedures and independently resolves the most difficult reconciliation problems, including those referred by lower-graded employees.  However, it somewhat exceeds this level in terms of the review of completed work, which does not extend to sampling or spot checking, as the appellant's supervisor accepts the results of her reconciliations as accurate. 

At Level 2-4 in the Primary Standard, the supervisor sets the overall objectives and resources available.  The employee and supervisor, in consultation, develop the deadlines, projects, and work to be done.  The employee, having developed expertise in the line of work, is responsible for planning and carrying out the assignment, resolving most of the conflicts that arise, coordinating the work with others as necessary, and interpreting policy on own initiative in terms of established objectives.  In some assignments, the employee also determines the approach to be taken and the methodology to be used.  The employee keeps the supervisor informed of progress and potentially controversial matters.  Completed work is reviewed only from an overall standpoint in terms of feasibility, compatibility with other work, or effectiveness in meeting requirements or expected results.

The supervisory controls and review described at Level 2-4 are based on the performance of more difficult and extended assignments and projects that require such elements as planning, determining approach and methodology, and independently interpreting policy.  The employee must keep the supervisor informed of progress and potential controversies because the assignments are longer-term and involve making decisions or taking actions that may have repercussions.  The type of review exercised at this level is that normally associated with work that is analytical or otherwise two-grade interval in nature.  By contrast, the appellant's work is routinized and involves carrying out established processes to identify the source of funding discrepancies.  Her work assignments are short-term and do not involve any significant degree of planning, determining approach or methodology, or interpreting policy, nor would they be expected to create controversies.  Therefore, her work does not lend itself to the type of supervisory controls and review described at Level 2-4.

Level 2-3 is credited (275 points).

Factor 3, Guidelines

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

The guidelines used by the appellant match Level 3-3 (the highest level described under this factor).  At this level, guidelines lack specificity, frequently change, or are not completely applicable to the work.  For example, when completing a transaction, the employee may have to rely on experienced judgment rather than guides to fill in gaps, identify sources of information, and make working assumptions about what transpired.  The employee uses judgment to interpret guidelines, adapt procedures, decide approaches, and resolve specific problems.  This includes, for example, using judgment to reconstruct incomplete files, devise more efficient methods for procedural processing, gather and organize information for inquiries, or resolve problems referred by others (e.g., those that could not be resolved at lower levels).  The employee may suggest specific changes to the guidelines, the development of control mechanisms, additional training for employees, or specific guidance related to the procedural handling of documents and information. 

The appellant's position fully meets but does not exceed this level in that it depicts the experienced judgment she must use in resolving funding variances and other problems referred by lower-graded employees. This level also reflects the appellant’s participation in NASA Grant Steering Committee meetings where she may suggest changes in procedures as they affect the HGAO, but her work does not exceed this level as she is not responsible for the development of these guidelines.  

Level 3-3 is credited (275 points).

Factor 4, Complexity

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

The complexity of the appellant’s work is comparable to Level 4-4 (the highest level described under this factor).  At this level, the work is characterized by (1) the variety and complexity of the examinations, transactions, or systems involved; (2) the nature and variety of the problems encountered and resolved; and (3) the nature of independent decisions made by the employee.  The work involves application of many different and unrelated processes and methods relating to examination or analysis of complex and unusual transactions requiring substantial research and thorough understanding of a wide variety of transactions and accounts.  Decisions regarding what needs to be done include assessing unusual circumstances or conditions, developing variations in approach to fit specific problems, or dealing with incomplete, unreliable, or conflicting data.  The work requires making decisions, devising solutions, and taking actions based on program knowledge.

The appellant's position fully meets but does not exceed this level in that it accurately depicts the substantial research she conducts using multiple financial systems to resolve funding deviations involving grant projects. 

Level 4-4 is credited (225 points).

Factor 5, Scope and effect

This factor covers the relationship between the nature of the work, and the effect of the work products or services both within and outside the organization.

The scope and effect of the appellant’s work meet Level 5-3 (the highest level described under this factor).  At this level, the purpose of the work is to treat a variety of problems in accounting, budget, or financial management transactions.  Issues might result, for example, from insufficient information about the transaction, a need for more efficient processing procedures, or requests to expedite urgently needed cases.  The work affects the quality, quantity, and accuracy of the organization’s records, program operations, and service to clients.  For example, the effect of the work is to ensure the integrity of the overall general ledger; the amount and timely availability of money to pay for services; the economic well-being of employees being serviced; or compliance with legal and regulatory requirements.

The appellant's position fully meets but does not exceed this level in that the specific purpose of her work is to resolve identified problems in financial transactions in order to ensure the overall accuracy of grant funding records in terms of expenditures and available funds.

Level 5-3 is credited (150 points).

Factor 6, Personal contacts

   and

Factor 7, Purpose of contacts

These factors include face-to-face and telephone contacts with persons not in the supervisory chain and the purposes of those contacts.  The relationship between Factors 6 and 7 presumes that the same contacts will be evaluated under both factors.

     Persons contacted

The appellant’s personal contacts match level 2, where contacts are with employees in the same agency but outside the immediate organization, such as with personnel in other functional areas, and/or with members of the general public in a moderately structured setting.  Level 3 is not met, where contacts are with persons outside the agency in their capacity as representatives of others such as attorneys and accountants, contractors, public action groups, or congressional staff members making inquiries on behalf of constituents.  The appellant has occasional minor contacts with grantees to obtain documentation, but her regular and recurring contacts with external parties are more accurately represented at level 2.

     Purpose of contacts

The purpose of the appellant’s contacts is consistent with level b, where contacts are to plan and coordinate actions to correct or prevent errors, delays, or other complications during the transaction cycle; e.g., requesting other personnel to correct errors in documentation or data entry.  Level c is not met, where the purpose of contacts is to persuade individuals who are fearful, skeptical, uncooperative, or threatening to provide information, take corrective action, and accept findings to gain compliance with established laws and regulations.  The appellant's contacts are collegial and do not involve the conflicts described at level c.

Level 2b is credited (75 points).

Summary 

Factors	Level	Points
Knowledge Required	1-5	750
Supervisory Controls	2-3	275
Guidelines	3-3	275
Complexity	4-4	225
Scope and Effect	5-3	150
Personal Contacts and Purpose of Contacts	2b	75
Physical Demands	8-1	5
Work Environment	9-1	5
Total		1760

The total of 1760 points falls within the GS-8 range (1605-1850) on the grade conversion table provided in the guide. 

Evaluation using the GS-1106 Position Classification Standard (PCS)

The appellant’s work related to reviewing TRPs prior to their submission to NSSC is evaluated using the GS-1106 PCS for the Procurement Clerical and Technician Series, which is also written in FES format. 

Factor 1, Knowledge required by the position

The knowledge required by the appellant’s position generally meets Level 1-4 (the highest level described under this factor).  At this level, the work requires in-depth or broad knowledge of a body of procurement regulations, procedures, and policies including, for example, knowledge of the wide variety of interrelated steps and procedures required to assemble, review, and maintain procurement files related to complex contracts (e.g., large purchases for specialized supplies or for services and construction), and knowledge of the requirements of various contract clauses and special laws (e.g., Davis-Bacon, Service Contract, Prompt Payment Acts, progress payments, first article production/testing requirements) to ensure the inclusion of necessary information or supporting documentation in bid and solicitation packages.

This accurately represents the knowledge requirements of the position (e.g., relevant portions of the NASA Grants Handbook, NASA FAR Supplement) in reviewing complex TRPs to ensure the required information has been provided and any additional documentation to support the request is included.

Level 1-4 is credited (550 points).

Factor 2, Supervisory controls

The supervision under which the appellant operates is consistent with Level 2-3 (the highest level described under this factor).  At this level, the supervisor assigns work with standing instructions on objectives, priorities, and deadlines and provides guidance for unusually involved situations.  The employee plans and carries out successive steps necessary to perform procurement support tasks and uses accepted practices or procedures to resolve problems and deviations.  Problems include, for example, purchases that cannot be processed using standard procedures or practices because of the specialized nature of the transaction or conflicting or lacking documentation.  The supervisor reviews completed work for technical soundness, appropriateness, and conformance to policy and requirements.

This factor level is essentially similar under both the GS-1106 PCS and the GS-500 JFS above, and the same analysis applies. 

Level 2-3 is credited (275 points).

Factor 3, Guidelines

The guidelines used by the appellant match Level 3-3 (the highest level described under this factor).  At this level, guidelines are not completely applicable to many aspects of the work because of the problem solving or complicated nature of the assignments.  The employee uses judgment to interpret guidelines, adapt procedures, decide approaches, and resolve specific problems; e.g., in resolving problems referred by others (ones that could not be resolved at lower levels).

The appellant's position fully meets but does not exceed this level in that it depicts the experienced judgment she must use in resolving potentially disallowable factors in TRPs identified by lower-graded employees. 

Level 3-3 is credited (275 points).

Factor 4, Complexity

The complexity of the appellant’s work is comparable to Level 4-3 (the highest level described under this factor).  At this level, the work involves various procurement support duties involving the use of different and unrelated procedures and methods resulting from, for example, the nonstandardized nature of the transactions or their interrelationship with other systems, requiring extensive coordination with various personnel.  The employee identifies the nature of the issue and determines the need for and obtains additional information through contacts and by reviewing regulations and manuals.  The following examples are provided in the PCS to illustrate this level:

• assemble and review various solicitation packages that involve numerous line items, contract clauses, provisions, and attachments for incompatible information or administrative discrepancies.
• use different established procedures to process applications for contracting officer warrants, review vendors' applications for bidder's mailing lists, screen incoming purchase request item descriptions for accuracy and adequacy, and monitor the status of purchase orders.
• provide procurement support work throughout the procurement cycle by assembling contracts, abstracting bids, processing amendments and modifications, monitoring the status of deliveries, reconciling invoices, and preparing information for closing out contracts.

The appellant's position fully meets but does not exceed this level in that she performs analogous work in reviewing TRPs (i.e., "solicitation packages") with numerous clauses and provisions for completeness and conformance to basic administrative requirements, and in processing amendments and modifications.

Level 4-3 is credited (150 points).

Factor 5, Scope and effect

The scope and effect of the appellant’s work meet Level 5-3 (the highest level described under this factor).  At this level, the purpose of the work is to apply conventional practices to treat a variety of problems in procurement transactions.  Problems might result, for example, from insufficient information in contract files, a need for more efficient processing procedures, or requests to expedite urgently needed items.  The work results in recommendations, solutions, or reports that directly affect customer or vendor relations or operations.

The appellant's position fully meets but does not exceed this level in that the specific purpose of her work is to resolve problems identified in TRPs, such as insufficient information or documentation, and the work results in recommendations that directly affect relations with the NASA program offices concerned with the expeditious processing of their grant actions.   

Level 5-3 is credited (150 points).

Factor 6, Personal contacts

               and

Factor 7, Purpose of contacts

     Persons contacted
The appellant’s personal contacts match level 2 (the highest level described under this factor), where contacts are with employees in the same agency but outside the immediate organization, such as with personnel in other functional areas, and/or with members of the general public in a moderately structured setting.

     Purpose of contacts
The purpose of the appellant's contacts is consistent with Level b, where contacts are to plan and coordinate actions to correct or prevent errors, delays, or other complications during the procurement cycle, such as by requesting other personnel to submit paperwork or correct errors in documentation.
Level 2b is credited (75 points).

Summary  

Factors	Level	Points
Knowledge Required	1-4	550
Supervisory Controls	2-3	275
Guidelines	3-3	275
Complexity	4-3	150
Scope and Effect	5-3	150
Personal Contacts and Purpose of Contacts	2b	75
Physical Demands	8-1	5
Work Environment	9-1	5
Total		1485

The total of 1485 points falls within the GS-7 range (1355-1600) on the grade conversion table provided in the PCS.

Decision

The highest grade level of work performed occupying 25 percent or more of the appellant’s work time is GS-8.  Therefore, the position is properly classified as GS-503-8, with the title at agency discretion.                            
 

 

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